Privacy Policy — Jilli1

1.Introduction

1.1 This Privacy Policy ("Policy") describes how Jilli1 ("Jilli1," "we," "us," "our") collects, uses, stores, shares, and protects the personal information of players and visitors ("you," "your") who access or use the Jilli1 website, mobile application, and related services (collectively, the "Platform").

1.2 Jilli1 is committed to protecting the privacy and security of your personal data. We process personal information only for legitimate, specified purposes and in a manner consistent with the Philippine Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and the directives of the National Privacy Commission (NPC).

1.3 This Policy applies to all personal data collected through the Jilli1 Platform, including data collected during account registration, identity verification, payment processing, gameplay, customer support interactions, and marketing communications.

1.4 This Policy should be read alongside Jilli1's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2.Data Controller

2.1 Jilli1 acts as the data controller for all personal information collected through the Platform. As data controller, Jilli1 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws.

2.2 Jilli1 operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing activities are subject to PAGCOR's regulatory requirements in addition to the requirements of the National Privacy Commission.

3.Data We Collect

3.1 Jilli1 collects the following categories of personal data from players and platform visitors:

3.2 Jilli1 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required for responsible gaming assessments or as mandated by applicable law or PAGCOR regulations.

4.How We Collect Your Data

4.1 Jilli1 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, server logs, and similar tracking technologies. See Section 10 for full details on our cookie practices.
• Third-party sources: Data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, fraud prevention services, and analytics partners, where permitted by law.
• Publicly available sources: Information from public registries or databases where relevant to fraud prevention or regulatory compliance.

4.2 Where Jilli1 receives personal data about you from a third party, we will inform you of this at the earliest practicable opportunity, unless doing so would compromise an ongoing fraud investigation or is otherwise restricted by law.

5.How We Use Your Data

5.1 Jilli1 uses your personal data for the following purposes:

• To create, verify, and manage your Jilli1 player account;
• To process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers;
• To verify your identity and age (21+) in compliance with PAGCOR requirements;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity;
• To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations;
• To provide customer support and resolve disputes;
• To monitor gameplay for responsible gaming purposes and enforce self-exclusion or limit settings;
• To send transactional communications such as deposit confirmations, withdrawal notifications, and security alerts;
• To send promotional communications and personalized offers, where you have provided consent;
• To improve the Platform through analytics, A/B testing, and user experience research;
• To comply with legal obligations imposed by Philippine law, PAGCOR, the NPC, or other competent authorities.

5.2 Jilli1 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for processing.

6.Legal Basis for Processing

6.1 Jilli1 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and gameplay services;
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AML/CTF regulations, NPC directives, and other applicable Philippine laws;
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7.Sharing Your Data

7.1 Jilli1 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to the extent necessary to process your transactions;
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and eligibility;
• Fraud prevention and AML services: Specialist providers that help Jilli1 detect and prevent fraudulent activity and comply with anti-money laundering obligations;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government agencies, where required by law or regulatory directive;
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate a crime;
• IT and platform service providers: Cloud hosting, analytics, and customer support technology providers engaged by Jilli1 under strict data processing agreements;
• Business transfers: In the event of a merger, acquisition, or sale of all or part of Jilli1's business, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7.2 All third parties with whom Jilli1 shares personal data are required to process that data in accordance with applicable data protection laws and are prohibited from using it for any purpose beyond what is strictly necessary.

8.Data Retention

8.1 Jilli1 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and PAGCOR regulations.

8.2 The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AML record-keeping requirements;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier;
• Technical and usage data: Retained for up to twelve (12) months, unless required for longer periods for security or fraud investigation purposes.

8.3 Upon expiry of the applicable retention period, Jilli1 will securely delete or anonymize your personal data in a manner that prevents reconstruction or identification.

9.Data Security

9.1 Jilli1 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Jilli1 Platform;
• Encryption of sensitive data at rest, including financial and identity information;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Jilli1 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 where required by law.

9.3 While Jilli1 takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying Jilli1 immediately if you suspect unauthorized access to your account.

10.Cookies & Tracking Technologies

10.1 Jilli1 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

10.2 Jilli1 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled. They include session management, authentication, and security cookies;
• Functional cookies: Remember your preferences such as language settings and login details to improve your experience;
• Analytics cookies: Collect anonymized data about how players use the Platform to help us improve performance and content;
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of our campaigns. These are only set with your consent.

10.3 You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Jilli1 Platform. Withdrawing consent for marketing cookies will not affect your ability to use core Platform features.

11.Your Rights

11.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by Jilli1:

• Right to be informed: The right to know whether Jilli1 holds personal data about you and to receive clear information about how it is processed;
• Right of access: The right to request a copy of the personal data Jilli1 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: 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 legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

11.2 To exercise any of the rights listed above, please contact Jilli1's Data Protection Officer using the contact details provided in Section 14. Jilli1 will respond to all verified requests within fifteen (15) business days. In complex cases, this period may be extended by a further fifteen (15) business days, with prior notice to you.

11.3 Jilli1 may need to verify your identity before processing a data rights request to ensure that personal data is not disclosed to unauthorized parties.

12.Minors & Age Policy

12.1 If Jilli1 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any deposits made by an underage player will be returned to the original payment method after deducting any bonuses received.

12.2 If you believe that a minor has registered on the Jilli1 Platform, please contact our support team immediately so that we can investigate and take appropriate action.

13.Changes to This Policy

13.1 Jilli1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. The updated Policy will be posted on this page with a revised effective date.

13.2 Where changes are material, Jilli1 will notify registered players via email or in-platform notification at least seven (7) days before the changes take effect. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

13.3 We encourage you to review this Policy periodically to stay informed about how Jilli1 protects your personal data.

14.Contact & Complaints

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the way Jilli1 processes your personal data, please contact our Data Protection Officer. We are committed to resolving all privacy-related inquiries promptly and transparently.

14.2 You may reach Jilli1's Data Protection Officer at the following address (plain text — not a clickable link):

14.3 If you are not satisfied with Jilli1's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for enforcing the Data Privacy Act of 2012 in the Philippines.

14.4 For responsible gaming concerns, account limit requests, or self-exclusion, please visit our Responsible Gaming page or contact our support team directly.