16jl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes the practices of 16jl ("16jl," "we," "us," or "our") with respect to the collection, use, storage, disclosure, and protection of personal information provided by or collected about users ("you," "Player," or "User") of the 16jl website located at 16jl.asia and all associated platform services (collectively, the "Platform").

By registering an account on 16jl, accessing or using the Platform, or providing personal information to 16jl in any form, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal information as described herein.

This Policy should be read together with the 16jl Terms & Conditions, which are incorporated herein by reference. Defined terms used in the Terms & Conditions carry the same meaning in this Policy unless otherwise specified.

2. Data Controller

16jl is the data controller for personal information collected through the Platform. As data controller, 16jl is responsible for determining the purposes and means of processing your personal data and for ensuring that such processing complies with applicable Philippine law, including the Data Privacy Act of 2012 (RA 10173) and the regulations and issuances of the National Privacy Commission (NPC).

For all data privacy inquiries, access requests, correction requests, or complaints, you may contact the 16jl Data Protection Officer (DPO) at: [email protected] (plain text — not a clickable link). Please include "Data Privacy" in the subject line of your communication.

3. Information We Collect

3.1 Information You Provide Directly

When you register an account, use the Platform, or communicate with 16jl, we collect personal information that you provide to us, including:

• Registration data: Full legal name, date of birth, Philippine mobile number, email address, and chosen username;
• KYC and identity verification data: Government-issued Philippine identification documents (PhilSys/National ID, passport, driver's license), selfie photographs, and any additional identity verification documents requested for regulatory compliance;
• Payment and financial data: GCash account details, Maya account details, bank account numbers (BPI, BDO, Metrobank, UnionBank), transaction records, and deposit/withdrawal history;
• Communications data: Records of your interactions with 16jl customer support via live chat or email, including chat transcripts and support ticket records;
• Responsible gaming data: Self-reported responsible gaming preferences, deposit limit settings, self-exclusion requests, and cooling-off period applications.

3.2 Information Collected Automatically

When you access and use the Platform, we automatically collect certain technical and usage data, including:

• Device identifiers, device type, operating system, and browser information;
• IP address and approximate geographic location (country and region level);
• Session data including login times, session duration, pages visited, and features used;
• Game play records including games accessed, stakes placed, outcomes, and transaction timestamps;
• Cookies and similar tracking technologies (see Section 9 for details).

3.3 Information from Third Parties

16jl may receive personal information about you from third parties in connection with identity verification, fraud prevention, and regulatory compliance, including from:

• Payment processors and e-wallet providers (GCash, Maya) in connection with transaction processing and fund verification;
• Identity verification service providers engaged for KYC compliance;
• PAGCOR and other Philippine regulatory authorities, where required by law.

4. How We Use Your Information

16jl processes your personal information for the following purposes:

• Account creation and management: To register, verify, maintain, and administer your 16jl account, including processing your login credentials and managing your account security settings;
• KYC and regulatory compliance: To verify your identity and age (21+ requirement) as mandated by PAGCOR and applicable Philippine anti-money laundering (AML) and counter-terrorism financing (CTF) laws, including Republic Act No. 9160 (Anti-Money Laundering Act) as amended;
• Transaction processing: To process deposits, withdrawals, and game transactions in Philippine Peso via your chosen payment method;
• Platform operation and customer support: To provide, maintain, and improve the 16jl Platform and to respond to your support inquiries;
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited activities on the Platform;
• Responsible gaming: To implement and monitor responsible gaming tools including deposit limits, self-exclusion, and session controls;
• Regulatory reporting: To fulfill reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other applicable Philippine authorities;
• Marketing and promotions: To send you promotional communications about 16jl offers and bonuses, where you have not opted out of such communications. You may opt out of marketing communications at any time by contacting support.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 16jl processes your personal information on the following legal bases:

• Consent: For account registration, marketing communications, and non-mandatory data collection where you have provided express consent;
• Contractual necessity: For data processing required to fulfill our obligations to you under the 16jl Terms & Conditions, including account management and transaction processing;
• Legal obligation: For processing required to comply with PAGCOR licensing obligations, AML/CTF legislation, AMLC reporting requirements, NPC regulations, and other applicable Philippine law;
• Legitimate interests: For fraud prevention, platform security, responsible gaming monitoring, and analytics that are necessary for the safe and lawful operation of the 16jl Platform, provided these interests are not overridden by your data protection rights.

6. Sharing Your Information

16jl does not sell your personal information to third parties. We may share your personal information with the following categories of recipients in accordance with this Policy:

• Payment processors and e-wallet providers: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), and Philippine banking partners (BPI, BDO, Metrobank, UnionBank), solely for the purpose of processing your deposits and withdrawals;
• Identity verification providers: Third-party KYC service providers engaged to verify your identity documents as required by PAGCOR regulations;
• Game software providers: Licensed game studios whose games are available in the 16jl lobby, who may receive aggregated or anonymized game session data for technical support and game audit purposes;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law, regulation, court order, or lawful authority request;
• Professional advisors: Legal, financial, and compliance advisors bound by confidentiality obligations, where necessary for the operation or defense of 16jl's legal interests.

All third-party service providers engaged by 16jl are contractually required to process personal data only for specified purposes, to maintain appropriate security measures, and to comply with applicable data protection requirements.

7. Data Retention

16jl retains your personal information for as long as your account remains active and for such further periods as may be required to comply with applicable legal and regulatory obligations. Specific retention periods applicable to 16jl are as follows:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and Republic Act No. 9160 (Anti-Money Laundering Act);
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLC record-keeping requirements;
• Customer support communications: Retained for two (2) years from the date of each interaction, unless a longer period is required for ongoing dispute resolution;
• Marketing preferences and opt-out records: Retained for the duration of your account and for three (3) years thereafter to evidence your consent or opt-out status.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with applicable data protection standards.

8. Security Measures

16jl implements a range of technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 16jl Platform;
• Encrypted storage of sensitive account credentials and financial information using industry-standard hashing algorithms;
• Two-factor authentication (2FA) available for all account holders, providing an additional layer of protection beyond password credentials;
• Access controls limiting employee and contractor access to personal data on a need-to-know basis;
• Regular security assessments and monitoring of the Platform for potential vulnerabilities;
• Incident response procedures for detecting and responding to potential data security breaches in accordance with NPC notification requirements.

While 16jl employs robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the security of your account credentials. If you suspect unauthorized access to your account, please contact 16jl support immediately.

9. Cookies & Tracking Technologies

The 16jl Platform uses cookies and similar tracking technologies to enhance your user experience, maintain session security, and collect Platform analytics data. The categories of cookies used by 16jl include:

• Strictly necessary cookies: Required for the Platform to function, including session authentication cookies that keep you logged in during your gaming session;
• Performance and analytics cookies: Used to collect anonymized data about how users interact with the Platform, which pages are visited most frequently, and where technical errors occur, helping 16jl improve Platform performance;
• Functionality cookies: Used to remember your preferences such as language settings, display preferences, and recent game history.

16jl does not use third-party advertising tracking cookies or sell behavioral data to advertising networks. You may configure your browser to refuse or delete cookies; however, disabling strictly necessary cookies may prevent you from accessing certain Platform features, including account login.

10. Your Data Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 16jl:

• Right to be informed: The right to be informed of the existence of processing of your personal data, the purpose for which it is being processed, and the manner in which it is used — fulfilled by this Privacy Policy;
• Right of access: The right to request a copy of the personal data held about you by 16jl;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure / blocking: The right to request deletion or blocking of your personal data where processing is no longer necessary, provided that mandatory regulatory retention obligations are not thereby breached;
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to object: The right to object to processing of your personal data for direct marketing purposes at any time;
• Right to file a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact the 16jl Data Protection Officer at [email protected]. 16jl will respond to data rights requests within fifteen (15) business days of receipt. Requests may require identity verification before they are processed.

11. Children's Privacy

The 16jl Platform is strictly restricted to individuals aged 21 years and above in accordance with Philippine law and PAGCOR regulations. 16jl does not knowingly collect personal information from individuals under the age of 21. Account registration requires submission of identity verification documents confirming the applicant's age. Where 16jl becomes aware that personal data has been submitted by or on behalf of a person under 21 years of age, the associated account will be immediately suspended, all relevant data will be deleted, and any deposited funds will be returned to the originating payment method.

If you believe that a minor has registered or attempted to register an account on the 16jl Platform, please notify 16jl immediately at [email protected].

12. Cross-Border Data Transfers

16jl primarily processes and stores personal data within servers located in the Asia-Pacific region. Where personal data is transferred to or accessible by service providers or data processors located outside the Philippines (for example, identity verification service providers or game audit partners), 16jl ensures that such transfers are carried out in compliance with Section 21 of the Data Privacy Act of 2012 and NPC regulations on cross-border data transfers, including by implementing appropriate contractual safeguards such as data processing agreements with applicable data protection clauses.

By using the 16jl Platform, you consent to the transfer of your personal data to servers and service providers in jurisdictions outside the Philippines where such transfers are necessary for Platform operation, subject to the safeguards described above.

13. Responsible Gaming & Data

Responsible gaming data — including self-reported deposit limit settings, cooling-off periods, and self-exclusion requests — is treated with the highest level of confidentiality and is processed exclusively for the purposes of implementing the requested responsible gaming controls and fulfilling applicable PAGCOR compliance obligations. Self-exclusion records are retained for the duration of the exclusion period and for five (5) years thereafter.

For full details on responsible gaming tools available on 16jl, please visit the Responsible Gaming page. Assistance is also available through the NCMH Crisis Line: 1553 (Free, 24/7, Philippines).

14. Changes to This Policy

16jl reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, 16jl will provide notice to registered account holders via email to the address on file or via a prominent notice on the Platform at least seven (7) days prior to the revised Policy taking effect, except where an immediate update is required to comply with applicable law or regulatory direction.

The "Last updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the 16jl Platform following the effective date of a revised Policy constitutes your acceptance of the revised terms.

15. Contact & Data Protection Officer

For all data privacy matters, including access requests, correction requests, objection to processing, or privacy complaints, please contact the 16jl Data Protection Officer:

• Email: [email protected] — please include "Data Privacy" in the subject line
• Live Chat: Available 24/7 via your account dashboard

If you are not satisfied with 16jl's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent regulatory authority responsible for enforcing the Data Privacy Act of 2012.

16jl is committed to resolving all data privacy inquiries fairly and within the timeframes required by Philippine law.