477jl Privacy Policy

1. Who We Are – The Data Controller

477jl ("we", "us", "477jl") is the data controller responsible for personal information collected through the 477jl Platform at https://477jl.org. 477jl operates as a PAGCOR-regulated online gaming service provider serving the Philippine market.

For all data privacy matters, 477jl has designated a Data Protection Officer (DPO) who may be contacted at the details provided in Section 13 of this Policy.

2. Personal Data We Collect

477jl collects personal data in the following categories:

477jl does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, health data, or religious beliefs. Where such information is inadvertently shared (e.g., in a support message), it will not be stored or processed beyond the resolution of the immediate query.

3. How We Use Your Personal Data

477jl processes your personal data for the following purposes:

• Account creation and management: Creating and maintaining your 477jl account, verifying your identity, and enabling 477jl login functionality;
• Service delivery: Enabling your participation in games, processing bets, crediting winnings, and facilitating deposits and withdrawals via GCash, Maya, BPI, BDO, and other payment methods;
• Regulatory compliance: Fulfilling PAGCOR licensing obligations, Anti-Money Laundering Act (AMLA) reporting requirements, and age verification mandates under Philippine law;
• Customer support: Responding to your queries, complaints, and requests submitted through live chat or email;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and applying responsible gaming measures in compliance with PAGCOR guidelines;
• Security and fraud prevention: Detecting and preventing unauthorized account access, fraudulent transactions, bonus abuse, and other prohibited conduct;
• Platform improvement: Analyzing aggregated, anonymized usage data to improve game performance, user interface, and overall Platform experience;
• Marketing communications: Sending promotional offers and updates to your registered mobile number or email address, subject to your communication preferences — you may opt out at any time through your Account Settings.

4. Legal Basis for Processing

477jl processes your personal data on the following legal grounds under the Philippine Data Privacy Act of 2012 (R.A. 10173):

• Contractual necessity: Processing required to provide you with the services you have contracted for by creating a 477jl account and accepting the Terms & Conditions;
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, Bureau of Internal Revenue (BIR) requirements, and orders from Philippine courts or law enforcement;
• Legitimate interests: Processing necessary for fraud detection, platform security, responsible gaming monitoring, and internal analytics, where these interests are not overridden by your rights;
• Consent: Processing for optional marketing communications, where you have provided express opt-in consent.

5. Data Sharing and Disclosure

477jl does not sell your personal data. We may share your personal data with the following categories of recipients under the conditions described:

• PAGCOR and Philippine regulatory authorities: As required by our operating license and applicable Philippine law, including mandatory reporting of suspicious transactions to the Anti-Money Laundering Council (AMLC);
• Payment processors: GCash (Mynt), PayMaya (Maya Bank), BPI, BDO, Metrobank, and other payment service providers engaged to process your financial transactions — each bound by their own privacy policies and applicable PCI-DSS standards;
• Game content providers: Software providers such as Pragmatic Play, PG Soft, Jili, and others may receive session-level technical data necessary to deliver game content, governed by data processing agreements that restrict their use of your data;
• KYC and identity verification partners: Third-party identity verification services used to satisfy PAGCOR-mandated Know Your Customer obligations;
• IT infrastructure providers: Cloud hosting, cybersecurity, and platform maintenance providers, all of whom are contractually bound to process data only on 477jl's instructions and to maintain appropriate security standards;
• Law enforcement and courts: Where required by valid legal process, court order, or at the discretion of 477jl to protect the rights, property, or safety of the Platform, its members, or the public.

6. Cookies and Tracking Technologies

477jl uses cookies and similar tracking technologies on the Platform. The following types of cookies may be set on your device:

• Essential cookies: Required for the Platform to function, including maintaining your logged-in session after completing 477jl login and remembering your security preferences. These cannot be disabled without impairing Platform functionality.
• Analytics cookies: Used to collect aggregated, anonymized data about how visitors use the Platform, which pages they visit, and where errors occur, enabling us to improve user experience.
• Preference cookies: Store your language, game view preferences, and other optional settings to improve your experience on return visits.
• Marketing cookies: Used to deliver promotional content relevant to your interests, if you have consented to marketing communications. These may be disabled via Account Settings or your browser's cookie management tools.

You may control cookie preferences through your browser settings. Blocking essential cookies will prevent you from accessing account features including 477jl login.

7. Data Retention

477jl retains personal data for as long as necessary to fulfil the purposes described in this Policy, including compliance with legal obligations:

• Active account data: Retained for the duration of your account's active status plus five (5) years following account closure, in compliance with PAGCOR record-keeping requirements;
• Financial transaction records: Retained for a minimum of ten (10) years as required by the AMLA and BIR regulations;
• KYC and identity documents: Retained for the period of the account's existence plus five (5) years, or longer if required by law enforcement or regulatory investigation;
• Support communications: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained until consent is withdrawn and for a further one (1) year as evidence of compliance.

After the applicable retention period expires, personal data is securely deleted or anonymized in accordance with 477jl's data disposal procedures.

8. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 477jl:

To exercise any of the above rights, contact 477jl's DPO at [email protected] with the subject line "Data Subject Request". 477jl will respond within the timeframes required by R.A. 10173. Note that certain rights may be limited where processing is required for regulatory compliance or legitimate legal claims.

9. Children's Privacy

The 477jl Platform is strictly restricted to persons aged 21 years and over, in compliance with PAGCOR regulations governing online gaming in the Philippines. 477jl does not knowingly collect personal data from individuals under the age of 21.

If 477jl discovers that personal data has been collected from an individual under 21 years of age, that account will be suspended immediately, all associated funds will be returned (net of any chargeable costs), and the personal data will be deleted as soon as practicable. If you believe a minor has created a 477jl account, please contact us immediately at [email protected].

10. Cross-Border Data Transfers

477jl primarily stores and processes personal data within the Philippines. Where it is necessary to transfer data to service providers or game content partners operating outside the Philippines (for example, software providers with server infrastructure in other ASEAN jurisdictions), 477jl ensures that such transfers are made only to recipients that provide an adequate level of data protection, whether through contractual safeguards, data processing agreements, or equivalent legal mechanisms recognized under R.A. 10173.

477jl will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your express consent, except where required by applicable Philippine law.

11. Security Measures

477jl implements technical and organizational security measures proportionate to the sensitivity of the personal data we process:

• Encryption: All data transmitted between your device and 477jl servers is encrypted using TLS 1.3 with 256-bit AES encryption. Financial data is processed through PCI-DSS Level 1 compliant payment infrastructure;
• Access controls: Personal data access within 477jl's systems is restricted on a need-to-know basis, with role-based access controls and multi-factor authentication required for administrative access;
• Audit logging: All access to personal data is logged and monitored. Audit logs are retained for a minimum of one year and are available to PAGCOR for inspection;
• Penetration testing: 477jl's infrastructure undergoes regular third-party security assessments and penetration testing;
• Staff training: All 477jl personnel with access to personal data receive data privacy training upon onboarding and annually thereafter.

While 477jl takes all reasonable steps to protect your personal data, no online system can guarantee absolute security. You are encouraged to use a strong, unique password for your 477jl account and to protect your 477jl login credentials from disclosure to others.

12. Changes to This Privacy Policy

477jl reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. The "Last Updated" date at the top of this page will be revised accordingly whenever material changes are made.

Where changes significantly affect your rights or the manner in which 477jl uses your personal data, we will provide notice via your registered email address or a prominent notice on the Platform before the changes take effect. Your continued use of the 477jl Platform following the publication of changes constitutes your acceptance of the revised Privacy Policy.

13. Contact and Data Protection Officer

For all data privacy inquiries, requests to exercise your data subject rights, or to contact 477jl's designated Data Protection Officer, please use the following contact details:

477jl aims to respond to all data subject requests within fifteen (15) business days of receipt. Complex requests may require an extension, of which you will be notified in writing.

You have the right to lodge a complaint directly with the Philippine National Privacy Commission (NPC) if you are not satisfied with 477jl's handling of your personal data. Information on how to file a complaint with the NPC is available on the NPC's official website.