jili89 Privacy Policy

1. Introduction

jili89 ("jili89," "we," "us," or "our") operates the online gaming platform accessible at jili89.club (the "Platform"). We are committed to protecting the privacy and personal data of all users ("you," "Player," or "User") who access or use the jili89 Platform. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This Privacy Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines. By registering an account on jili89 or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, jili89 acts as the Personal Information Controller ("PIC") in respect of the personal data you provide when using the Platform. As PIC, jili89 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

Where jili89 engages third-party service providers to process personal data on its behalf (for example, payment processors or identity verification providers), those third parties act as Personal Information Processors ("PIP") and are bound by data processing agreements that require them to process your data only on jili89's instructions and in accordance with applicable law.

3. Personal Data We Collect

jili89 collects the following categories of personal data from players and Platform users:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, government-issued ID number (e.g., PhilSys, passport, driver's licence)	Account registration, KYC/AML compliance, age verification
Contact Data	Philippine mobile number, email address, residential address	Account communications, support, regulatory reporting
Financial Data	GCash number, bank account details, transaction history, deposit and withdrawal records	Payment processing, AML compliance, fraud prevention
Technical Data	IP address, device type, browser type, operating system, session logs	Platform security, fraud detection, service improvement
Usage Data	Game history, betting patterns, session duration, feature interactions	Responsible gaming monitoring, personalisation, analytics
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer support, dispute resolution, quality assurance

jili89 does not collect sensitive personal information (as defined under Section 3(l) of the DPA) unless strictly required for regulatory compliance (e.g., health information relevant to a responsible gaming self-exclusion request), in which case explicit consent will be obtained separately.

4. How We Collect Your Data

jili89 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access or use the Platform.
• Third-party sources: Identity and fraud-screening data received from licensed identity verification providers, payment processors, and, where required by law, government databases or regulatory bodies such as PAGCOR and the AMLC.

5. How We Use Your Personal Data

jili89 processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your jili89 player account, including verifying your identity and age (21+ requirement) in compliance with PAGCOR regulations.
• Service delivery: To provide access to games, process bets, credit winnings, and deliver the full range of jili89 Platform services.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya / Maya, and Philippine bank transfers, and to maintain accurate financial records.
• Legal and regulatory compliance: To comply with obligations under the DPA, PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws, including mandatory reporting to the AMLC where required.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Customer support: To respond to your enquiries, resolve disputes, and improve the quality of our support services.
• Marketing and promotions: To send you information about jili89 promotions, bonuses, and new features, where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time.
• Platform improvement: To analyse usage patterns, conduct research, and improve the functionality, performance, and user experience of the jili89 Platform.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, jili89 processes your personal data on the following legal bases:

• Consent (Section 12(a) DPA): Where you have given your explicit, informed consent to the processing of your personal data for a specific purpose, such as marketing communications or the processing of sensitive personal information.
• Contractual necessity (Section 12(b) DPA): Where processing is necessary for the performance of the contract between you and jili89 (i.e., the Terms & Conditions), including account management, game delivery, and payment processing.
• Legal obligation (Section 12(c) DPA): Where processing is required to comply with a legal obligation applicable to jili89, including PAGCOR regulatory requirements, AMLA obligations, and NPC directives.
• Legitimate interests (Section 12(f) DPA): Where processing is necessary for the legitimate interests of jili89 or a third party, such as fraud prevention, platform security, and responsible gaming monitoring, provided that such interests are not overridden by your rights and freedoms.

7. Data Sharing & Disclosure

jili89 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: GCash (G-Xchange, Inc.), PayMaya / Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Licensed KYC and AML screening providers engaged to verify player identity and screen against sanctions lists.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and analytics service providers engaged to support the operation of the jili89 Platform, each bound by data processing agreements.
• Game content providers: Licensed game studios whose games are available on the jili89 Platform, to the extent necessary for game delivery and fairness certification.
• Professional advisers: Legal, accounting, and auditing firms engaged by jili89, subject to professional confidentiality obligations.

In the event of a merger, acquisition, or sale of all or substantially all of jili89's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

8. Data Retention

jili89 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and its implementing rules.
• KYC / identity verification documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by applicable law.
• Support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution.
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods for security investigations or legal proceedings.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with jili89's data disposal procedures.

9. Data Security

jili89 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the jili89 Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting access to personal data to authorised jili89 personnel on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the jili89 Platform.
• 24/7 security monitoring and incident response procedures.
• Staff training on data protection obligations and information security best practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jili89 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with NPC Circular No. 16-03.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jili89:

• Right to be informed: The right to be informed of the existence of processing, the nature of the data processed, and the purposes of processing — as set out in this Privacy Policy.
• Right of access: The right to obtain a copy of the personal data jili89 holds about you, together with information about how it is processed.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected or completed.
• Right to erasure or blocking: The right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful, subject to jili89's legal retention obligations.
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, including processing for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to damages: The right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data protection rights have been violated.

To exercise any of the above rights, please contact jili89's Data Protection Officer using the contact details in Section 15 below. jili89 will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11. Cookies & Tracking Technologies

jili89 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support security functions. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management, authentication, and security. These cannot be disabled.
• Functional cookies: Used to remember your preferences and settings, such as language and display options.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform, to help jili89 improve its services.
• Security cookies: Used to detect and prevent fraudulent activity and protect the integrity of the Platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jili89 Platform. jili89 does not use cookies for third-party advertising or cross-site tracking.

12. Minors

The jili89 Platform is strictly intended for individuals aged 21 years and above, in compliance with PAGCOR regulations and Philippine law. jili89 does not knowingly collect personal data from individuals under the age of 21. If jili89 becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the jili89 Platform, please contact our support team immediately.

13. International Data Transfers

Where jili89 transfers personal data outside the Philippines — for example, to cloud infrastructure providers or game content providers located in other jurisdictions — such transfers are conducted in accordance with Section 21 of the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers. jili89 ensures that adequate safeguards are in place, including contractual clauses that require the recipient to provide a level of data protection equivalent to that required under Philippine law.

14. Changes to This Privacy Policy

jili89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, jili89 will notify registered players via the email address or mobile number on file, or by posting a prominent notice on the Platform. The revised Privacy Policy will take effect on the date specified in the notice. Your continued use of the jili89 Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by jili89, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: Data Privacy Request – [Your Name]
• Response time: Within 15 business days of receipt

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated:

• NPC Website: privacy.gov.ph
• NPC Email: [email protected]