jili109 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by jili109 ("jili109," "we," "us," or "our") and applies to all personal data collected through the jili109 online gaming platform accessible at jili109.org, including any mobile-optimized interfaces, customer support channels, and promotional communications associated with the jili109 brand.

jili109 is committed to protecting the privacy and personal data of every Filipino player who registers, browses, or interacts with our platform. This Policy is designed to comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

By creating a jili109 account or continuing to use the platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the jili109 platform and contact our support team to request account closure.

2. Data Controller Information

For the purposes of the Data Privacy Act of 2012 and applicable data protection regulations, jili109 acts as the personal information controller in respect of the personal data it collects from players and visitors to the jili109 platform.

All data protection inquiries, access requests, correction requests, and complaints may be directed to our Data Protection Officer (DPO) via the contact details provided in Section 15 of this Policy. jili109 maintains a designated DPO responsible for overseeing compliance with data protection obligations and serving as the primary point of contact for data subjects and the National Privacy Commission.

3. Personal Data We Collect

jili109 collects the following categories of personal data from players and platform visitors:

We do not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, health information, or political affiliations.

4. How We Collect Your Data

jili109 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated collection: Technical and behavioral data collected automatically when you access the jili109 platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from government-authorized verification services; fraud and AML screening data from compliance service providers; payment data from GCash, PayMaya, and banking partners.
• Referral programs: Basic contact information shared by existing jili109 players who refer new registrants, subject to the referring player's confirmation that the referred individual has consented to such sharing.

5. Legal Basis for Processing

jili109 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations under the jili109 Terms & Conditions, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, and NPC requirements, including KYC verification and transaction monitoring.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have provided explicit, freely given, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

jili109 uses the personal data we collect for the following purposes:

• Creating, verifying, and managing your jili109 player account.
• Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
• Verifying your identity and age (21+) in compliance with PAGCOR and AMLA requirements.
• Delivering games, calculating results, and maintaining accurate gaming records.
• Detecting, investigating, and preventing fraud, money laundering, and other prohibited activities.
• Monitoring gaming behavior to identify signs of problem gambling and applying responsible gaming interventions where appropriate.
• Providing customer support via live chat and email.
• Sending transactional communications (account confirmations, deposit receipts, withdrawal notifications).
• Sending promotional communications about bonuses, new games, and special offers — only where you have provided consent or where permitted under applicable law.
• Improving the jili109 platform through analytics and user experience research.
• Complying with legal and regulatory obligations, including responding to lawful requests from PAGCOR, the NPC, or other competent Philippine authorities.

jili109 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have provided explicit consent.

7. Sharing and Disclosure of Data

jili109 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your financial transactions.
• Identity verification providers: Third-party KYC and AML screening services engaged to verify your identity and comply with regulatory obligations.
• Game providers: Licensed game software providers whose games are hosted on the jili109 platform, to the extent necessary for game delivery and dispute resolution.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and analytics service providers engaged to operate and maintain the jili109 platform.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, 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.

All third-party service providers engaged by jili109 are required to process personal data only on jili109's documented instructions and to implement appropriate technical and organizational security measures.

8. Cookies and Tracking Technologies

jili109 uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze usage patterns. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for the platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your language preferences, display settings, and login state to improve your experience.
• Analytics cookies: Collect aggregated, anonymized data about how players use the jili109 platform to help us improve performance and usability.
• Marketing cookies: Used to deliver relevant promotional content about jili109 games and offers. These are only activated with your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jili109 platform. For more information on managing cookies in popular Philippine mobile browsers, refer to your device's browser help documentation.

9. Data Retention

jili109 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by AMLA and PAGCOR regulations.
• Gaming history: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes.
• Customer support records: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained for the duration of your account and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with jili109's data disposal procedures.

10. Data Security

jili109 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the jili109 platform.
• Encryption of sensitive data at rest, including financial account details and government ID information.
• Role-based access controls limiting staff 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 all administrative access to systems holding personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While jili109 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying jili109 immediately if you suspect unauthorized access to your account.

11. Your Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jili109:

• Right to be informed: The right to know what personal data jili109 collects, how it is used, and with whom it is shared — as set out in this Policy.
• Right of access: The right to request a copy of the personal data jili109 holds about you.
• Right to correction: 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 processing based on legitimate interests, including direct marketing.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. jili109 will respond to all verified requests within fifteen (15) business days. We may require identity verification before processing your request.

12. Children's Privacy

The jili109 platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine law and PAGCOR regulations. jili109 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the associated account and delete the data in question.

If you are a parent or guardian and believe that a minor has registered on the jili109 platform, please contact our support team immediately so that we can take appropriate action.

13. Cross-Border Data Transfers

Some of jili109's technology and service providers may be located outside the Philippines. Where personal data is transferred to recipients in other countries, jili109 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. Such safeguards may include contractual data protection clauses, adequacy assessments, or other mechanisms recognized by the National Privacy Commission.

By using the jili109 platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

14. Changes to This Policy

jili109 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via the contact information on file or through a prominent notice on the jili109 platform. The updated Policy will be posted on this page with a revised "Last Updated" date.

Your continued use of the jili109 platform following the posting of an updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how jili109 protects your personal data.

15. Contact and Complaints

For all data protection inquiries, access requests, correction requests, objections, or complaints, please contact the jili109 Data Protection Officer:

• Live Chat: Available 24/7 via the jili109 platform — average response time under 5 minutes.
• Email: [email protected] (plain text — not a clickable link)
• Coverage: Serving players across the Philippines — Manila, Cebu, Davao, Quezon City, Makati, and beyond.

If you are not satisfied with jili109's response to your data protection concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.