Privacy Policy

1 Introduction

jilli 1 takes the privacy of its players seriously. As a PAGCOR-regulated online gaming platform serving Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and throughout the Philippine archipelago, jilli 1 processes personal data in connection with account registration, identity verification, gaming activity, financial transactions, and customer support.

This Policy is issued in compliance with the Republic of the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). Where applicable, this Policy also reflects standards aligned with international data privacy best practices.

By creating a jilli 1 account and using our platform, you acknowledge that you have read and understood this Policy, and you consent to the collection and processing of your personal data as described herein. If you do not consent to the practices described in this Policy, you should not use the jilli 1 platform.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, jilli 1 is the personal information controller in respect of the personal data of players and visitors to the jilli 1 platform. jilli 1 determines the purposes and means of processing personal data collected through the jilli 1 website and associated services.

jilli 1 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and with applicable data privacy law. Contact details for the jilli 1 DPO are provided in Section 15 of this Policy.

Where jilli 1 engages third-party service providers — such as payment processors, identity verification services, gaming software providers, or cloud infrastructure providers — those parties act as personal information processors, processing data on jilli 1's behalf and under jilli 1's instructions. jilli 1 requires all processors to maintain appropriate security and confidentiality standards consistent with this Policy.

3 Personal Data We Collect

jilli 1 collects the following categories of personal data, depending on how you interact with the platform:

Data Category	Specific Examples	Collection Point
Identity Data	Full legal name, date of birth, nationality, government-issued ID number (e.g., PhilSys ID, Passport, UMID)	Account registration; KYC verification
Contact Data	Philippine mobile number (Smart, Globe, or DITO), email address, residential address	Account registration; account settings
Financial Data	GCash account reference, Maya account reference, bank account name/number (BPI, BDO, UnionBank), transaction histories	Deposit and withdrawal requests
Gaming Activity Data	Game session logs, bet amounts, game outcomes, wagering history, bonus redemptions, VIP tier activity	Platform activity; automatically generated
Technical Data	IP address, device type, browser type and version, operating system, screen resolution, session timestamps	Automatically collected on platform access
Communications Data	Live chat transcripts, email correspondence, SMS OTP logs, support ticket records	Customer support interactions
Preference Data	Saved payment methods, responsible gaming tool settings, marketing preferences, language settings	Account settings; platform usage

jilli 1 does not collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act — such as racial or ethnic origin, religious beliefs, health data, or political opinions — unless specifically required by applicable law or regulation (e.g., PAGCOR-mandated responsible gaming assessments).

4 How We Collect Your Data

jilli 1 collects personal data through the following means:

Direct collection: Data you provide voluntarily when registering a jilli 1 account, completing identity verification (KYC), making deposits or withdrawals, contacting customer support, or participating in promotions.
Automated collection: Technical data collected automatically when you access the jilli 1 platform, including IP address, device identifiers, browser information, and session activity logs. This data is collected using cookies, server logs, and similar technologies as described in Section 9.
Third-party sources: Identity verification data received from PAGCOR or third-party KYC service providers; fraud prevention data received from financial intelligence services; payment confirmation data received from GCash, Maya, BPI, BDO, and other payment processors.
Publicly available sources: Publicly available information used to verify identity or to conduct AML due diligence, consistent with jilli 1's obligations under the Anti-Money Laundering Act of 2001 (AMLA) as amended.

5 Legal Basis for Processing

jilli 1 processes your personal data on one or more of the following legal bases under the Data Privacy Act of 2012:

Consent: Where you have provided clear and informed consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or enabling personalised game recommendations.
Contractual necessity: Processing necessary for jilli 1 to perform the contract entered into with you when you create a jilli 1 account and agree to our Terms & Conditions — including account management, game access, payment processing, and customer support.
Legal obligation: Processing required for jilli 1 to comply with applicable Philippine laws and regulations, including PAGCOR licensing obligations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable legislation.
Legitimate interests: Processing necessary for jilli 1's legitimate business interests, where such interests are not overridden by your rights and interests. This includes fraud prevention, platform security, responsible gaming monitoring, and statistical analysis to improve the platform.

6 How We Use Your Personal Data

jilli 1 uses the personal data we collect for the following specific purposes:

Account registration and management: Creating and maintaining your jilli 1 account, verifying your identity, managing your VIP tier, and enabling your access to all platform features.
Payment processing: Facilitating deposits and withdrawals via GCash, Maya, BPI, BDO, UnionBank, and other payment channels; maintaining transaction records; and complying with AML reporting obligations.
Gaming services: Enabling access to all jilli 1 games — live casino, slots, sports betting, and bingo — and maintaining game history records for transparency and dispute resolution.
Security and fraud prevention: Monitoring account activity for suspicious behaviour, unauthorised access, multi-accounting, and other fraudulent activity; operating device fingerprinting and IP monitoring systems.
Regulatory compliance: Fulfilling jilli 1's obligations under PAGCOR's regulatory framework, AMLA reporting requirements, NPC data privacy compliance, and age verification obligations.
Responsible gaming: Monitoring gaming patterns to identify players who may be exhibiting signs of problem gambling; communicating with players regarding responsible gaming tools and resources; processing self-exclusion requests.
Customer support: Processing your queries, complaints, and support requests efficiently and maintaining records of communications for quality assurance and dispute resolution.
Marketing and promotions: Sending promotional offers, bonus notifications, and platform updates to players who have consented to receive such communications. You may opt out of marketing communications at any time via your account settings or by contacting support.
Platform improvement: Analysing aggregated and anonymised platform usage data to improve the jilli 1 user experience, optimise game selection, and enhance technical performance.

7 Sharing and Disclosure of Your Data

jilli 1 does not sell, rent, or trade your personal data to third parties for their own marketing purposes under any circumstances. jilli 1 may share your personal data with the following categories of recipients, strictly as necessary:

PAGCOR and regulatory authorities: jilli 1 is required to share player account data, transaction data, and gaming activity data with PAGCOR upon request, as part of its regulatory obligations as a PAGCOR-licensed operator.
Anti-money laundering authorities: jilli 1 is obligated to report suspicious transactions to the Anti-Money Laundering Council (AMLC) in accordance with the Anti-Money Laundering Act of 2001 as amended.
Payment processors: Transaction data is shared with GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, UnionBank, and other payment processors strictly as required to process your financial transactions.
Identity verification service providers: Identity document data and biometric data (where collected) may be shared with third-party KYC service providers engaged by jilli 1 to conduct identity verification. These providers are contractually bound to handle your data securely and in accordance with this Policy.
Technology and infrastructure providers: Cloud hosting providers, cybersecurity service providers, and gaming software providers who operate systems on jilli 1's behalf. All such providers are bound by data processing agreements consistent with the Data Privacy Act.
Law enforcement: jilli 1 will disclose personal data to law enforcement agencies when required to do so by a valid court order, government directive, or where jilli 1 reasonably believes disclosure is necessary to prevent or investigate crime.
Corporate transactions: In the event of a merger, acquisition, restructuring, or sale of jilli 1's business or assets, personal data may be transferred to the relevant successor entity, subject to the successor entity's commitment to maintain equivalent privacy standards.

jilli 1 will never sell your personal data. Any sharing of personal data is limited to what is strictly necessary for the purpose described, and all recipients are bound by confidentiality and data security obligations consistent with the Data Privacy Act of 2012.

8 International Data Transfers

jilli 1 primarily processes and stores personal data within the Philippines on servers located in Philippine data centres. Where jilli 1 engages third-party service providers whose systems are located outside the Philippines — such as certain gaming software providers or cloud infrastructure partners — personal data may be transferred to, and processed in, jurisdictions outside the Philippines.

In such circumstances, jilli 1 ensures that any international transfer of personal data is subject to appropriate safeguards consistent with the Data Privacy Act's provisions on cross-border information flows. These safeguards include contractual data transfer agreements that require the recipient to maintain equivalent levels of data protection to those required under Philippine law.

jilli 1 does not transfer personal data to jurisdictions that the National Privacy Commission has determined to provide inadequate protection for personal data, except where specific safeguards have been approved by the NPC or required by a legitimate legal obligation.

9 Cookies & Tracking Technologies

The jilli 1 platform uses cookies and similar tracking technologies to operate certain essential functions of the platform, to improve user experience, and to assist in fraud prevention and security monitoring. The following categories of cookies are used on jilli 1:

Strictly necessary cookies: Required for the jilli 1 platform to function. These include session management cookies that keep you logged in, security tokens that protect against cross-site request forgery, and cookies that store your language preference. These cookies cannot be disabled without preventing the platform from functioning.
Functional cookies: Cookies that remember your preferences — such as your saved payment method, responsible gaming settings, and previously played games — to improve your experience on return visits.
Analytics cookies: Aggregated, anonymised cookies used to understand how players navigate the jilli 1 platform, which games are most popular, and how platform performance can be improved. These analytics are conducted on aggregated data only and cannot be used to identify individual players.
Security and fraud prevention cookies: Device fingerprinting and session integrity cookies used to detect multi-accounting, bot activity, and other fraudulent behaviour. These cookies are essential for maintaining platform security and PAGCOR compliance.

You may adjust your browser settings to refuse or delete cookies; however, disabling strictly necessary cookies will prevent you from accessing your jilli 1 account and using the platform. jilli 1 does not use third-party advertising or behavioural profiling cookies.

10 Data Security

jilli 1 implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, and misuse. These measures include:

256-bit SSL/TLS encryption for all data transmitted between your device and the jilli 1 platform;
Encrypted storage of all sensitive personal and financial data at rest, using industry-standard encryption algorithms;
Hashed password storage — jilli 1 does not store passwords in plain text under any circumstances;
Multi-factor authentication options for player accounts, including SMS OTP verification;
Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis;
Regular security audits and penetration testing conducted by qualified third-party security professionals;
Automated intrusion detection and monitoring systems operating continuously across jilli 1's infrastructure;
Data minimisation practices ensuring that only the personal data necessary for each specific purpose is collected and retained.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. If jilli 1 becomes aware of a personal data breach that is likely to affect your rights and freedoms, jilli 1 will notify the National Privacy Commission within the timeframe required under the Data Privacy Act, and will notify affected players as required.

jilli 1 will never ask for your password, OTP, or financial account credentials via email, SMS, or live chat. If you receive such a request purportedly from jilli 1, treat it as fraudulent and report it to [email protected] immediately.

11 Data Retention

jilli 1 retains personal data for the period necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law. The following general retention periods apply:

Account and identity data: Retained for the duration of your active jilli 1 account plus a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and the Anti-Money Laundering Act.
Financial transaction data: Retained for a minimum of five (5) years from the date of each transaction, consistent with AML record-keeping obligations and PAGCOR audit requirements.
Gaming activity data: Retained for a minimum of three (3) years from the date of each game session, for dispute resolution, responsible gaming monitoring, and regulatory audit purposes.
Customer support records: Retained for two (2) years from the date of resolution of the relevant support interaction, for quality assurance and dispute reference purposes.
Technical and log data: Retained for twelve (12) months from collection, except where required longer for security investigation purposes.
Marketing preferences: Retained for the duration of your account, or until you withdraw consent to marketing communications, whichever is earlier.

When personal data is no longer required, jilli 1 will securely delete or anonymise such data in accordance with its data disposal procedures, consistent with the Data Privacy Act's requirements for proper disposal of personal information.

12 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jilli 1. jilli 1 will respond to all valid rights requests within thirty (30) days of receipt, and in no event later than the period required by applicable NPC guidelines.

Right to Access

You have the right to request a copy of the personal data jilli 1 holds about you, and to receive information about how that data is being processed.

Right to Rectification

You have the right to request correction of any inaccurate or incomplete personal data jilli 1 holds about you. You may update most personal data directly via your account settings.

Right to Erasure

You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jilli 1's legal retention obligations.

Right to Block Processing

You have the right to request that jilli 1 suspend processing of your personal data in certain circumstances, such as while a rectification request is pending verification.

Right to Object

You have the right to object to the processing of your personal data for direct marketing, and to object to processing based on jilli 1's legitimate interests in certain circumstances.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format where processing is based on your consent or a contract.

Right to Complain

You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe jilli 1 has processed your personal data in violation of the Data Privacy Act.

Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, please contact the jilli 1 Data Protection Officer at [email protected] with the subject line "Data Privacy Request." jilli 1 may require you to verify your identity before processing a rights request.

13 Children's Privacy

The jilli 1 platform is strictly intended for adults aged 21 years and older, consistent with PAGCOR's minimum age requirement for online casino gaming in the Philippines. jilli 1 does not knowingly collect personal data from individuals under the age of 21.

If jilli 1 discovers that personal data has been collected from a player who is under the age of 21, jilli 1 will immediately close the relevant account, void all associated gaming activity, return any remaining real-money balance (net of any voided wins) to the depositing payment source, and permanently delete the associated personal data, except where retention is required by law or PAGCOR regulation.

If you believe that a person under the age of 21 has registered a jilli 1 account, please contact jilli 1 support immediately at [email protected].

14 Updates to This Policy

jilli 1 reserves the right to update this Privacy Policy from time to time to reflect changes in jilli 1's data processing practices, changes in applicable Philippine data privacy law, NPC guidance, or PAGCOR regulatory requirements. The "Last Updated" date at the top of this Policy will be revised upon any amendment.

Where changes to this Policy are material — that is, where they significantly affect your rights or jilli 1's data processing obligations — jilli 1 will notify registered players via SMS to their registered Philippine mobile number, via email where an email address is registered, or via a prominent notice on the jilli 1 platform, no less than seven (7) days before the changes take effect.

Your continued use of the jilli 1 platform following the effective date of any revised Policy constitutes your acknowledgement of the updated practices. If you do not agree to the updated Policy, you must cease using jilli 1 and may request account closure and data deletion in accordance with Section 12 of this Policy.

15 Contact & Data Protection Officer

For all privacy-related queries, rights requests, data breach reports, or complaints regarding jilli 1's data processing practices, please contact the jilli 1 Data Protection Officer through the following channels:

Email: [email protected] — use the subject line "Data Privacy Request" or "DPO Enquiry" for priority routing.
Live Chat: Available 24/7 through the jilli 1 platform — request to speak with a Privacy Officer for escalated data privacy matters.
Response Commitment: jilli 1 will acknowledge all data privacy enquiries within two (2) Philippine business days and will substantively respond within thirty (30) calendar days.

If you are not satisfied with jilli 1's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC accepts complaints from data subjects through its official channels as published on the NPC's website.

Your data privacy matters to us. The jilli 1 DPO is a dedicated function — not a support agent — and is specifically trained to handle data privacy matters in accordance with the Data Privacy Act of 2012 and NPC regulations.

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