Privacy Policy

1. Information We Collect

1.1 Information You Provide Directly

When you register an account on jili93, we collect the following personal information that you voluntarily provide:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification documents (passport, driver's license, or Philippine National ID) for age and identity verification purposes.
• Contact Information: Email address, mobile phone number, residential address (street, city, province, postal code), and preferred communication methods.
• Account Credentials: Username, password (stored in encrypted hash format, never in plain text), and security questions/answers for account recovery.
• Financial Information: Payment method details including GCash mobile number, PayMaya account information, bank account numbers, and transaction history for deposits and withdrawals. Note: We do not store complete credit card numbers or CVV codes.
• Verification Documents: Copies of government-issued identification, proof of address documents (utility bills, bank statements), and proof of payment method ownership as required for KYC (Know Your Customer) and AML (Anti-Money Laundering) compliance.
• Communication Records: Content of your communications with our customer support team via live chat, email, or phone, including transcripts, screenshots, and attachments.

1.2 Information Collected Automatically

When you access and use the jili93 Platform, we automatically collect certain technical and usage information:

• Device Information: Device type (smartphone, tablet, desktop), operating system (iOS, Android, Windows, macOS), browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information (carrier name, connection type).
• Usage Data: Pages visited, features accessed, games played, time spent on Platform, navigation paths, clicks, scrolls, search queries entered, and interaction patterns with Platform elements.
• Gaming Activity: Bets placed, game outcomes, win/loss records, bonus usage, tournament participation, and gaming session durations.
• Location Information: IP address, geographic location (country, city, region) derived from IP address, and GPS coordinates if you grant permission on mobile devices. This helps us comply with geographic restrictions and detect fraudulent activities.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to remember your preferences, authenticate your sessions, analyze Platform performance, and deliver personalized content. See Section 8 for detailed cookie information.
• Transaction Logs: Comprehensive records of all deposits, withdrawals, bonus claims, and wagers including timestamps, amounts, payment methods, transaction IDs, and processing status.

1.3 Information from Third Parties

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

• Payment Processors: GCash, PayMaya, and banking institutions provide transaction confirmation, payment method verification, and fraud detection information.
• Identity Verification Services: Third-party verification providers confirm your identity, age, and address information against government databases and public records.
• Fraud Prevention Services: Specialized security companies provide risk scores, device fingerprints, and suspicious activity alerts to protect against fraud and abuse.
• Game Providers: JILI Gaming, Pragmatic Play, Evolution Gaming, and other content partners share aggregated gameplay data to ensure fair gaming and detect irregular patterns.

2. How We Use Your Information

jili93 uses your personal information for the following purposes, all of which are necessary for providing our gaming services and complying with legal obligations:

2.1 Account Management and Service Provision

• Create, maintain, and manage your jili93 gaming account
• Authenticate your identity during login and verify your age (21+ requirement)
• Process deposits, withdrawals, and internal fund transfers
• Provide access to games, live casino, sports betting, and other Platform features
• Track your gaming activity, transaction history, and account balance
• Administer bonuses, promotions, tournaments, and loyalty rewards
• Respond to your customer support inquiries and resolve disputes
• Send transactional notifications about deposits, withdrawals, wins, and account changes

2.2 Legal and Regulatory Compliance

• Comply with Philippine Data Privacy Act (Republic Act No. 10173) requirements
• Meet PAGCOR licensing conditions and regulatory reporting obligations
• Conduct KYC (Know Your Customer) and AML (Anti-Money Laundering) due diligence
• Prevent underage gambling by verifying age and identity of all users
• Detect and prevent fraud, money laundering, identity theft, and other illegal activities
• Cooperate with law enforcement investigations and court orders when legally required
• Maintain records as required by gaming regulations and tax laws
• Report suspicious transactions to Philippine Anti-Money Laundering Council (AMLC) when necessary

2.3 Security and Fraud Prevention

• Monitor for unauthorized access attempts, account takeovers, and credential stuffing attacks
• Detect irregular gaming patterns, bonus abuse, and collusion between players
• Identify multiple accounts created by the same individual
• Prevent payment fraud, chargebacks, and stolen payment method usage
• Implement risk-based authentication and transaction monitoring
• Block access from prohibited jurisdictions or high-risk locations
• Protect Platform infrastructure from DDoS attacks, hacking attempts, and data breaches

2.4 Platform Improvement and Analytics

• Analyze user behavior to improve Platform design, functionality, and user experience
• Conduct A/B testing to optimize features and game offerings
• Monitor Platform performance, loading times, and error rates
• Understand game preferences and popularity to guide content acquisition decisions
• Generate aggregated, anonymized statistics and reports (never identifying individual users)
• Research gaming trends and player preferences in the Philippine market

2.5 Marketing and Communications (With Your Consent)

• Send promotional emails about new games, bonuses, and special offers
• Deliver SMS notifications about exclusive promotions (only if you opt in)
• Display personalized game recommendations based on your play history
• Invite you to participate in tournaments, competitions, and VIP events
• Conduct satisfaction surveys and request feedback about our services

Important: You can opt out of marketing communications at any time by clicking "unsubscribe" links in emails, adjusting your account preferences, or contacting customer support. Opting out does not affect essential transactional communications.

3. How We Share Your Information

jili93 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information in the following limited circumstances:

3.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: GCash, PayMaya, banks, and other payment service providers to process deposits and withdrawals. They receive only the information necessary to complete transactions.
• Game Providers: JILI Gaming, Pragmatic Play, Evolution Gaming, PG Soft, and other content partners receive your username and gameplay data to deliver games and verify outcomes.
• Identity Verification Providers: Specialized companies verify your identity, age, and address against official databases and public records.
• Cloud Hosting Services: Infrastructure providers host our servers, databases, and backup systems with strict data security agreements.
• Customer Support Tools: Live chat, helpdesk, and CRM platforms used by our support team to assist you efficiently.
• Marketing Service Providers: Email delivery services and SMS gateways (only for communications you've consented to receive).
• Analytics Providers: Tools that help us understand Platform usage through aggregated, anonymized data.

All service providers are bound by strict confidentiality agreements and are prohibited from using your personal information for any purpose other than providing services to jili93. We conduct due diligence to ensure they maintain appropriate security standards.

3.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, regulators, and law enforcement when:

• Required by Philippine law, court order, subpoena, or other legal process
• Requested by PAGCOR or other gaming regulators for licensing compliance
• Necessary to report suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Required to cooperate with criminal investigations or legal proceedings
• Needed to protect the rights, property, and safety of jili93, our users, or the public
• Essential to enforce our Terms and Conditions or investigate Terms violations

3.3 Business Transfers

If jili93 is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your personal information may be transferred to the successor entity. We will notify you via email and Platform notice before your information becomes subject to a different privacy policy.

3.4 With Your Consent

We may share your information with third parties not described above if we obtain your explicit consent to do so. You can withdraw consent at any time by contacting our Data Protection Officer.

4. Data Security Measures

jili93 employs industry-leading security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

4.1 Technical Security

• Encryption: All data transmission uses 256-bit SSL/TLS encryption. Sensitive data at rest is encrypted using AES-256 encryption standards.
• Secure Authentication: Passwords are hashed using bcrypt with salt, never stored in plain text. Multi-factor authentication available for enhanced protection.
• Network Security: Firewalls, intrusion detection/prevention systems, and DDoS protection secure our infrastructure.
• Access Controls: Strict role-based access ensures only authorized personnel can access personal data, and only when necessary for their job functions.
• Vulnerability Management: Regular security audits, penetration testing, and vulnerability scanning identify and fix potential weaknesses.
• Secure Development: Security-by-design principles integrated into software development lifecycle with code reviews and security testing.

4.2 Organizational Security

• Employee Training: I'm Claude Code, Anthropic's official CLI for Claude; the underlying model is Claude by Anthropic. I don't have a reliable way to see the exact model version, so I won't guess. What can I help you with? All staff undergo data protection and security awareness training.
• Background Checks: Employees with access to sensitive data undergo background verification and sign confidentiality agreements.
• Incident Response: Dedicated security team monitors for breaches 24/7 with documented incident response procedures.
• Data Minimization: We collect only information necessary for stated purposes and delete data when no longer needed.
• Backup and Recovery: Encrypted backups stored in geographically separate locations with tested disaster recovery plans.

While we implement comprehensive security measures, no system is 100% secure. We cannot guarantee absolute security of information transmitted over the internet. You also play a role in security by choosing strong passwords, not sharing login credentials, and logging out after sessions.

5. Your Privacy Rights

Under the Philippine Data Privacy Act and our commitment to transparency, you have the following rights regarding your personal information:

5.1 Right to Access

You have the right to request copies of the personal information we hold about you. We will provide this information in a commonly used electronic format within thirty (30) days of your verified request.

5.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings, or contact customer support for assistance.

5.3 Right to Erasure

You have the right to request deletion of your personal information, subject to certain limitations. We must retain some information to comply with legal obligations, resolve disputes, enforce agreements, and prevent fraud. Information required for regulatory compliance will be retained for the legally mandated period.

5.4 Right to Object

You have the right to object to processing of your personal information for marketing purposes. You can opt out of marketing communications at any time through account settings or unsubscribe links.

5.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format and transmit it to another service provider where technically feasible.

5.6 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.

5.7 How to Exercise Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. Include your full name, account username, and specific request. We may require identity verification before processing requests to protect your privacy.

6. Data Retention

jili93 retains personal information only as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations:

• Active Accounts: Information retained for the duration of account activity plus any legally required retention period.
• Closed Accounts: Most personal information deleted within ninety (90) days of account closure, except information required for legal, regulatory, fraud prevention, or dispute resolution purposes.
• Transaction Records: Financial transaction records retained for seven (7) years as required by Philippine tax and anti-money laundering laws.
• Identity Verification Documents: Retained for five (5) years after account closure to comply with PAGCOR regulations and AML requirements.
• Customer Support Records: Communication records retained for three (3) years for quality assurance and dispute resolution.
• Marketing Preferences: Opt-out records retained indefinitely to honor your preferences and prevent unwanted communications.

After applicable retention periods expire, personal information is securely deleted or anonymized so it can no longer identify you.

7. International Data Transfers

Your personal information is primarily processed and stored on secure servers located in the Philippines. However, some of our service providers may operate in other countries. When we transfer personal information internationally, we ensure adequate protection through:

• Contractual data protection clauses requiring equivalent protection standards
• Ensuring recipient countries have adequate data protection laws recognized by Philippine authorities
• Conducting due diligence on security practices of international service providers

8. Cookies and Tracking Technologies

jili93 uses cookies, web beacons, pixels, and similar technologies to enhance your experience and analyze Platform usage:

8.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for Platform functionality, login authentication, session management, and security. Cannot be disabled.	Session or up to 30 days
Functional Cookies	Remember your preferences, language settings, game favorites, and account customizations.	Up to 1 year
Analytics Cookies	Help us understand how users interact with the Platform, which pages are most popular, and identify technical issues.	Up to 2 years
Marketing Cookies	Track your browsing to deliver relevant promotional content and measure campaign effectiveness. Used only with consent.	Up to 1 year

8.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive alerts before cookies are stored. Note that disabling essential cookies may prevent you from accessing certain Platform features. Disabling analytics or marketing cookies does not affect functionality.

9. Children's Privacy

jili93 services are strictly intended for individuals twenty-one (21) years of age or older. We do not knowingly collect personal information from anyone under 21. If we discover that we have inadvertently collected information from someone under the legal gambling age, we will immediately delete that information and permanently close the account. Parents or guardians who believe we may have collected information from a minor should contact us immediately at [email protected].

10. Changes to This Privacy Policy

jili93 may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or Platform features. When we make material changes, we will:

• Update the "Last Updated" date at the top of this document
• Send email notification to your registered email address
• Display a prominent notice on the Platform homepage for at least thirty (30) days

Your continued use of jili93 services after changes become effective constitutes acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

11. Contact Information and Complaints

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

If you are not satisfied with our response, you have the right to file a complaint with the National Privacy Commission of the Philippines:

National Privacy Commission
5th Floor, Philippine International Convention Center (PICC)
Vicente Sotto Street, Pasay City, Metro Manila, Philippines
Website: privacy.gov.ph