Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by jiliji through our website, mobile applications, customer support channels, and any other services we provide (collectively, the "Services"). By using jiliji, you acknowledge that you have read, understood, and agree to the data practices described in this Privacy Policy.

jiliji operates as a data controller under Philippine law, meaning we determine the purposes and means of processing your personal data. We are committed to processing your information lawfully, fairly, and transparently.

1.1 Data Controller Information

The data controller responsible for your personal information is:

• Entity Name: jiliji Online Gaming Services
• Business Address: Philippines (specific address available upon request)
• Data Protection Officer: [email protected]
• General Inquiries: [email protected]

1.2 Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to provide our Services, process transactions, and fulfill our obligations under our Terms & Conditions.
• Legal Obligation: Processing is required to comply with Philippine gaming regulations, anti-money laundering laws, tax obligations, and other legal requirements.
• Legitimate Interests: Processing is necessary for fraud prevention, security, service improvement, and business operations, provided such interests do not override your fundamental rights.
• Consent: For marketing communications, cookies, and optional data collection, we obtain your explicit consent, which you may withdraw at any time.

2. Information We Collect

2.1 Information You Provide Directly

When you register, use our Services, or contact us, we collect the following categories of personal information:

Data Category	Examples	Purpose
Identity Information	Full name, date of birth, gender, government-issued ID numbers	Account registration, age verification, regulatory compliance
Contact Information	Email address, phone number, residential address	Communication, account recovery, fraud prevention
Financial Information	Payment method details, bank account information, transaction history	Deposits, withdrawals, financial reporting
Account Credentials	Username, password (encrypted), security questions	Account access, authentication, security
Verification Documents	Government ID, proof of address, selfie photos	Identity verification, anti-fraud measures
Communication Records	Support tickets, live chat transcripts, emails	Customer service, dispute resolution, quality assurance

2.2 Information Collected Automatically

When you use jiliji, we automatically collect technical and usage information through cookies, server logs, and analytics tools:

• Device Information: Device type, operating system, browser type and version, unique device identifiers.
• Usage Data: Pages visited, features used, games played, bet history, session duration, clickstream data.
• Location Data: IP address, geolocation data (to verify you are in a permitted jurisdiction and comply with gaming regulations).
• Performance Data: Error logs, crash reports, loading times, API response times.
• Cookie Data: Cookies and similar tracking technologies used for authentication, preferences, analytics, and advertising (see Section 7 for details).

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction confirmation, payment verification, fraud screening results from GCash, Maya, banks, and cryptocurrency providers.
• Identity Verification Services: Age verification, identity authentication, and fraud detection data from specialized verification providers.
• Game Providers: Game results, RTP statistics, and gameplay data from third-party casino and sports betting providers.
• Marketing Partners: If you come to jiliji through an affiliate or advertising partner, we may receive limited data about the referring source.
• Public Databases: Information from public records, sanctions lists, and politically exposed persons (PEP) databases for compliance purposes.

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your jiliji account
• Processing deposits, bets, and withdrawal requests
• Providing access to games, sports betting, and other Services
• Authenticating your identity and securing your account
• Managing bonuses, promotions, and loyalty programs
• Providing customer support and responding to inquiries

3.2 Legal and Regulatory Compliance

• Verifying your age and eligibility to use our Services (21+ requirement)
• Complying with Philippine gaming regulations and PAGCOR requirements
• Conducting anti-money laundering (AML) checks and reporting suspicious activity
• Fulfilling tax reporting obligations
• Responding to legal requests from courts, regulators, and law enforcement
• Maintaining records as required by law (typically 5-7 years for financial records)

3.3 Security and Fraud Prevention

• Detecting and preventing fraud, collusion, bonus abuse, and other prohibited activities
• Monitoring for suspicious betting patterns or account behavior
• Protecting against cyberattacks, unauthorized access, and security breaches
• Enforcing our Terms & Conditions and other policies
• Investigating disputes and resolving complaints

3.4 Service Improvement and Analytics

• Analyzing usage patterns to improve user experience
• Testing new features and conducting A/B testing
• Optimizing website and app performance
• Understanding player preferences and game popularity
• Generating anonymized statistics and reports

3.5 Marketing and Communications

• Sending promotional offers, bonuses, and news about jiliji (with your consent)
• Personalizing marketing based on your interests and gaming activity
• Conducting customer satisfaction surveys
• Sending transactional communications (account notifications, withdrawal confirmations, etc.)

Note: You can opt out of marketing communications at any time through your account settings or by clicking "unsubscribe" in our emails. Transactional communications cannot be opted out as they are necessary for service delivery.

4. How We Share Your Information

We do not sell your personal information to third parties. However, we may share your data with the following categories of recipients under strict confidentiality agreements and data processing terms:

4.1 Service Providers and Business Partners

• Payment Processors: GCash, Maya, BPI, BDO, cryptocurrency exchanges, and other payment providers to process deposits and withdrawals.
• Game Providers: Third-party game developers and live casino operators who provide our gaming content.
• Identity Verification Services: Specialized companies that verify age, identity, and conduct fraud screening.
• Cloud Infrastructure Providers: Secure hosting and data storage services.
• Customer Support Tools: Live chat, ticketing, and CRM platforms.
• Analytics and Marketing Platforms: Tools for website analytics, email marketing, and advertising (with appropriate data protection safeguards).

4.2 Legal and Regulatory Authorities

We may disclose your information when required by law or in good faith belief that such disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests from PAGCOR or other government agencies
• Report suspicious transactions under anti-money laundering regulations
• Protect our rights, property, or safety, or that of our users or the public
• Investigate and prevent fraud, security threats, or illegal activities

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the successor entity. We will notify you via email and/or prominent notice on our website before your data is transferred and becomes subject to a different privacy policy.

4.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for research, analytics, or business purposes. This data does not constitute personal information under Philippine law.

5. Data Security Measures

We implement industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Safeguards

• Encryption: All data transmitted between your device and our servers is protected using 256-bit SSL/TLS encryption. Sensitive data at rest is encrypted using AES-256 encryption.
• Secure Authentication: Passwords are hashed using bcrypt with salt. We support two-factor authentication (2FA) for enhanced account security.
• Firewalls and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls and real-time intrusion detection systems.
• Regular Security Audits: We conduct quarterly security assessments and penetration testing by independent third parties.
• Secure Data Centers: Our data is hosted in ISO 27001 certified data centers with physical access controls, 24/7 monitoring, and redundant backups.

5.2 Organizational Safeguards

• Access Controls: Access to personal data is restricted to authorized employees who need it for their job functions, enforced through role-based access controls.
• Employee Training: All staff receive regular training on data protection, privacy practices, and security protocols.
• Confidentiality Agreements: All employees and contractors sign strict confidentiality agreements.
• Incident Response Plan: We maintain a comprehensive data breach response plan to quickly contain and remediate security incidents.
• Vendor Management: All service providers undergo security assessments and must comply with our data protection standards.

5.3 Data Breach Notification

In the unlikely event of a data breach affecting your personal information, we will notify you and the Philippine National Privacy Commission within 72 hours of discovering the breach, as required by law. The notification will include:

• The nature of the breach and categories of data affected
• The likely consequences of the breach
• Measures we have taken or propose to take to address the breach
• Steps you can take to protect yourself

6. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012 and international best practices, you have the following rights regarding your personal information:

6.1 Right to Access

You have the right to obtain confirmation that we are processing your personal data and to access that data. You can view most of your information directly in your account dashboard. For additional data, contact our Data Protection Officer.

6.2 Right to Rectification

If your personal information is inaccurate or incomplete, you have the right to request correction. You can update most information directly in your account settings. For verification documents or other restricted data, submit a request to our support team.

6.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal information under certain circumstances, such as when:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent (where processing was based on consent)
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed

Important: We may retain certain information as required by law (e.g., financial records for tax purposes) or for legitimate business purposes (e.g., fraud prevention, dispute resolution). We will inform you if we cannot fully comply with an erasure request and explain the reasons.

6.4 Right to Restrict Processing

You have the right to request that we limit how we use your data in certain situations, such as when you contest the accuracy of your data or object to processing.

6.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller. Contact our Data Protection Officer to request a data export.

6.6 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes (which we will honor immediately) or for other purposes based on legitimate interests (which we will honor unless we demonstrate compelling legitimate grounds).

6.7 Right to Withdraw Consent

Where we process your data based on consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing conducted prior to withdrawal.

6.8 Exercising Your Rights

To exercise any of these rights, contact us at:

• Email: [email protected]
• Subject Line: "Data Privacy Request"
• Include: Your full name, account email, and specific request

We will respond to your request within 15 days and verify your identity before processing requests involving sensitive data. There is no charge for most requests, but we may charge a reasonable fee for excessive or manifestly unfounded requests.

6.9 Right to Lodge a Complaint

If you believe we have violated your privacy rights, you have the right to lodge a complaint with the Philippine National Privacy Commission:

• Website: privacy.gov.ph
• Email: [email protected]
• Phone: (02) 8234-2228

7. Cookies and Tracking Technologies

jiliji uses cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver personalized content. By using our Services, you consent to our use of cookies as described below.

7.1 What Are Cookies?

Cookies are small text files stored on your device by your web browser. They allow websites to remember your preferences, authenticate your session, and collect usage data.

7.2 Types of Cookies We Use

• Essential Cookies: Required for basic website functionality, authentication, and security. These cannot be disabled.
• Performance Cookies: Collect anonymous data about how you use jiliji to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (language, region) and provide personalized features.
• Advertising Cookies: Track your activity across websites to deliver relevant ads and measure campaign effectiveness.

7.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may impair website functionality. You can manage non-essential cookies through our cookie consent banner or in your account settings.

7.4 Third-Party Cookies

Some cookies are set by third-party services we use (analytics providers, advertising networks). These third parties have their own privacy policies governing their use of your data.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

8.1 Retention Periods

• Active Accounts: Data is retained for the duration of your account and for a period thereafter as required by law (typically 5-7 years for financial and transactional records).
• Closed Accounts: When you close your account, most personal data is deleted within 90 days, except for records we must retain for legal, regulatory, or fraud prevention purposes.
• Marketing Data: If you opt out of marketing communications, we will retain only enough information to honor your opt-out request.
• Support Records: Customer support communications are retained for 3 years for quality assurance and dispute resolution.
• Security Logs: Security and audit logs are retained for 12 months.

8.2 Secure Disposal

When data is no longer needed, we securely delete or anonymize it using industry-standard methods to prevent recovery or reconstruction.

9. International Data Transfers

Your personal information may be transferred to and processed in countries outside the Philippines, including jurisdictions that may not offer the same level of data protection as Philippine law. When we transfer data internationally, we implement appropriate safeguards, including:

• Standard contractual clauses approved by relevant data protection authorities
• Ensuring that service providers comply with internationally recognized data protection standards
• Using encryption and secure transmission protocols

By using jiliji, you consent to the transfer of your information as described in this Privacy Policy.

10. Children's Privacy

jiliji is strictly for users aged 21 and above. We do not knowingly collect personal information from individuals under 21. If we discover that we have inadvertently collected data from someone under 21, we will immediately delete that information and close the associated account.

If you believe a minor has registered on jiliji, please contact us immediately at [email protected].

11. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Data Protection Officer: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 through your account dashboard
• Response Time: We aim to respond to all privacy inquiries within 72 hours