jili23 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how jili23 ("jili23," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you" or "your") who access or use the jili23 website, mobile platform, games, and all related services (collectively, the "Platform").

jili23 is committed to protecting your privacy and handling your personal data responsibly. This Policy is designed to help you understand what information we collect about you, why we collect it, how we use it, and what rights you have in relation to your personal data.

By registering an account on jili23 or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the jili23 Platform.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, jili23 is the personal information controller responsible for the personal data collected through the Platform.

jili23 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data privacy laws and this Policy. You may contact the jili23 DPO at any time with questions or concerns regarding the processing of your personal data. Contact details are provided in Section 15 of this Policy.

3 Personal Data We Collect

jili23 collects the following categories of personal data from users of the Platform:

3.1 Identity and Contact Information

• Full legal name
• Date of birth
• Gender
• Nationality
• Email address
• Philippine mobile number
• Residential address (including city, province, and postal code)

3.2 Identity Verification Documents

• Government-issued photo identification (e.g., PhilSys National ID, passport, driver's license, SSS/GSIS ID, PRC ID, Voter's ID)
• Proof of address documents
• Proof of payment method ownership
• Selfie or facial image for identity verification purposes

3.3 Financial Information

• GCash or Maya account details (mobile number associated with the account)
• Bank account details (account name, account number, bank name) for withdrawal processing
• Debit card details (card number, expiry date — stored in token ized form only)
• Transaction history (deposits, withdrawals, wagers, winnings)

3.4 Gaming and Account Activity

• Account username and encrypted password
• Game play history, bet records, and session logs
• Bonus and promotion usage history
• Responsible gaming settings and self-exclusion records
• Customer support communications and complaint records

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Unique device identifiers
• Platform access logs and session timestamps
• Cookie and tracking technology data (see Section 8)

4 How We Collect Your Data

jili23 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and device data collected automatically when you access or use the Platform, including through cookies, web beacons, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from anti-fraud partners; payment verification data from payment processors such as GCash, Maya, and Philippine banks.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with compliance obligations, including self-exclusion registry data.

5 How We Use Your Personal Data

jili23 uses your personal data for the following purposes:

6 Legal Basis for Processing

jili23 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including KYC/AML obligations under the Anti-Money Laundering Act, PAGCOR regulatory requirements, and the Data Privacy Act itself.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Personal Data

jili23 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist jili23 in verifying user identity and age in compliance with regulatory requirements.
• Game providers: Software providers whose games are available on the jili23 Platform, to the extent necessary for game operation and fairness auditing.
• Fraud prevention and security partners: Services that help jili23 detect and prevent fraudulent activity, money laundering, and unauthorized access.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory obligation.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of jili23 assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom jili23 shares personal data are required to process that data in accordance with applicable Philippine data privacy laws and jili23's data processing standards.

8 Cookies & Tracking Technologies

jili23 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the jili23 website.

8.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits to provide a personalized experience.
• Analytics cookies: Help jili23 understand how users interact with the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized account access attempts.

8.2 Managing Cookies

You can control non-essential cookies through your browser settings or the jili23 cookie preference center. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate securely.

9 Data Security

jili23 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the jili23 Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

10 Data Retention

jili23 retains your personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law and regulatory obligations. 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 AMLC record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Gaming activity logs: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes.
• Customer support records: Retained for three (3) years from the date of resolution of the relevant query or complaint.
• Marketing consent records: Retained until consent is withdrawn and for one (1) year thereafter as evidence of consent.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with jili23's data disposal procedures.

11 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jili23:

• Right to be informed: The right to be notified of how your personal data is collected and processed — which this Policy fulfills.
• Right of access: The right to request a copy of the personal data jili23 holds about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held by jili23.
• 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 jili23's 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 format and to transmit it to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jili23 has violated your data privacy rights.

To exercise any of these rights, please contact the jili23 Data Protection Officer using the contact details in Section 15. jili23 will respond to all valid requests within thirty (30) days. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified of the extension.

12 Children's Privacy

The jili23 Platform is strictly intended for users who are 21 years of age or older, in accordance with Philippine gambling regulations. jili23 does not knowingly collect personal data from individuals under the age of 21.

If jili23 becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted promptly and the associated account will be closed. If you believe that a minor has registered on the jili23 Platform, please contact us immediately using the details in Section 15.

13 Cross-Border Data Transfers

Some of jili23's service providers and game technology partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, jili23 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law.

Such safeguards may include contractual data processing agreements incorporating standard data protection clauses, or transfers to countries recognized by the National Privacy Commission as providing adequate levels of data protection.

By using the jili23 Platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

14 Updates to This Privacy Policy

jili23 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Policy, jili23 will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect. Your continued use of the jili23 Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

We encourage you to review this Privacy Policy periodically to stay informed about how jili23 protects your personal information.

15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by jili23, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.

jili23 is committed to resolving all privacy-related queries promptly and transparently. We aim to acknowledge all DPO inquiries within five (5) business days and to provide a substantive response within thirty (30) days.