Effective Date: January 1, 2025
Last Updated: January 1, 2025
Governing Law: Republic of the Philippines Data Privacy Act of 2012 (RA 10173)
Data Controller: jilii1 Gaming Services
1. Introduction and Scope
jilii1 Gaming Services ("jilii1," "we," "us," or "our") is committed to protecting the privacy and personal data of our users ("you," "your," or "Player"). This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information when you access or use the jilii1 website (https://jilii1.cam), mobile applications, and related gaming services (collectively, the "Service").
This Policy is designed to comply with the Republic of the Philippines Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and related National Privacy Commission issuances. By creating an account, accessing the Service, or providing personal information to jilii1, you acknowledge that you have read, understood, and consent to the data processing practices described in this Policy.
Important: If you do not agree with this Privacy Policy, you must immediately discontinue use of the Service and refrain from providing any personal information to jilii1. Continued use of our platform constitutes acceptance of this Policy and our data practices.
2. Information We Collect
2.1 Information You Provide Directly
When you register for a jilii1 account or use our services, we collect personal information that you voluntarily provide, including but not limited to:
- Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification documents (passport, driver's license, national ID, or UMID) required for age verification and Know Your Customer (KYC) compliance;
- Contact Information: Residential address, email address, mobile phone number, and preferred communication channels;
- Financial Information: Bank account details, e-wallet account information (GCash, PayMaya), payment card information, transaction history, deposit and withdrawal records;
- Account Credentials: Username, password (stored in encrypted form), security questions and answers, and two-factor authentication settings;
- Communication Records: Correspondence with customer support via email, live chat, social media messages, and phone calls (which may be recorded for quality assurance and training purposes);
- Verification Documents: Proof of identity, proof of address (utility bills, bank statements), selfie photographs for identity verification, and source of funds documentation.
2.2 Information Collected Automatically
When you access or use the jilii1 Service, we automatically collect technical and usage information through cookies, log files, and similar tracking technologies:
- Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, IDFA, Android ID), and mobile network information;
- Connection Data: IP address, internet service provider, geographic location data (country, region, city based on IP geolocation), time zone settings;
- Usage Data: Pages visited, features accessed, time spent on pages, clickstream data, search queries, games played, bet history, session duration, and navigation patterns;
- Performance Data: Error logs, crash reports, application performance metrics, loading times, and technical diagnostics;
- Cookie Data: Session cookies, preference cookies, analytics cookies, and advertising cookies (see Section 9 for detailed cookie information).
2.3 Information from Third-Party Sources
We may receive information about you from third-party sources including payment processors (GCash, PayMaya, banks), identity verification services, fraud prevention agencies, credit reference agencies, and publicly available sources to verify your identity, prevent fraud, and comply with anti-money laundering regulations.
3. How We Use Your Information
3.1 Primary Purposes
jilii1 processes your personal information for the following legitimate business purposes:
- Account Management: Creating and maintaining your player account, authenticating your identity, processing login sessions, managing your profile settings and preferences;
- Service Delivery: Providing access to casino games, sports betting, live dealer tables, and all gaming services; processing bets and wagers; calculating and crediting winnings; maintaining game history;
- Financial Transactions: Processing deposits, withdrawals, and internal transfers; verifying payment methods; preventing payment fraud; reconciling accounts; generating financial statements;
- Regulatory Compliance: Verifying age (21+ requirement), conducting KYC and anti-money laundering (AML) checks, reporting to Philippine Amusement and Gaming Corporation (PAGCOR) as required, maintaining records for audit purposes;
- Security and Fraud Prevention: Detecting and preventing fraud, money laundering, collusion, bonus abuse, multi-accounting, and unauthorized access; monitoring suspicious activity; enforcing Terms and Conditions;
- Customer Support: Responding to inquiries, resolving technical issues, handling complaints, providing assistance via live chat, email, phone, and social media channels;
- Communication: Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts), promotional offers, bonus announcements, newsletters, and service updates;
- Personalization: Customizing user experience, recommending games based on preferences, tailoring promotional offers, displaying personalized content;
- Analytics and Improvement: Analyzing user behavior, measuring platform performance, conducting A/B testing, improving features, developing new services, optimizing user interface;
- Marketing: Sending promotional communications, displaying targeted advertisements, conducting surveys, analyzing marketing campaign effectiveness (subject to your consent where required by law).
3.2 Legal Basis for Processing
Under Philippine Data Privacy Act, we process your personal information based on the following legal grounds:
- Contractual Necessity: Processing required to fulfill our obligations under the Terms and Conditions you accepted when creating your account;
- Legal Obligation: Processing required to comply with Philippine gaming regulations, anti-money laundering laws, tax obligations, and court orders;
- Legitimate Interests: Processing necessary for fraud prevention, security, network integrity, and business analytics, balanced against your privacy rights;
- Consent: Processing based on your explicit consent for marketing communications, non-essential cookies, and optional data collection, which you may withdraw at any time.
4. Information Sharing and Disclosure
4.1 Service Providers and Partners
jilii1 shares your personal information with carefully selected third-party service providers who assist us in operating the Service, subject to strict confidentiality obligations:
- Payment Processors: GCash, PayMaya, local banks, and international payment gateways for processing deposits and withdrawals;
- Identity Verification Services: Third-party KYC providers for age verification, identity authentication, and document validation;
- Game Providers: Licensed casino game developers and sports betting data providers;
- Cloud Hosting: Infrastructure providers for data storage, server hosting, and content delivery networks;
- Customer Support: Live chat platforms, email services, and CRM systems;
- Marketing Services: Email marketing platforms, SMS providers, analytics services, and advertising networks;
- Security Services: Fraud detection agencies, DDoS protection services, and cybersecurity consultants.
4.2 Legal and Regulatory Disclosure
We may disclose your personal information when required by law or in good faith belief that such disclosure is necessary to:
- Comply with legal obligations, court orders, subpoenas, or regulatory requests from PAGCOR, National Privacy Commission, or law enforcement agencies;
- Enforce our Terms and Conditions, investigate violations, and protect against fraud or security threats;
- Protect the rights, property, or safety of jilii1, our users, or the public as required or permitted by law;
- Respond to claims that content violates third-party rights or applicable laws.
4.3 Business Transfers
In the event of a merger, acquisition, corporate reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity, subject to the same privacy protections outlined in this Policy.
4.4 No Sale of Personal Information
jilii1 does not sell, rent, or trade your personal information to third parties for their independent marketing purposes. Any data sharing is strictly limited to service delivery, legal compliance, and operational necessity as described in this Policy.
5. Data Security and Protection
5.1 Technical Security Measures
jilii1 implements industry-standard technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:
- Encryption: 256-bit SSL/TLS encryption for data transmission; AES-256 encryption for stored sensitive data including passwords and financial information;
- Access Controls: Role-based access restrictions, multi-factor authentication for administrative access, regular access audits;
- Network Security: Firewalls, intrusion detection systems, DDoS protection, regular security vulnerability assessments;
- Data Segregation: Logical separation of personal data, financial data, and operational data;
- Monitoring: 24/7 security monitoring, automated threat detection, incident response procedures;
- Regular Updates: Timely application of security patches, software updates, and infrastructure maintenance.
5.2 Organizational Security Measures
- Confidentiality agreements with all employees and contractors with access to personal data;
- Security awareness training for staff handling sensitive information;
- Background checks for employees in security-sensitive roles;
- Data breach response plan and incident management procedures;
- Regular security audits and compliance assessments.
5.3 User Responsibility
While jilii1 implements robust security measures, you also play a critical role in protecting your account. You are responsible for maintaining the confidentiality of your login credentials, using strong passwords, enabling two-factor authentication, and immediately notifying us of any unauthorized access or security concerns.
6. Data Retention
jilii1 retains your personal information for as long as necessary to fulfill the purposes outlined in this Policy and comply with legal, regulatory, accounting, and reporting obligations:
- Active Accounts: Personal information is retained throughout the duration of your active account relationship with jilii1;
- Closed Accounts: After account closure, we retain personal information for a minimum of five (5) years as required by Philippine gaming regulations, anti-money laundering laws, and tax compliance;
- Transaction Records: Financial transaction records, bet history, and game logs are retained for at least seven (7) years for audit, dispute resolution, and regulatory purposes;
- Marketing Data: Marketing contact information is retained until you withdraw consent or unsubscribe, after which it is deleted within thirty (30) days;
- Legal Requirements: In cases involving legal disputes, investigations, or regulatory proceedings, relevant data may be retained until resolution and expiration of applicable limitation periods.
Upon expiration of retention periods, personal information is securely deleted or anonymized beyond reconstruction. Anonymized and aggregated data that cannot identify individuals may be retained indefinitely for statistical, analytical, and research purposes.
7. Your Privacy Rights
Under the Philippine Data Privacy Act, you have the following rights regarding your personal information:
7.1 Right to Access
You have the right to obtain confirmation of whether jilii1 is processing your personal data and to access a copy of that data. You may request information about the purposes of processing, categories of data collected, recipients of data, and retention periods.
7.2 Right to Correction
You have the right to request correction of inaccurate, incomplete, or outdated personal information. You may update most account information directly through your jilii1 profile settings.
7.3 Right to Erasure ("Right to be Forgotten")
You may request deletion of your personal information under certain circumstances, subject to legal retention obligations. Requests will be honored unless we are required to retain the information for compliance, legal, or legitimate business purposes.
7.4 Right to Object
You have the right to object to processing of your personal data for direct marketing purposes, including profiling. You may opt out of marketing communications at any time by clicking unsubscribe links or adjusting your communication preferences.
7.5 Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.
7.6 Right to Lodge a Complaint
You have the right to file a complaint with the National Privacy Commission if you believe jilii1 has violated your data privacy rights. Contact details: National Privacy Commission, 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City; Email: [email protected]; Hotline: (+632) 8234-2228.
7.7 Exercising Your Rights
To exercise any of these rights, submit a written request to our Data Protection Officer at [email protected]. We will respond to verified requests within fifteen (15) business days. Identity verification may be required to prevent unauthorized access to your information.
8. International Data Transfers
While jilii1 primarily operates within the Philippines, some of our service providers and partners may be located outside the Philippines, including cloud storage providers, payment processors, and game developers. When we transfer your personal information internationally, we ensure appropriate safeguards are in place through:
- Standard contractual clauses approved by the National Privacy Commission;
- Data processing agreements with security and confidentiality obligations;
- Verification that recipient countries provide adequate data protection levels;
- Regular compliance audits of international service providers.
By using the jilii1 Service, you consent to the transfer of your personal information outside the Philippines under these protective measures.
9. Cookies and Tracking Technologies
9.1 Types of Cookies We Use
jilii1 uses cookies, web beacons, pixels, and similar tracking technologies to enhance user experience, analyze usage, and deliver personalized content:
- Essential Cookies: Required for basic platform functionality, authentication, security, and session management. These cannot be disabled without affecting Service usability;
- Performance Cookies: Collect anonymized data about how users interact with the Service, helping us identify issues and improve performance;
- Functionality Cookies: Remember your preferences, language settings, and customization choices to provide a personalized experience;
- Advertising Cookies: Used to deliver relevant advertisements, measure campaign effectiveness, and limit ad frequency. These cookies may be set by third-party advertising networks.
9.2 Managing Cookies
You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies, though disabling essential cookies may impair platform functionality. You can also opt out of third-party advertising cookies through industry opt-out tools.
10. Children's Privacy
The jilii1 Service is strictly intended for individuals aged twenty-one (21) years and older. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected information from an individual under 21, we will immediately delete that information and terminate the associated account. Parents or guardians who believe a minor has provided information to jilii1 should contact us immediately at [email protected].
11. Changes to This Privacy Policy
jilii1 reserves the right to modify, update, or revise this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Material changes will be communicated via email notification to registered users and prominently displayed on the website at least thirty (30) days before taking effect. Your continued use of the Service following the posting of updated terms constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically to remain informed about how we protect your information.
12. Contact Information
For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:
- Data Protection Officer: [email protected]
- Customer Support: [email protected]
- Live Chat: Available 24/7 through the jilii1 website
- Mailing Address: jilii1 Gaming Services, Metro Manila, Philippines
We are committed to resolving privacy concerns promptly and transparently. All inquiries will be acknowledged within forty-eight (48) hours and substantively addressed within fifteen (15) business days.