jilli9 Privacy Policy

1 Overview & Scope

This Privacy Policy applies to all personal data collected by jilli9 through the jilli9.app website, mobile platform, customer support channels, and any other services operated by jilli9 (collectively, the "Platform"). It applies to all registered players, visitors, and any individual whose personal data is processed by jilli9 in connection with the Platform.

jilli9 acts as the data controller for personal data collected through the Platform. This means jilli9 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws, including the Philippine Data Privacy Act of 2012 (RA 10173).

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your use of the jilli9 Platform.

2 Personal Data We Collect

jilli9 collects the following categories of personal data:

jilli9 does not collect sensitive personal information (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless specifically required by law or with your explicit consent.

3 How We Collect Your Data

jilli9 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical data collected automatically when you access the Platform, including cookies, web beacons, log files, and similar tracking technologies.
• Third-party sources: Data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, fraud prevention services, and analytics providers — all of whom are bound by confidentiality obligations.
• Regulatory sources: Data received from regulatory authorities or law enforcement agencies in connection with our legal compliance obligations.

4 Purpose of Processing

jilli9 processes your personal data for the following purposes:

• To create and manage your jilli9 player account and verify your identity and age (21+ requirement).
• To process deposits, withdrawals, and other financial transactions in Philippine Peso via your chosen payment method.
• To provide, maintain, and improve the jilli9 gaming platform and all associated services.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements and Know Your Customer (KYC) verification.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited activities.
• To provide customer support and respond to your inquiries and complaints.
• To send you service-related communications, including account notifications, security alerts, and transaction confirmations.
• To send you marketing communications about jilli9 promotions and offers, where you have consented to receive such communications.
• To conduct responsible gaming monitoring and provide you with responsible gaming tools and interventions where appropriate.
• To analyze Platform usage and improve user experience through aggregated, anonymized analytics.

5 Legal Basis for Processing

jilli9 processes your personal data on the following legal bases under the Philippine 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 laws, including AML regulations, KYC requirements, and gaming regulations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time by contacting our support team.

6 Data Sharing & Disclosure

jilli9 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 only to the extent necessary:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and eligibility.
• Game software providers: Licensed game suppliers whose games are available on the jilli9 Platform, to the extent necessary to provide gameplay services.
• Fraud prevention and security services: Providers that help jilli9 detect and prevent fraudulent activity, money laundering, and other prohibited conduct.
• Regulatory and law enforcement authorities: Where required by law, court order, or regulatory directive, including disclosures to PAGCOR or other Philippine government agencies.
• Professional advisers: Lawyers, auditors, and other professional advisers bound by confidentiality obligations.

7 Data Retention

jilli9 retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and our legitimate business interests. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML and gaming regulatory requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session.
• Customer support communications: Retained for two (2) years from the date of the last communication.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation purposes.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, jilli9 will securely delete or anonymize that data.

8 Security Measures

jilli9 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 transmitted between your device and the jilli9 Platform.
• Encryption of sensitive data at rest, including financial data and KYC documents.
• Role-based access controls ensuring that only authorized jilli9 personnel can access personal data, and only to the extent required for their specific role.
• Regular security audits, vulnerability assessments, and penetration testing of the jilli9 Platform.
• Multi-factor authentication for internal systems and, where available, for player accounts.
• Secure data centers with physical access controls and environmental safeguards.
• Incident response procedures to detect, contain, and report data breaches in accordance with applicable law.

9 Cookies & Tracking Technologies

jilli9 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function, including session management, authentication, and security. These cannot be disabled.
• Functional cookies: Remember your preferences (such as language settings) to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the Platform to help us improve performance and user experience.
• Marketing cookies: Used to deliver relevant promotional content about jilli9 offers. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the jilli9 Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jilli9:

• Right to be informed: The right to know what personal data jilli9 collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data jilli9 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to object: The right to object to processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact the jilli9 Data Privacy Officer via our support team. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

11 Minors & Age Restriction

If you are a parent or guardian and believe that a minor has registered on jilli9 or provided personal data to jilli9 without your consent, please contact our support team immediately so we can take appropriate action.

12 International Data Transfers

Some of jilli9's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, jilli9 ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses that meet the standards required by the Philippine Data Privacy Act.

jilli9 will not transfer your personal data to any country that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13 Changes to This Privacy Policy

jilli9 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. When material changes are made, we will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent update is shown at the top of this page. We encourage you to review this Privacy Policy periodically. Your continued use of the jilli9 Platform after any update constitutes your acceptance of the revised Privacy Policy.

14 Contact & Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way jilli9 handles your personal data, please contact our Data Privacy Officer through the jilli9 support team. Our support is available 24/7 via live chat on the Platform.

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. Information about the NPC and how to file a complaint is available through official Philippine government channels.