Privacy Policy

1. Introduction

jili0 ("we," "us," "our") is committed to protecting the privacy and personal data of all players and visitors who use the jili0 platform. This Privacy Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

As a personal information controller, jili0 determines the purposes and means of processing personal data collected through the Platform. We process your data only for the purposes described in this Policy and only to the extent necessary to fulfil those purposes. We do not process personal data in ways that are incompatible with the purposes for which it was originally collected.

This Policy applies to all registered players, prospective players, and visitors to the jili0 Platform, regardless of whether they are located in Metro Manila, Cebu, Davao, Makati, Quezon City, or any other part of the Philippines.

2. Personal Data We Collect

jili0 collects personal data that you provide directly, data generated through your use of the Platform, and data received from third parties in connection with payment processing and identity verification. The categories of personal data we collect include:

2.1 Registration Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Email address
• Mobile number
• Residential address (including city and province)
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Government-issued ID (e.g., Philippine passport, SSS ID, UMID, driver's licence)
• Proof of address documents
• Selfie or facial image for identity verification purposes
• Source of funds documentation where required by applicable regulations

2.3 Financial Data

• GCash account reference (where used for deposits or withdrawals)
• PayMaya (Maya) account reference
• Bank account details (BPI, BDO, Metrobank) where provided
• Transaction history, deposit and withdrawal records

2.4 Usage and Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and features used
• Game history, wagering activity, and betting patterns
• Login timestamps and access logs

2.5 Communications Data

• Support chat transcripts and email correspondence
• Survey responses and feedback submissions
• Promotional opt-in preferences

3. How We Use Your Personal Data

jili0 uses the personal data we collect for the following purposes:

jili0 will not use your personal data for any purpose that is incompatible with those listed above without first obtaining your consent or establishing another lawful basis for the new processing activity.

4. Legal Basis for Processing

jili0 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to register your account, verify your identity, process transactions, and provide access to the jili0 Platform in accordance with our Terms & Conditions.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering obligations, PAGCOR reporting requirements, and tax regulations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving the jili0 Platform, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing and Disclosure

jili0 does not sell your personal data. 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, and Metrobank, for the purpose of processing deposits and withdrawals. These providers act as independent data controllers for their own services.
• KYC and identity verification providers: Third-party service providers engaged to assist with document verification and fraud screening, acting as data processors under jili0's instruction.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• IT and platform service providers: Cloud hosting, data analytics, and cybersecurity providers engaged to support the operation of the jili0 Platform, acting as data processors under binding data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of jili0's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third-party data processors engaged by jili0 are required to process personal data only in accordance with jili0's documented instructions and to implement appropriate technical and organisational security measures.

6. Data Retention

jili0 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AMLC and PAGCOR requirements.
• Communications data: Support correspondence is retained for up to three (3) years from the date of the last interaction.
• Usage and technical data: Aggregated analytics data may be retained indefinitely in anonymised form. Raw usage logs are retained for up to twelve (12) months.
• Marketing preferences: Retained until you withdraw consent or close your account, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jili0's data disposal procedures.

7. Data Security

jili0 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the jili0 Platform.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• Role-based access controls limiting access to personal data to authorised personnel only.
• Regular security assessments, vulnerability scanning, and penetration testing of the jili0 Platform.
• Multi-factor authentication options for player accounts.
• Staff training on data protection obligations and secure data handling practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jili0 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.

8. Cookies and Similar Technologies

jili0 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device when you visit the jili0 website or use the jili0 app. We use the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function, including session management, authentication, and security. These cannot be disabled without affecting your ability to use jili0.
• Functional cookies: Remember your preferences such as language settings and display options to provide a more personalised experience.
• Analytics cookies: Collect aggregated, anonymised data about how players use the Platform, helping jili0 identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Session cookies: Temporary cookies that expire when you close your browser, used to maintain your login session during a single visit.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the jili0 Platform. jili0 does not use third-party advertising cookies or cross-site tracking technologies.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jili0:

• Right to be informed: The right to be notified of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data jili0 holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You can update most account information directly through your jili0 account settings.
• 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 jili0'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, and machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jili0 has violated your data privacy rights.

To exercise any of these rights, please contact the jili0 Data Protection Officer using the contact details in Section 14 of this Policy. jili0 will acknowledge your request within three (3) business days and respond substantively within thirty (30) days. In complex cases, this period may be extended by a further thirty (30) days with prior notice.

10. Children's Privacy

The jili0 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. jili0 does not knowingly collect personal data from individuals under the age of 21. If jili0 becomes aware that personal data has been collected from a person under 21, the relevant account will be immediately suspended, all balances forfeited, and the personal data deleted in accordance with applicable law.

If you believe that a minor has registered on the jili0 Platform, please contact our support team immediately so that appropriate action can be taken without delay.

11. International Data Transfers

jili0 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines, jili0 ensures that such transfers are carried out in compliance with the Data Privacy Act and NPC regulations, including the implementation of appropriate safeguards such as contractual data protection clauses.

jili0 will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

12. Third-Party Links

The jili0 Platform may contain references to third-party services such as payment providers. jili0 is not responsible for the privacy practices of third-party services and encourages you to review the privacy policies of any third-party service you use in connection with your jili0 account. This Privacy Policy applies solely to data processed by jili0 through the jili0 Platform.

13. Updates to this Privacy Policy

jili0 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The "Last Updated" date at the top of this page will be revised accordingly. Where changes are material, jili0 will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect.

Your continued use of the jili0 Platform after the effective date of any update constitutes your acknowledgement of the revised Privacy Policy. If you do not agree with any changes, you should discontinue use of the Platform and may request account closure in accordance with the jili0 Terms & Conditions.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jili0, please contact our Data Protection Officer (DPO):