jili100 Privacy Policy

SECTION 01 1. Introduction

This Privacy Policy ("Policy") applies to all personal information collected by jili100 through the website at jili100.app and any associated mobile interfaces (collectively, the "Platform"). By accessing or using the jili100 Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and disclosure of your personal information as described herein.

jili100 operates as a data controller with respect to the personal information we collect from you. We are responsible for ensuring that your personal data is processed lawfully, fairly, and transparently, and that appropriate technical and organisational measures are in place to protect your information from unauthorised access, loss, or misuse.

This Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, which together form the complete legal framework governing your use of the jili100 Platform.

SECTION 02 2. Information We Collect

jili100 collects various categories of personal information to provide, maintain, and improve our services. The types of information we collect include:

2.1 Information You Provide Directly

• Account Registration Data: When you create an account on jili100, we collect your full name, date of birth, email address, mobile phone number, residential address, and a password of your choosing.
• Identity Verification Data: To comply with Know Your Customer (KYC) and anti-money laundering (AML) regulations, we collect copies of government-issued identification documents (such as a Philippine passport, driver's licence, or national ID), proof of address (such as utility bills or bank statements), and in some cases, selfie photographs for identity verification purposes.
• Payment Information: We collect details of your payment methods, including bank account numbers, GCash or PayMaya account details, and transaction history. Payment card information, where applicable, is processed by our third-party payment processors and is not stored directly on jili100 servers.
• Communications: When you contact jili100 customer support via email, live chat, or other communication channels, we collect the content of your messages, your contact details, and any attachments you provide.

2.2 Information Collected Automatically

• Device and Usage Data: We automatically collect information about the device you use to access the Platform, including your IP address, device type, operating system, browser type and version, screen resolution, and language settings.
• Gameplay Data: We collect detailed records of your gaming activity, including games played, bets placed, winnings and losses, session duration, and timestamps of all transactions.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your interactions with the Platform. For more details, please see Section 9 (Cookies and Tracking).
• Location Data: We may collect approximate location data based on your IP address to ensure compliance with jurisdictional restrictions and to provide localised content and services.

2.3 Information from Third Parties

In certain circumstances, we may receive information about you from third-party sources, including payment processors, identity verification services, fraud prevention agencies, and marketing partners. This information is used to verify your identity, prevent fraud, and improve the quality of our services.

SECTION 03 3. How We Use Your Information

jili100 uses the personal information we collect for the following purposes:

• Account Management: To create and maintain your jili100 account, authenticate your identity, and provide you with access to the Platform's features and services.
• Transaction Processing: To process deposits, withdrawals, and other financial transactions, and to maintain accurate records of your account balance and transaction history.
• Regulatory Compliance: To comply with legal and regulatory obligations, including KYC and AML requirements, age verification, responsible gaming obligations, and reporting requirements under Philippine gaming law.
• Fraud Prevention and Security: To detect, prevent, and investigate fraudulent activity, unauthorised access, and other security threats to the Platform and our users.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Service Improvement: To analyse usage patterns, identify technical issues, and improve the functionality, performance, and user experience of the Platform.
• Marketing and Promotions: To send you promotional offers, bonuses, newsletters, and other marketing communications, where you have consented to receive such communications. You may opt out of marketing communications at any time.
• Responsible Gaming: To monitor your gaming behaviour, identify signs of problem gambling, and implement responsible gaming measures such as deposit limits, self-exclusion, and reality checks.

SECTION 04 4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and other applicable data protection laws, jili100 must have a lawful basis for processing your personal information. We rely on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., the Terms & Conditions) and to provide the services you have requested.
• Legal Obligation: Processing is necessary to comply with legal and regulatory obligations, including KYC, AML, age verification, and responsible gaming requirements.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, service improvement, and direct marketing, provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where required by law, we obtain your explicit consent before processing certain categories of personal information, such as marketing communications and the use of certain cookies.

SECTION 05 5. Data Sharing and Disclosure

jili100 does not sell, rent, or trade your personal information to third parties. However, we may share your information with the following categories of recipients in the circumstances described below:

5.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including payment processing, identity verification, fraud detection, customer support, data analytics, and marketing services. These service providers have access to your personal information only to the extent necessary to perform their functions and are contractually obligated to protect your data and use it only for the purposes for which it was disclosed.

5.2 Regulatory and Law Enforcement Authorities

We may disclose your personal information to regulatory authorities, law enforcement agencies, courts, and other governmental bodies where required by law, or where we believe in good faith that such disclosure is necessary to comply with legal obligations, protect our rights, prevent fraud, or ensure the safety of our users and the public.

5.3 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of jili100's assets, your personal information may be transferred to the acquiring entity. We will notify you of any such transfer and any choices you may have regarding your personal information.

5 .4 Affiliated Companies

We may share your personal information with our affiliated companies and subsidiaries for the purposes described in this Policy, subject to the same data protection standards that apply to jili100.

SECTION 06 6. Data Security

jili100 takes the security of your personal information seriously. We implement a range of technical and organisational measures designed to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the jili100 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. Sensitive data stored on our servers, including financial information and identity documents, is encrypted at rest.
• Access Controls: Access to personal information is restricted to authorised personnel who require it to perform their job functions. All staff with access to personal data are subject to strict confidentiality obligations.
• Firewalls and Intrusion Detection: Our systems are protected by enterprise-grade firewalls and intrusion detection systems that monitor for and respond to suspicious activity in real time.
• Regular Security Audits: We conduct regular security assessments, penetration testing, and vulnerability scans to identify and address potential weaknesses in our systems.
• Two-Factor Authentication: We offer two-factor authentication (2FA) for account login to provide an additional layer of security for your jili100 account.

While we take all reasonable steps to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your data, and you use the Platform at your own risk. If you suspect that your account has been compromised, please contact jili100 customer support immediately.

SECTION 07 7. Data Retention

jili100 retains your personal information for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The specific retention periods we apply are as follows:

• Account Data: We retain your account registration data and KYC documentation for a minimum of five (5) years following the closure of your account, in accordance with Philippine AML regulations and gaming licensing requirements.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of five (5) years from the date of each transaction.
• Gameplay Records: Detailed gameplay logs are retained for a minimum of three (3) years from the date of each gaming session.
• Customer Support Communications: Records of customer support interactions are retained for a minimum of two (2) years from the date of the last interaction.
• Marketing Data: Where you have consented to receive marketing communications, we retain your marketing preferences until you withdraw your consent or request deletion of your data.

Upon expiry of the applicable retention period, your personal information will be securely deleted or anonymised in accordance with our data disposal procedures. In some cases, we may retain anonymised or aggregated data for analytical purposes after the retention period has expired, provided that such data can no longer be used to identify you.

SECTION 08 8. Your Privacy Rights

Under the Data Privacy Act of 2012 and other applicable Philippine data protection laws, you have the following rights with respect to your personal information held by jili100:

• Right to Be Informed: You have the right to be informed about how your personal information is collected, used, stored, and shared. This Privacy Policy is our primary means of fulfilling this obligation.
• Right of Access: You have the right to request a copy of the personal information we hold about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal information we hold about you. You may update certain account information directly through your jili100 account settings.
• Right to Erasure: You have the right to request the deletion of your personal information in certain circumstances, such as where the data is no longer necessary for the purposes for which it was collected, or where you withdraw your consent. Please note that this right is subject to our legal and regulatory retention obligations.
• Right to Data Portability: You have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format, and to request that we transmit this data to another data controller where technically feasible.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes at any time. You may also object to processing based on our legitimate interests, subject to certain conditions.
• Right to Withdraw Consent: Where we process your personal information based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

To exercise any of these rights, please contact our Data Protection Officer. We will respond to all verified requests within thirty (30) days. In some cases, we may need to verify your identity before processing your request. We reserve the right to refuse requests that are manifestly unfounded, excessive, or that would require us to breach our legal or regulatory obligations.

SECTION 09 9. Cookies and Tracking Technologies

jili100 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver relevant content and advertising. A cookie is a small text file that is stored on your device when you visit a website. We use the following categories of cookies:

9.1 Strictly Necessary Cookies

These cookies are essential for the operation of the Platform and cannot be disabled. They enable core functions such as account authentication, session management, security, and fraud prevention. Without these cookies, the Platform cannot function properly.

9.2 Performance and Analytics Cookies

These cookies collect information about how you use the Platform, such as which pages you visit most frequently and whether you encounter any errors. This information is used in aggregate form to improve the performance and usability of the Platform. We use analytics tools to process this data.

9.3 Functional Cookies

These cookies allow the Platform to remember your preferences and settings, such as your preferred language, display settings, and whether you have previously accepted our cookie policy. They enhance the personalisation of your experience on the Platform.

9.4 Marketing Cookies

With your consent, we may use marketing cookies to track your browsing activity and deliver targeted promotional content relevant to your interests. You may withdraw your consent to marketing cookies at any time through your browser settings or our cookie preference centre.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information about managing cookies, refer to your browser's help documentation.

SECTION 10 10. Third-Party Services

The jili100 Platform integrates with a number of third-party services to deliver a complete gaming experience. These include payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank; identity verification providers; game software suppliers; and customer support platforms. Each of these third-party providers operates under their own privacy policies and data protection practices.

jili100 carefully selects its third-party partners and requires them to maintain data protection standards consistent with applicable Philippine law. However, jili100 is not responsible for the privacy practices of third-party services that operate independently of the Platform. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of jili100.

SECTION 11 11. Children's Privacy

The jili100 Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine gaming regulations. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal information from a person under the age of 21, we will take immediate steps to delete that information and close the associated account.

If you are a parent or guardian and believe that your child has provided personal information to jili100, please contact our support team immediately so that we can investigate and take appropriate action.

SECTION 12 12. Changes to This Privacy Policy

jili100 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. When we make material changes to this Policy, we will notify registered users by email or through a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this Policy. We encourage you to review this Policy periodically to stay informed about how jili100 protects your personal information. Your continued use of the Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy.

If you have any questions, concerns, or complaints regarding this Privacy Policy or jili100's data processing practices, please do not hesitate to reach out to our Data Protection Officer. We are committed to resolving all privacy-related concerns promptly and transparently.