JILIY Privacy Policy – How We Protect Your Data in the PH

1. Introduction

This Privacy Policy describes how JILIY ("we," "us," or "our"), operating through the website jiliy.best (the "Platform"), collects, uses, stores, and protects the personal information of players and visitors based in the Philippines.

JILIY is committed to handling your personal data responsibly, transparently, and in full compliance with Republic Act 10173, the Data Privacy Act of 2012, along with its Implementing Rules and Regulations (IRR) and the guidance of the National Privacy Commission (NPC).

By registering for a JILIY account or using any service on the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein. If you do not agree, you should not create an account or use the Platform.

2. What Personal Information We Collect

JILIY collects two broad categories of personal information: information you provide directly, and information generated automatically when you use the Platform.

Information You Provide Directly

• Registration data: Full legal name, date of birth, gender, nationality, home address, email address, and Philippine mobile number
• Identity verification (KYC): Government-issued ID (PhilSys ID, Passport, Driver's License, SSS/UMID), selfie photo for liveness verification, proof of address documents
• Payment information: GCash or Maya mobile number, bank account details (for bank transfer withdrawals), card details (handled by PCI DSS-compliant processors — JILIY does not store full card numbers)
• Account preferences: Responsible gaming limit settings, communication preferences, preferred language
• Support communications: Messages, complaints, and enquiries sent to our support team via chat or email

Information Generated Automatically

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Session timestamps, pages visited, and time spent on the Platform
• Game play history, bet amounts, win/loss records, and game session logs
• Transaction history (deposits, withdrawals, bonus claims)
• Cookie and tracking data (see Section 11)

3. How We Collect Your Information

JILIY collects personal information through the following channels:

• Direct submission: When you complete the registration form, submit KYC documents, make a deposit, request a withdrawal, or contact support
• Automatic collection: Through cookies, server logs, and analytics tools when you browse or play on the Platform
• Third-party verification services: Identity and address verification providers used during the KYC process
• Payment processors: Transaction confirmation and fraud signals shared by GCash, Maya, and banking partners in relation to your transactions on JILIY
• Regulatory databases: Self-exclusion registers and problem gambling databases maintained by relevant Philippine regulatory bodies, which JILIY checks as part of responsible gaming due diligence

4. How We Use Your Personal Information

JILIY uses your personal information for the following specific purposes:

JILIY does not use your personal data for any purpose not listed above without first obtaining your specific consent. Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173) and its IRR, JILIY processes your personal information based on the following legal grounds:

• Contractual necessity: Processing required to fulfil our obligations to you as a registered JILIY player — including account management, payment processing, and game service delivery
• Legal obligation: Processing required to comply with Philippine anti-money laundering laws (AMLA), gaming regulations, and tax reporting requirements
• Legitimate interests: Fraud detection, platform security, responsible gaming monitoring, and improving our services — provided these interests do not override your fundamental rights
• Consent: Marketing communications and any non-essential personalisation features — you can withdraw consent at any time without affecting your account

6. When and With Whom We Share Your Data

JILIY does not sell, rent, or trade your personal information. We share it only in the specific, limited circumstances described below:

Payment Processors

To process deposits and withdrawals, JILIY shares necessary transaction data with payment service providers including GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet operators, and card processing networks. These processors are contractually bound to handle your data securely and only for the purpose of completing your transaction.

Identity Verification Providers

For KYC compliance, JILIY uses third-party identity verification services. Your submitted documents and biometric data are shared with these providers solely for verification purposes and are not retained by them beyond the period required for the verification process.

Regulatory and Law Enforcement Authorities

JILIY is legally required to report certain information to Philippine regulatory bodies, including the Anti-Money Laundering Council (AMLC), PAGCOR, and law enforcement agencies, where mandated by law or court order. We will always verify the legal basis for any such request before disclosing data.

Service Providers

JILIY works with carefully selected third-party service providers for functions including cloud hosting, customer support software, fraud prevention, and analytics. These providers have access only to the data required for their specific function and are bound by data processing agreements that require them to protect your information to the same standard as JILIY.

7. How We Handle Payment Data

Payment data security is one of JILIY's highest priorities. Here is exactly how your financial information is handled:

• JILIY does not store full card numbers (PAN), CVV codes, or complete bank account credentials on its own systems
• All card transactions are tokenised and processed through PCI DSS Level 1-certified payment processors
• GCash and Maya mobile wallet transactions are processed directly through the official APIs of those platforms with end-to-end encryption
• Bank transfer details used for withdrawal are stored in encrypted form and accessible only to authorised finance staff for payment processing purposes
• Transaction records are retained for the period required by Philippine AML and tax law (generally 5–10 years) and then securely deleted

8. How Long We Keep Your Data

JILIY retains personal data only for as long as necessary for the purposes it was collected or as required by law. The general retention periods are as follows:

• Account data: For the lifetime of your active account plus 5 years after closure (required for AML compliance under Philippine law)
• KYC documents: For the lifetime of your active account plus 5 years after closure
• Transaction records: 10 years from the date of transaction (required under the AMLA)
• Game session logs: 2 years from the date of the session
• Support communications: 3 years from the date of last contact
• Marketing preferences: Until you withdraw consent or close your account

When data reaches the end of its retention period, it is securely deleted or anonymised so that it can no longer be associated with you as an individual. JILIY conducts periodic data audits to ensure retention schedules are followed.

9. Security Measures

JILIY implements a comprehensive range of technical and organisational measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction:

• Transport Layer Security (TLS 1.3): All data in transit between your browser and JILIY's servers is encrypted
• AES-256 encryption: Sensitive data at rest — including KYC documents and account credentials — is encrypted using AES-256
• Hashed passwords: Account passwords are stored as salted hashes using bcrypt. JILIY staff cannot see your plaintext password
• Two-factor authentication (2FA): Available for all player accounts and mandatory for internal staff accessing production systems
• Access controls: Personal data is accessible internally only to staff with a legitimate business need, enforced through role-based access control (RBAC)
• Penetration testing: JILIY's infrastructure undergoes regular security audits and penetration testing by qualified independent security firms
• Incident response plan: A documented breach response procedure is in place, including the 72-hour NPC notification requirement under RA 10173

While JILIY takes all reasonable steps to protect your data, no online system can be guaranteed 100% secure. You also play a role in keeping your account safe — use a strong, unique password, enable 2FA, and never share your login credentials with anyone.

10. Your Privacy Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you have the following rights regarding your personal information held by JILIY. To exercise any of these rights, contact us at support@jiliy.best.

JILIY will respond to verified data subject requests within 30 calendar days. We may ask you to verify your identity before processing any request to protect against unauthorised access to your personal data.

11. Cookies and Tracking Technologies

JILIY uses cookies and similar tracking technologies to operate the Platform, improve your experience, and understand how players use the site. Here is a breakdown of the types of cookies we use:

• Essential cookies: Required for basic Platform functionality — session management, login state, and security tokens. These cannot be disabled without breaking the Platform.
• Analytics cookies: Collect anonymous data about how visitors navigate the Platform, which pages are most popular, and where users encounter issues. This data is used to improve the Platform and is never linked to your personal identity.
• Preference cookies: Remember your settings and preferences — language, game display options, and responsible gaming tool states — so you don't have to re-enter them each session.
• Marketing cookies: Track whether you came to JILIY through a referral link or affiliate partner, and help us understand which promotional campaigns are effective. These are only placed with your consent.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will affect Platform functionality. To opt out of marketing cookies specifically, use the cookie preference centre accessible from the Platform's footer.

12. Protection of Minors

JILIY is an online gaming platform intended strictly for adults aged 21 and over in the Philippines. We do not knowingly collect personal information from anyone under the age of 21.

If JILIY discovers or is notified that a person under 21 has registered an account or provided personal information, we will immediately suspend the account, delete the associated personal data, and void any transactions made. Winnings generated by an account belonging to a minor will not be paid out.

If you believe a minor has created a JILIY account, please contact us immediately at support@jiliy.best so we can act without delay.

13. Cross-Border Data Transfers

Some of JILIY's third-party service providers — including cloud hosting infrastructure, fraud prevention tools, and identity verification services — may process data in data centres located outside the Philippines. Where this occurs, JILIY ensures that adequate safeguards are in place to protect your personal information to a standard equivalent to, or higher than, that required under the Data Privacy Act of 2012.

Safeguards used for cross-border transfers include: contractual clauses that bind the recipient to NPC-equivalent data protection standards; transfers only to jurisdictions with recognised adequate data protection frameworks; and data processing agreements reviewed by JILIY's Data Protection Officer.

You can request information about the specific safeguards in place for any cross-border transfer involving your personal data by contacting our Data Protection Officer at the address in Section 15.

14. Updates to This Privacy Policy

JILIY reviews and updates this Privacy Policy periodically to reflect changes in our practices, legal obligations, or Platform features. When material changes are made, we will notify registered players via the email address on file at least 14 days before the changes take effect.

The "Last Updated" date at the top of this page reflects the most recent revision. We encourage you to review this policy periodically. Continued use of the Platform after the effective date of any update constitutes acceptance of the revised policy. If you disagree with the updated policy, you may close your account before the changes take effect.

15. Contact Us & Data Protection Officer

JILIY has appointed a Data Protection Officer (DPO) in compliance with the Data Privacy Act of 2012 and NPC Circular No. 2016-02. If you have any questions, concerns, or requests related to this Privacy Policy or the handling of your personal data, you can reach our DPO directly:

• Data Protection Officer: JILIY Privacy Office
• Email: privacy@jiliy.best
• General Support: support@jiliy.best
• Live Chat: Available 24/7 via the Platform (log in to access)
• Response Time: Within 15 business days for formal data subject requests; within 24 hours for general privacy queries

If you believe your data privacy rights have been violated and JILIY has not adequately addressed your concern, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of the Philippines. Any disputes arising from this policy shall be subject to the jurisdiction of Philippine courts or relevant regulatory authorities.