Jilli Win Privacy Policy – How We Protect Your Personal Data

1Introduction

Jilli Win ("we," "us," "our") operates jilliwin.app, an online casino and sports betting platform licensed by the Philippine Amusement and Gaming Corporation (PAGCOR) and serving players in the Philippines. This Privacy Policy explains how Jilli Win collects, processes, stores, and protects the personal information of registered players and visitors to the platform.

This Policy is published in compliance with Republic Act 10173, the Data Privacy Act of 2012, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. It applies to all personal data collected through jilliwin.app, the Jilli Win mobile browser interface, and any communications you have with the Jilli Win team.

By registering an account with Jilli Win, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal information as described here. Kung may tanong ka, huwag nang mahiyang makipag-ugnayan sa aming support team — that's what they're there for.

2Personal Data We Collect

Jilli Win collects personal information in the following categories. We collect only what is necessary for the stated purposes.

Jilli Win does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where required by specific PAGCOR or AMLC verification obligations (for example, a selfie photograph for identity verification purposes).

3How We Collect Your Data

Jilli Win collects personal information through the following channels:

• Direct registration: Information you provide when creating a Jilli Win account, including name, mobile number, date of birth, and payment details.
• Identity verification: Documents or images you submit when Jilli Win requests identity verification in compliance with KYC (Know Your Customer) requirements under PAGCOR regulations and the Anti-Money Laundering Act.
• Transactional activity: Data automatically generated each time you make a deposit, withdrawal, or place a bet on Jilli Win — including timestamps, amounts, game outcomes, and payment method references.
• Device and browser data: Technical information automatically collected when you access Jilli Win through your device, including your IP address, browser version, and device model.
• Cookies and tracking technologies: Session identifiers, preference cookies, and analytics data collected through the Jilli Win platform as described in Section 7 of this Policy.
• Customer support interactions: Information shared with the Jilli Win support team through live chat, email, or any other communication channel.
• Third-party verification providers: Identity and address verification data returned by regulated third-party KYC and fraud prevention services used by Jilli Win.

4How Jilli Win Uses Your Personal Data

Jilli Win uses collected personal data only for the purposes described below. We do not use your data in ways that are incompatible with these stated purposes without seeking your separate consent.

• Account management: Creating, maintaining, and securing your Jilli Win account, including authentication, password reset, and two-factor verification processes.
• Transaction processing: Facilitating deposits, withdrawals, and any financial transfer associated with your Jilli Win account. Your payment data is processed through PCI-DSS compliant payment providers.
• Identity and age verification: Confirming that you meet Jilli Win's eligibility requirements — including being at least 21 years old and being the named account holder — in compliance with PAGCOR licence conditions.
• Regulatory compliance: Fulfilling mandatory reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine regulatory bodies. This includes the retention of transaction records as required by law.
• Responsible gaming: Monitoring play patterns for signs of problem gambling behaviour, applying player-requested limits, enforcing self-exclusion decisions, and making referrals to support resources where appropriate.
• Security and fraud prevention: Detecting, investigating, and preventing fraud, cheating, money laundering, bot usage, and other prohibited activities on the Jilli Win platform.
• Customer support: Responding to your questions, resolving disputes, and processing complaints through the Jilli Win support team.
• Platform improvement: Using anonymised and aggregated usage data to improve game selection, user experience, and technical performance on Jilli Win.
• Marketing communications: Sending promotional offers, tournament announcements, and product updates to players who have opted in to marketing communications. See Section 12 for opt-out information.

5Legal Basis for Processing

Under Republic Act 10173, Jilli Win processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to provide the services described in the Jilli Win Terms and Conditions — account creation, transaction processing, game access, and withdrawal handling — is necessary to perform our contractual obligations to you as a player.
• Consent: Where Jilli Win requests consent for optional processing — such as marketing communications — we obtain your express, informed, and freely given consent before proceeding. You may withdraw this consent at any time.
• Legal obligation: Certain processing is required by Philippine law, including KYC verification under PAGCOR regulations, transaction record retention under the AMLC Act, and data breach notification under RA 10173.
• Legitimate interests: Processing for fraud prevention, security monitoring, responsible gaming oversight, and platform improvement is conducted on the basis of Jilli Win's legitimate interest in operating a safe and fair platform, provided this does not override your privacy rights.

6Data Sharing & Disclosure

Jilli Win does not sell your personal data. We share personal information only with the categories of third parties described below, and only to the extent necessary for the stated purpose.

Regulated Third-Party Service Providers

• Payment processors: GCash (Mynt), Maya (Voyager Innovations), GrabPay, InstaPay/PESONet network members, BDO, BPI, UnionBank, and card networks — to process your deposits and withdrawals.
• KYC and identity verification providers: Regulated providers used to verify identity documents and confirm player eligibility in compliance with PAGCOR requirements.
• Anti-fraud and security providers: Specialist third-party services used to detect bot activity, account takeover attempts, and financial fraud patterns.
• Cloud hosting and infrastructure providers: Providers of the server infrastructure on which Jilli Win operates, subject to data processing agreements that bind them to the same privacy standards as Jilli Win.
• Customer support technology providers: Software platforms used to operate the Jilli Win help desk and live chat system.

Regulatory and Law Enforcement Disclosure

Jilli Win is legally required to disclose certain player data to the following authorities when requested under applicable Philippine law:

• Philippine Amusement and Gaming Corporation (PAGCOR) — in connection with licence compliance audits and player complaint investigations
• Anti-Money Laundering Council (AMLC) — for suspicious transaction reports and covered transaction reports required under RA 9160 and its amendments
• National Privacy Commission (NPC) — in connection with data breach notifications and privacy complaint investigations
• Philippine law enforcement agencies — pursuant to valid court orders or legal process issued by Philippine courts

7Cookies & Tracking Technologies

Jilli Win uses cookies and similar technologies to operate the platform and improve your experience. Here's a plain breakdown of what we use and why:

You can manage non-essential cookies through your browser settings. Note that disabling preference and analytics cookies will not affect your ability to play on Jilli Win, but essential and responsible gaming cookies cannot be disabled without breaking account functionality or disabling safety features.

8Data Retention

Jilli Win retains personal data for the periods described below, after which it is securely deleted or anonymised:

• Account data (active accounts): Retained for the duration of the account relationship. Data is reviewed annually and updated if inaccurate.
• Transaction and bet records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLC Act and PAGCOR record-keeping regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years from account closure or the end of the customer relationship.
• Responsible gaming records (self-exclusion, limit history): Retained for a minimum of five (5) years to ensure that exclusion decisions are respected if a player later attempts to re-register.
• Customer support communications: Retained for three (3) years from the date of the last communication.
• Marketing consent records: Retained until consent is withdrawn plus one (1) year to demonstrate compliance.

When a player closes their Jilli Win account, personal data is retained for the mandatory legal retention periods above. After those periods expire, data is securely deleted from Jilli Win systems.

9Data Security

Jilli Win implements a combination of technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• TLS/SSL encryption: All data transmitted between your device and Jilli Win servers is encrypted using industry-standard Transport Layer Security (TLS 1.2 or higher).
• At-rest encryption: Personal and financial data stored in Jilli Win databases is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data within Jilli Win is restricted to staff members who require it to perform their job functions. All access is logged and auditable.
• Two-factor authentication: Available and recommended for all player accounts. Mandatory for internal Jilli Win staff accounts that access player data.
• Regular security audits: Jilli Win undergoes periodic security assessments including vulnerability scanning and penetration testing conducted by qualified third-party security professionals.
• Incident response: Jilli Win maintains a documented data breach response plan that complies with RA 10173 notification requirements. In the event of a breach affecting your personal data, you will be notified as required by law.

10Your Privacy Rights Under RA 10173

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal information held by Jilli Win. These rights can be exercised by contacting our Data Protection Officer at support@jilliwin.app.