jilliee Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how jilliee ("jilliee," "we," "our," or "us"), operator of the online gaming platform at https://jilliee.app, collects, uses, stores, shares, and protects personal information obtained from players and visitors ("you" or "your") in connection with the use of jilliee's website, platform, mobile browser interface, and all associated services (collectively, the "Platform").

jilliee is committed to protecting the privacy and personal data of all Filipino players in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC). This Policy should be read in conjunction with jilliee's Terms & Conditions.

By registering for a jilliee account, using the Platform, or otherwise interacting with jilliee's services, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with any part of this Policy, please do not use the Platform.

2. Data Controller Identity

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, jilliee acts as the Personal Information Controller (PIC) in respect of the personal data of players registered on the Platform.

jilliee has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection obligations. Contact details for the DPO are provided in Section 14 of this Policy.

3. Categories of Personal Data We Collect

jilliee collects personal data through the following channels: account registration, KYC verification, gameplay activity, financial transactions, customer support interactions, and automatic technical collection. The categories of data collected include:

jilliee does not collect sensitive personal information such as racial or ethnic origin, political opinions, or health information, except where required for responsible gaming assessments in specific circumstances involving player welfare concerns.

4. How jilliee Uses Your Personal Data

4.1 Account Management and Service Delivery

jilliee processes your personal data to create and maintain your player account, authenticate your jilliee login, process deposits and withdrawals via GCash, Maya, BDO, BPI, and other accepted methods, deliver game content, and provide customer support.

4.2 Regulatory Compliance and KYC

jilliee is legally obligated to verify player identity before processing withdrawals, and to conduct anti-money laundering (AML) and counter-terrorism financing (CTF) checks as required by Philippine financial regulations and applicable PAGCOR rules. Identity and financial data is processed for this purpose.

4.3 Fraud Prevention and Platform Security

Technical data, gaming data, and financial data are analysed to detect and prevent fraudulent activity, multi-accounting, bonus abuse, collusion, and unauthorised access to player accounts. This processing is essential to maintaining Platform integrity for all jilliee players.

4.4 Responsible Gaming

Gaming session data, deposit frequency, and wager patterns are monitored to identify players who may be exhibiting signs of problem gambling behaviour. jilliee uses this information to provide responsible gaming interventions such as deposit limit suggestions and self-exclusion notifications.

4.5 Marketing and Promotions

With your consent, jilliee may send promotional communications about new games, bonuses, and offers via SMS to your registered Philippine mobile number. You may withdraw this consent at any time through your account settings or by contacting jilliee support.

4.6 Platform Improvement

Aggregated and anonymised technical and gaming data is used to improve Platform performance, optimise game lobby curation, and enhance the overall player experience for Filipino users.

5. Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, jilliee processes personal data on the following lawful bases:

• Contractual necessity: Processing required to fulfil jilliee's obligations under the Terms & Conditions accepted at account registration (account management, payment processing, game delivery).
• Legal obligation: Processing required to comply with applicable Philippine laws, including Anti-Money Laundering Act (AMLA) compliance, PAGCOR reporting requirements, and NPC data subject rights obligations.
• Legitimate interests: Processing for fraud prevention, Platform security, and responsible gaming monitoring, where jilliee's interests in maintaining Platform integrity do not override the rights and interests of data subjects.
• Consent: Processing for marketing communications, where jilliee has obtained your prior express consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Third-Party Disclosure

jilliee does not sell your personal data to third parties. jilliee may share personal data with the following categories of recipients only as necessary for the purposes described in this Policy:

• Payment processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), and other payment service providers necessary to process your deposits and withdrawals.
• Game content providers: Licensed game studios (e.g., JILI Games, Pragmatic Play, PG Soft) who may receive aggregated session data for game performance monitoring. These providers do not receive directly identifiable player information beyond session identifiers.
• KYC and identity verification services: Third-party identity verification providers used to fulfil jilliee's KYC obligations.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government agencies, where jilliee is legally required to disclose information.
• IT and infrastructure service providers: Cloud hosting, cybersecurity, and platform operations vendors operating under binding data processing agreements with jilliee.

7. Cookies and Tracking Technologies

jilliee uses cookies and similar tracking technologies on its Platform for the following purposes:

• Strictly necessary cookies: Session authentication tokens, jilliee login state maintenance, load balancing. These cannot be disabled as they are essential to Platform functionality.
• Functional cookies: Language preferences, game lobby display settings, remembered username (where "Keep me signed in" is enabled).
• Analytics cookies: Aggregated, anonymised Platform usage data used to improve user experience and game lobby performance.
• Security cookies: Device fingerprinting tokens used to detect account takeover attempts and unauthorised jilliee login activity.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality including the ability to complete the jilliee login process.

8. Data Retention

jilliee retains personal data for the following periods, subject to applicable legal requirements:

• Active account data: Retained for the duration of your jilliee account plus a minimum of five (5) years following account closure, in compliance with AMLC and PAGCOR recordkeeping requirements.
• KYC identity documents: Retained for a minimum of five (5) years from the date of submission, as required by the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the transaction date in compliance with applicable Philippine financial regulations.
• Gaming session logs: Retained for a minimum of two (2) years for dispute resolution and responsible gaming monitoring purposes.
• Support communications: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained for the period of consent and three (3) years thereafter for compliance documentation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jilliee's data destruction protocols.

9. Data Security Measures

jilliee implements the following technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• TLS 1.3 encryption for all data in transit between your device and jilliee's servers.
• AES-256 encryption for personal data and financial information stored at rest.
• Multi-factor authentication requirements for jilliee platform administrative access.
• Regular penetration testing and vulnerability assessments by independent security firms.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Intrusion detection and real-time security monitoring systems.
• Incident response procedures with NPC notification protocols in the event of a data breach.

In the event of a personal data breach that poses a real risk to the rights and freedoms of affected players, jilliee 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, in accordance with NPC Circular No. 16-03.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, jilliee players have the following rights regarding their personal data:

• Right to be informed: The right to know what personal data jilliee holds about you and how it is processed.
• Right of access: The right to obtain a copy of your personal data held by jilliee.
• Right to rectification: The right to correct inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of personal data, subject to jilliee's legal retention obligations under AMLA and PAGCOR regulations.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: The right to object to processing of your personal data for marketing purposes at any time.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jilliee has not handled your personal data in compliance with RA 10173.

To exercise any of these rights, please contact jilliee's Data Protection Officer at the details provided in Section 14. jilliee will respond to all data subject rights requests within thirty (30) calendar days of receipt.

11. Children's Privacy

12. International Data Transfers

Where jilliee transfers personal data of Philippine players to recipients outside the Philippines — for example, to international game content providers or cloud infrastructure providers — jilliee ensures that such transfers comply with the requirements of the Philippine Data Privacy Act and NPC regulations, including by implementing appropriate safeguards such as standard contractual clauses or ensuring the recipient jurisdiction provides an adequate level of data protection as determined by the NPC.

jilliee does not transfer personal data to jurisdictions that lack adequate data protection safeguards without implementing appropriate supplementary measures.

13. Updates to This Privacy Policy

jilliee reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, NPC guidelines, PAGCOR requirements, or jilliee's data processing practices. Material changes to this Policy will be communicated to registered players via SMS notification to their registered Philippine mobile number and by posting a prominent notice on the Platform.

The effective date at the top of this Policy will be updated upon any revision. Continued use of the jilliee Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

14. Contact — Data Protection Officer

For all data privacy enquiries, data subject rights requests, complaints, or questions about this Privacy Policy, please contact jilliee's Data Protection Officer:

• Email (plain text): [email protected] — subject line: "Data Privacy Request"
• Live Chat: Available 24/7 through the Platform — request DPO escalation
• Response Time: Within 30 calendar days of receipt of a data subject rights request

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