Privacy Policy

1. Who We Are

This Privacy Policy applies to the jilli33 platform, accessible at jilli33.net, and all associated services, mobile applications, and features operated under the jilli33 brand (collectively, the "Platform"). For the purposes of this Policy, jilli33 acts as the personal information controller of the personal data you provide when using the Platform.

jilli33 is committed to protecting the privacy and security of all personal data it processes. This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

2. Data We Collect

jilli33 collects the following categories of personal data from users of the Platform:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government-issued ID number, selfie/photo for KYC	Account registration, age verification, KYC compliance
Contact Data	Email address, mobile number, residential address	Account communication, OTP delivery, support
Financial Data	GCash number, PayMaya account, bank account details, transaction history	Processing deposits and withdrawals, AML compliance
Technical Data	IP address, device type, browser, operating system, session logs	Security monitoring, fraud detection, platform optimization
Usage Data	Games played, wager amounts, session duration, feature interactions	Responsible gaming monitoring, personalization, analytics
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer support, dispute resolution, quality assurance

jilli33 does not collect sensitive personal information (as defined under RA 10173) unless strictly required for regulatory compliance, such as government ID details for KYC verification. Where sensitive data is collected, it is handled with heightened security measures and processed only on the basis of explicit consent or legal obligation.

3. How We Collect Data

jilli33 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 support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud signals from payment processors; publicly available information where permitted by law.

4. Why We Use Your Data

jilli33 uses your personal data for the following purposes:

• To create, verify, and manage your jilli33 account.
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine law.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities, including compliance with Anti-Money Laundering Act (AMLA) obligations.
• To provide customer support and resolve disputes.
• To send you transactional communications (account notifications, security alerts, withdrawal confirmations).
• To send you promotional communications about jilli33 offers and bonuses, where you have consented to receive such communications.
• To monitor your gaming activity for responsible gaming purposes and to apply any responsible gaming tools you have activated.
• To improve the Platform's performance, features, and user experience through analytics.
• To comply with applicable laws, regulations, and regulatory requests from PAGCOR, the NPC, the AMLC, and other competent authorities.

5. Legal Bases for Processing

jilli33 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and jilli33 (e.g., account management, payment processing).
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA obligations, and NPC requirements.
• Legitimate interests: Processing necessary for jilli33's legitimate interests, including fraud prevention, platform security, and business analytics, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Data

jilli33 does not sell, rent, or trade your personal data. We may share your 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/Maya, and Philippine banking partners, for the purpose of processing your financial transactions.
• KYC and identity verification providers: Third-party services that assist jilli33 in verifying your identity and age in compliance with regulatory requirements.
• IT and infrastructure providers: Cloud hosting, security, and analytics service providers that support the operation of the Platform.
• Regulatory authorities: PAGCOR, the AMLC, the NPC, the Bureau of Internal Revenue (BIR), and other competent Philippine government authorities, where required by law or regulation.
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate a crime.
• Professional advisers: Lawyers, auditors, and accountants, subject to professional confidentiality obligations.

All third- party recipients are contractually required to process your personal data only for the specified purpose and in accordance with jilli33's instructions and applicable Philippine data privacy law.

7. Cookies & Tracking Technologies

jilli33 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, maintain your session, and understand how you use the Platform.

The types of cookies jilli33 uses include:

• Strictly necessary cookies: Required for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and security.
• Analytics cookies: Help jilli33 understand how users interact with the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Functional cookies: Remember your preferences (such as language settings) to provide a more personalized experience.
• Security cookies: Used to detect and prevent fraudulent activity and unauthorized access.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. jilli33 does not use third-party advertising or tracking cookies.

8. Data Retention

jilli33 retains your personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. 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 after account closure, as required by PAGCOR licensing conditions and AMLA regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA and BIR requirements.
• Support communications: Retained for three (3) years from the date of the communication, or longer if related to an ongoing dispute or legal matter.
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods for security or legal purposes.
• Marketing consent records: Retained for the duration of your consent and for one (1) year after withdrawal of consent.

When personal data is no longer required, jilli33 will securely delete or anonymize it in accordance with industry-standard data destruction practices.

9. Data Security

jilli33 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jilli33's servers.
• Encryption of sensitive data at rest, including financial data and government ID information.
• Multi-factor authentication (MFA) for access to internal systems containing personal data.
• Role-based access controls ensuring that only authorized personnel can access personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• 24/7 security monitoring and intrusion detection systems.
• Staff training on data privacy and security obligations under Philippine law.

Despite these measures, no system is completely immune to security risks. In the event of a personal data breach that poses a real risk to your rights and freedoms, jilli33 will notify you and the NPC in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jilli33:

To exercise any of these rights, contact jilli33's Data Protection Officer at [email protected]. jilli33 will respond to your request within fifteen (15) working days, as required by the Data Privacy Act. We may need to verify your identity before processing your request.

11. Children's Privacy

The jilli33 Platform is strictly intended for persons who are 21 years of age or older, in accordance with Philippine law applicable to casino-style gambling. jilli33 does not knowingly collect personal data from individuals under the age of 21. If jilli33 becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be terminated.

If you believe that a minor has registered on the jilli33 Platform, please contact us immediately at [email protected] so that we can take appropriate action.

12. Cross-Border Data Transfers

jilli33 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines (for example, cloud hosting services), jilli33 ensures that such transfers are made only to countries or organizations that provide an adequate level of data protection, or subject to appropriate contractual safeguards such as standard contractual clauses approved by the NPC.

jilli33 will not transfer your personal data to jurisdictions that do not provide adequate data protection without your explicit consent or a valid legal basis under the Data Privacy Act.

13. Updates to This Policy

jilli33 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, jilli33 will notify registered users via email or a prominent notice on the Platform. The date of the most recent revision is displayed at the top of this page.

Your continued use of the jilli33 Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. We encourage you to review this Policy periodically to stay informed about how jilli33 protects your personal data.

14. Contact & Data Protection Officer

jilli33 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests regarding your personal data or this Policy, please contact:

• Data Protection Officer: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 on the Platform

If you are not satisfied with jilli33's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.