jililu Privacy Policy —
Your Data, Your Rights, Our Obligations

1. Introduction

jililu operates the Philippines' premier Black Diamond VIP online casino platform at jililu.net, offering a full suite of licensed gaming products including JILI slots, live dealer casino tables, sports betting markets, bingo, and fishing games to Filipino players aged 21 and above. As a PAGCOR-regulated online gaming operator, jililu is required by law to collect and process certain categories of personal data from our Members and platform visitors.

This Privacy Policy describes in plain, accessible language how jililu — as the personal information controller — handles your personal data from the moment you first visit jililu.net through the full lifecycle of your membership. We believe that informed consent is genuine consent, and so we have written this policy to be as clear and complete as possible, in line with the plain language obligations under the Data Privacy Act's implementing rules.

This policy applies to all personal data collected through the jililu website at jililu.net, the jililu mobile platform, jililu customer support channels (including live chat and email), and any marketing communications you receive from jililu. It applies to all jililu Members (registered account holders), prospective Members (visitors who have not yet registered), and former Members whose data jililu retains within lawful retention periods.

2. Data Controller Identity

For purposes of the Philippine Data Privacy Act of 2012, jililu is the personal information controller in respect of all personal data processed through the jililu platform. As the controller, jililu determines the purposes and means of processing your personal data and bears primary responsibility for ensuring that processing is lawful, proportionate, and consistent with the rights of data subjects.

jililu's designated Data Protection Officer (DPO) is responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act. The DPO's contact details are set out in Section 14 of this policy. The DPO can be contacted for any queries, concerns, or formal data subject rights requests related to jililu's handling of your personal data.

jililu's operations are licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR). In its capacity as a PAGCOR licensee, jililu is also subject to PAGCOR's data governance requirements applicable to licensed online gaming operators, including obligations related to player identity verification, transaction monitoring, and responsible gaming record-keeping.

3. Personal Data We Collect

3.1 Registration Data

When you create a jililu account, we collect the following personal data that you provide directly: your full legal name, date of birth, residential address in the Philippines (including city — e.g., Manila, Cebu, Davao, Quezon City, or Makati), email address, and mobile phone number. This data is required to create and maintain your account and cannot be omitted.

3.2 KYC Verification Data

To comply with PAGCOR's player identity verification requirements and the Philippine Anti-Money Laundering Act (AMLA), jililu collects copies of government-issued photo identification documents (such as the PhilSys National ID, Philippine passport, UMID, or driver's licence), selfie photographs, and proof of residential address. This data is collected at the point of withdrawal request or when triggered by transaction monitoring thresholds.

3.3 Financial and Payment Data

jililu collects transaction records associated with your account, including deposit and withdrawal amounts, timestamps, payment method references (e.g., GCash mobile number, Maya account reference, BPI/BDO/Metrobank account name), and transaction IDs. jililu does not store complete bank account numbers or full payment card numbers on its own systems — payment processing is handled by certified third-party payment processors under their own PCI-DSS compliance obligations.

3.4 Gaming Activity Data

jililu's systems automatically record your gaming activity on the platform, including games played, bet amounts, wager history, session durations, game outcomes, and bonus activation records. This data is used for game result verification, responsible gaming monitoring, bonus integrity checks, and regulatory reporting as required by PAGCOR.

3.5 Technical and Device Data

When you access jililu.net, we automatically collect certain technical data, including your IP address, browser type and version, operating system, device type, screen resolution, referring URL, and pages visited within the jililu platform. This data is collected via server logs and analytics tools and is used for platform security, fraud detection, and service improvement purposes.

3.6 Communication Data

If you contact jililu via live chat, email, or any other support channel, we collect and retain the content of those communications, along with associated metadata (date, time, agent ID). This data is used to resolve your query, train support staff, and maintain a record of jililu's customer service interactions.

3.7 Data Collected — Summary Table

4. Purpose & Legal Basis for Processing

jililu processes your personal data only for the purposes listed below and only where a lawful basis under the Data Privacy Act applies:

• Account Creation and Management — Processing your registration data to create and maintain your jililu account. Legal basis: performance of contract.
• Identity and Age Verification (KYC) — Verifying that you are who you say you are and that you are aged 21 or above, as required by PAGCOR regulations. Legal basis: compliance with legal obligation.
• Payment Processing — Processing your deposits and withdrawal requests via GCash, Maya, BPI, BDO, Metrobank, and other accepted channels. Legal basis: performance of contract.
• Regulatory Compliance and AML Monitoring — Monitoring transactions for Anti-Money Laundering Act compliance and reporting to PAGCOR and the Anti-Money Laundering Council (AMLC) where required. Legal basis: compliance with legal obligation.
• Platform Security and Fraud Prevention — Detecting and preventing fraudulent activity, collusion, multi-accounting, and unauthorised access. Legal basis: legitimate interests of jililu and protection of other Members.
• Responsible Gaming Monitoring — Monitoring gaming behaviour to identify signs of problem gambling and to deliver responsible gaming interventions and tools. Legal basis: compliance with PAGCOR responsible gaming requirements and legitimate interests.
• Customer Support — Responding to your enquiries, resolving disputes, and managing your account-related requests. Legal basis: performance of contract.
• Marketing Communications — Sending you promotional offers, VIP programme updates, and platform news where you have opted in to receive marketing communications. Legal basis: consent (freely given, specific, and revocable at any time).
• Platform Improvement and Analytics — Analysing aggregated and anonymised platform usage data to improve the jililu user experience and game offering. Legal basis: legitimate interests.

jililu will not process your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis under the Data Privacy Act.

5. Cookies & Tracking Technologies

jililu uses cookies and similar tracking technologies on the jililu.net website to operate essential platform functions, maintain your login session, remember your preferences, and collect analytics data. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking the platform.
• Functional Cookies: Remember your language preferences, display settings, and account dashboard layout choices to improve your experience on jililu.net.
• Analytics Cookies: Collect anonymised data about how Members navigate and use the jililu platform — such as which games are most visited and where Members encounter errors — to help jililu improve platform performance and content.
• Marketing Cookies: Where you have consented, these cookies enable jililu to tailor promotional content shown on the jililu platform to your stated interests and gaming activity profile.

You can manage your cookie preferences at any time via the cookie settings panel accessible from the jililu footer. Note that disabling non-essential cookies may affect some platform features. Strictly necessary cookies cannot be disabled as they are essential to platform operation. Most browsers also allow you to control cookies via browser settings — please refer to your browser's help documentation for guidance.

6. Data Sharing & Disclosure

jililu shares your personal data only in the following defined circumstances:

6.1 Authorised Service Providers

jililu engages third-party service providers who process personal data on jililu's behalf as personal information processors. These include payment processors (for GCash, Maya, and bank transfer settlement), KYC verification technology providers, IT hosting and cloud infrastructure providers, customer support platform providers, and anti-fraud analytics providers. All processors are bound by data processing agreements that prohibit them from using jililu Member data for any purpose other than performing the contracted service.

6.2 Regulatory and Law Enforcement Disclosure

jililu is required by Philippine law to disclose personal data and transaction records to PAGCOR, the AMLC, the National Privacy Commission (NPC), and other competent authorities when lawfully demanded. jililu will not notify you of such disclosures where prohibited from doing so by law or court order.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jililu's business, Member personal data may be transferred to the acquiring entity as part of the transaction, subject to the acquiring entity assuming jililu's obligations under this Privacy Policy and applicable Philippine data privacy law. Members will be notified of such transfers via their registered email address prior to the transfer taking effect.

6.4 No Sale of Data

jililu does not sell, rent, or otherwise commercially transfer your personal data to any third party for their own marketing or commercial purposes. This is an absolute restriction with no exceptions.

7. Data Retention

jililu retains personal data only for as long as is necessary for the purpose for which it was collected or as required by applicable Philippine law and PAGCOR regulations. The following retention periods apply:

• Account and Registration Data: Retained for the duration of active membership plus five (5) years following account closure, as required by PAGCOR record-keeping obligations and the AMLA.
• KYC and Identity Documents: Retained for five (5) years from the date of submission or from the date of account closure, whichever is later, in line with AMLA record-keeping requirements.
• Financial Transaction Records: Retained for ten (10) years from the date of the transaction, as required by the AMLA and associated PAGCOR obligations.
• Gaming Activity Data: Retained for five (5) years from the date of the gaming session, for regulatory audit, dispute resolution, and responsible gaming monitoring purposes.
• Support Communications: Retained for three (3) years from the date of the communication, for dispute resolution and training purposes.
• Analytics and Technical Data: Aggregated and anonymised within 12 months of collection; raw server log data is retained for 90 days for security purposes.
• Marketing Consent Records: Retained for the duration of membership plus three (3) years to maintain evidence of lawful processing.

Upon expiry of the applicable retention period, jililu will securely delete or anonymise the relevant personal data in accordance with NPC-approved disposal procedures.

8. Security Measures

jililu implements a multi-layered technical and organisational security programme designed to protect Member personal data against unauthorised access, loss, destruction, or alteration. Key security measures include:

• Transport Layer Security: All data transmitted between your device and jililu's servers is encrypted using TLS 1.3, the current industry standard for secure web communications.
• Encryption at Rest: Sensitive personal data — including identity documents and payment references — is encrypted using AES-256 at rest in jililu's data infrastructure.
• Access Controls: Personal data is accessible only to jililu staff and service providers on a strict need-to-know basis. Access is governed by role-based access controls and logged for audit purposes.
• Two-Factor Authentication: jililu offers two-factor authentication (2FA) to all Members for account login. Members are strongly encouraged to enable 2FA to protect their account.
• Penetration Testing: jililu's platform undergoes regular independent security penetration testing and vulnerability assessments. Critical vulnerabilities are remediated within defined SLAs.
• Incident Response: jililu maintains a documented personal data breach response procedure. In the event of a breach that poses a real risk to data subjects, jililu will notify the NPC within 72 hours of becoming aware of the breach and will notify affected Members without undue delay, as required by the Data Privacy Act.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in respect of your personal data held by jililu:

• Right to be Informed: You have the right to be informed of how jililu collects, uses, and shares your personal data — which is the primary purpose of this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data jililu holds about you, together with information about how it is processed. jililu will provide this within 15 business days of a verified request.
• Right to Correction / Rectification: You have the right to request that inaccurate or incomplete personal data held by jililu be corrected. You may update most of your account information directly via the jililu account dashboard. For KYC document corrections, please contact support.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the processing is unlawful. This right is subject to jililu's legal retention obligations — jililu cannot delete data that it is legally required to retain under PAGCOR or AMLA requirements.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time, with immediate effect. You may also object to processing based on legitimate interests, subject to jililu demonstrating compelling legitimate grounds that override your interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to request its transmission to another controller where technically feasible.
• Right to Damages: You have the right to claim compensation for any actual damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data by jililu.
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jililu has violated your data privacy rights.

To exercise any of the above rights, please contact jililu's Data Protection Officer using the details in Section 14. All rights requests must be submitted in writing and will require identity verification before processing. jililu will not charge a fee for handling data subject rights requests except in cases of manifestly unfounded or excessive repetitive requests.

10. Minors & Age Restriction

The jililu platform is strictly restricted to individuals aged 21 years and above in accordance with PAGCOR regulations governing casino-style online gaming in the Philippines. jililu does not knowingly collect personal data from persons under 21 years of age.

During the registration process, jililu collects date of birth information and conducts age verification checks as part of KYC procedures. Where jililu becomes aware — through KYC review, complaint, or any other means — that an account has been registered by or is being used by a person under 21, jililu will immediately suspend the account, void all associated transactions, and securely delete the minor's personal data in accordance with Data Privacy Act obligations, retaining only the minimum records necessary to document the incident for regulatory compliance purposes.

If you are a parent or guardian and believe that a person under 21 in your care has registered a jililu account, please contact jililu support immediately using the contact details in Section 14 so that we may take prompt action.

11. Cross-Border Data Transfers

jililu's primary data processing infrastructure is located within jurisdictions that maintain data protection standards compatible with the Philippine Data Privacy Act. Where jililu engages service providers — such as cloud infrastructure providers, KYC technology vendors, or analytics platforms — that process data outside the Philippines, jililu ensures that such transfers are protected by one or more of the following safeguards:

• Contractual clauses in data processing agreements that impose data protection obligations equivalent to those under Philippine law.
• Processing by providers located in countries recognised by the NPC as providing adequate levels of data protection.
• Binding corporate rules where data is transferred within a group of affiliated companies subject to group-wide data governance standards.

By accepting this Privacy Policy, you consent to your personal data being transferred to and processed in jurisdictions outside the Philippines where jililu's authorised service providers operate, subject to the safeguards described above. You may request details of specific international transfer arrangements by contacting jililu's Data Protection Officer.

12. Third-Party Links & Integrations

The jililu platform integrates third-party game content from certified game developers, including JILI and other PAGCOR-approved providers. These game integrations are hosted within the jililu platform environment and operate under jililu's data governance framework. Game developer partners do not receive independently identifiable personal data about jililu Members beyond the minimum technical session data required to deliver the game session.

This Privacy Policy applies exclusively to the jililu platform at jililu.net and does not govern the privacy practices of any third-party websites or services that may be referenced elsewhere. jililu is not responsible for the content or privacy practices of any external website. Members are encouraged to review the privacy policies of any external platforms they access independently of jililu.

13. Changes to This Privacy Policy

jililu reserves the right to update this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidance, PAGCOR regulatory requirements, or jililu's data processing practices. The "Last Updated" date at the top of this policy reflects the date of the most recent revision.

Where changes to this Privacy Policy are material — meaning they affect your rights as a data subject or significantly change how jililu uses your personal data — jililu will notify you via your registered email address at least seven (7) days before the changes take effect. Non-material changes (such as clarifications or typographical corrections) may take effect immediately upon publication.

Your continued use of the jililu platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the updated policy. If you do not agree with a material change to this policy, you have the right to close your jililu account in accordance with the account closure process described in jililu's Terms & Conditions.

14. Contact & Data Protection Officer

For any questions, concerns, or formal requests relating to this Privacy Policy or jililu's handling of your personal data, please contact jililu's Data Protection Officer through the following channels:

• Email (plain text — not a link): [email protected]
• Subject Line: Please use "Data Privacy Request – [Your Registered Name]" for all formal data subject rights requests to ensure prompt routing to the DPO team.
• Live Chat: Available 24/7 via the jililu platform. State that your query relates to "Data Privacy" at the start of the chat session.
• Response Time: jililu aims to acknowledge all data privacy enquiries within two (2) business days and to resolve formal data subject rights requests within fifteen (15) business days of identity verification.

If you are not satisfied with jililu's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines via the NPC's official complaint channels. The NPC is the competent supervisory authority for data protection matters under the Data Privacy Act of 2012.