jili52 Privacy Policy

Effective Date: January 1, 2024
Last Updated: January 1, 2024

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by jili52 through our website (jili52.cam), mobile applications, customer support channels, and any other services we provide (collectively, the "Services"). This policy covers personal data of players, prospective players, website visitors, and individuals who interact with jili52 in any capacity. jili52 operates in compliance with the Republic of the Philippines Data Privacy Act of 2012 (RA 10173), its implementing rules and regulations, and relevant guidance issued by the National Privacy Commission (NPC). Where applicable, we also adhere to international data protection standards including the General Data Protection Regulation (GDPR) for players located in jurisdictions covered by such laws.

2. Data Controller Information

jili52, operating under Philippine Amusement and Gaming Corporation (PAGCOR) license, is the data controller responsible for your personal information. As data controller, we determine the purposes and means of processing your personal data. For questions regarding data protection, privacy rights, or this Privacy Policy, you may contact our Data Protection Officer (DPO) using the contact information provided in Section 16 below.

3. Personal Data We Collect

jili52 collects various categories of personal data necessary to provide our gaming services, comply with legal obligations, and improve user experience. The personal information we collect includes:

3.1 Identity and Contact Information

• Full legal name (first name, middle name, surname)
• Date of birth
• Gender
• Nationality and citizenship status
• Government-issued identification numbers (e.g., passport number, driver's license number, PhilSys ID number)
• Residential address (street address, city, province, postal code)
• Email address
• Telephone and mobile phone numbers
• Photographic identification documents submitted during KYC verification

3.2 Financial and Transaction Data

• Bank account details (account number, bank name, branch)
• E-wallet account information (GCash number, Maya account, Coins.ph details)
• Payment card details (last four digits, expiration date, cardholder name)
• Cryptocurrency wallet addresses (for USDT transactions)
• Transaction history (deposits, withdrawals, transfer amounts, dates, times)
• Payment method verification documents (bank statements, screenshots)
• Source of funds documentation (where required for anti-money laundering compliance)

3.3 Gaming and Account Activity Data

• Username and account credentials (encrypted passwords)
• Gaming preferences and history (games played, bet amounts, wins and losses)
• Bonus claims and wagering progress
• Account balance and wallet activity
• Customer support interactions (chat logs, email correspondence, support tickets)
• Responsible gaming settings (deposit limits, time limits, self-exclusion requests)
• VIP tier status and loyalty program participation

3.4 Technical and Usage Data

• IP address and geolocation data
• Device information (device type, operating system, browser type and version)
• Unique device identifiers and mobile advertising IDs
• Login timestamps and session duration
• Website navigation patterns and clickstream data
• Cookies and similar tracking technologies data
• Referral source (how you found jili52)

3.5 Marketing and Communication Preferences

• Marketing consent status (email, SMS, push notifications)
• Communication preferences and language settings
• Survey responses and feedback
• Social media interactions (if you engage with our social media pages)

4. How We Collect Your Data

jili52 collects personal data through the following methods:

4.1 Direct Collection

You provide information directly when you register an account, complete your profile, make deposits or withdrawals, upload verification documents, contact customer support, participate in promotions, or adjust your account settings and preferences. All information you voluntarily submit through forms, upload interfaces, or communication channels is collected and stored in our secure databases.

4.2 Automated Collection

Technical data is automatically collected through cookies, web beacons, server logs, and similar tracking technologies when you access and use jili52 services. This includes IP addresses, device identifiers, browser information, and behavioral data such as pages visited, games played, and navigation patterns. These technologies help us understand user behavior, improve platform performance, detect fraud, and deliver personalized experiences.

4.3 Third-Party Sources

We may receive personal data from third parties including payment processors (banks, e-wallet providers, payment gateways) who provide transaction verification, identity verification service providers who assist with KYC compliance, fraud prevention agencies, and marketing partners (with your consent). We also collect publicly available information from government databases and registries when required for regulatory compliance.

5. Legal Basis for Data Processing

jili52 processes your personal data based on the following legal grounds as required under Philippine and international data protection law:

5.1 Contractual Necessity

Processing is necessary to provide our gaming services, manage your account, process deposits and withdrawals, deliver bonuses and promotions, and fulfill our contractual obligations under the Terms & Conditions you agreed to upon registration. Without this data, we cannot provide the services you requested.

5.2 Legal Obligation

We are required by law to collect and process certain personal data to comply with PAGCOR regulations, anti-money laundering (AML) laws, counter-terrorism financing (CTF) requirements, tax reporting obligations, age verification mandates, and responsible gaming regulations. We also process data to respond to lawful requests from law enforcement, regulatory authorities, and courts.

5.3 Legitimate Interests

jili52 processes personal data for legitimate business interests including fraud prevention and security, risk management, customer service improvement, platform optimization, business analytics, marketing research (subject to your rights and preferences), and defense of legal claims. We balance these interests against your privacy rights and do not process data in ways that would be unexpected or harmful to you.

5.4 Consent

Where required by law, we obtain your explicit consent before processing personal data for marketing communications, non-essential cookies and tracking, sharing data with specific third parties for promotional purposes, and processing sensitive personal information beyond what is legally required. You may withdraw consent at any time through your account settings or by contacting customer support.

6. How We Use Your Personal Data

jili52 uses your personal information for the following purposes:

6.1 Account Management and Service Delivery

• Create, maintain, and manage your gaming account
• Authenticate your identity and verify account ownership
• Process deposits, withdrawals, and other financial transactions
• Enable gameplay, calculate winnings, and update account balances
• Administer bonuses, promotions, loyalty programs, and VIP benefits
• Provide customer support and respond to inquiries
• Communicate important account notifications and service updates

6.2 Legal and Regulatory Compliance

• Verify your age and ensure compliance with minimum gambling age requirements (21+)
• Conduct Know Your Customer (KYC) checks and ongoing customer due diligence
• Screen for politically exposed persons (PEPs) and sanctions lists
• Monitor transactions for suspicious activity under AML/CTF obligations
• Report to PAGCOR and other regulatory authorities as required
• Maintain records as mandated by gaming regulations and tax laws
• Respond to lawful requests from law enforcement and judicial authorities

6.3 Security and Fraud Prevention

• Detect, prevent, and investigate fraudulent activity, money laundering, and payment fraud
• Identify duplicate accounts and enforce single-account policies
• Monitor for collusion, bonus abuse, and other prohibited activities
• Protect against unauthorized access, hacking, and cyberattacks
• Verify payment method ownership and prevent chargebacks
• Investigate disputes, complaints, and suspected Terms violations

6.4 Responsible Gaming

• Implement and enforce deposit limits, loss limits, and time restrictions
• Process self-exclusion and cool-off period requests
• Monitor for problematic gambling behavior patterns
• Provide reality checks and responsible gaming notifications
• Enforce age restrictions and prevent underage gambling

6.5 Platform Improvement and Analytics

• Analyze user behavior to improve website design and user experience
• Optimize game offerings based on player preferences and performance data
• Conduct business analytics and market research
• Test new features and conduct A/B testing
• Generate aggregated, anonymized statistics for business intelligence

6.6 Marketing and Communications

• Send promotional offers, bonuses, and special event notifications (with consent)
• Deliver personalized gaming recommendations and targeted promotions
• Conduct surveys and request feedback on our services
• Administer referral programs and affiliate marketing

7. Data Sharing and Third-Party Disclosure

jili52 does not sell your personal data to third parties. We share your information only with trusted partners and service providers who assist in delivering our services, and only to the extent necessary for specified purposes. Data sharing occurs in the following circumstances:

7.1 Service Providers and Business Partners

We engage third-party service providers to perform functions on our behalf including payment processors (banks, e-wallet providers, payment gateways), identity verification and KYC service providers, cloud hosting and data storage providers, customer support platforms, email and SMS communication services, marketing and analytics platforms, fraud prevention and security vendors, and game providers (Evolution Gaming, Pragmatic Play, Ezugi, etc.). These providers are contractually obligated to protect your data, use it only for authorized purposes, and comply with applicable data protection laws.

7.2 Regulatory Authorities and Law Enforcement

We disclose personal data to PAGCOR and other government regulators as required by gaming license conditions, to law enforcement agencies in response to lawful requests and court orders, to tax authorities for reporting purposes, and to the National Privacy Commission upon request for data protection compliance audits. Such disclosures are limited to information necessary to fulfill legal obligations.

7.3 Legal Proceedings and Rights Protection

Personal data may be disclosed to legal advisors, courts, and tribunals in connection with legal proceedings, to protect jili52's legal rights and interests, to enforce our Terms & Conditions, to defend against claims and lawsuits, and to investigate and prosecute fraud, abuse, or violations of platform rules.

7.4 Business Transfers

In the event of a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your personal data may be transferred to the acquiring entity or successor organization. You will be notified of any such transfer, and the new entity will be required to honor this Privacy Policy or provide you with notice of any changes.

7.5 With Your Consent

We may share your personal data with other third parties where you have provided explicit consent for such sharing, including social media platforms for promotional purposes, marketing partners for co-branded campaigns, and third-party loyalty programs you choose to participate in.

8. International Data Transfers

jili52 stores and processes data primarily within the Philippines. However, some of our service providers, particularly cloud hosting services, payment processors, and game providers, may operate servers or facilities outside the Philippines. When personal data is transferred internationally, we ensure adequate protection through contractual safeguards including standard contractual clauses approved by data protection authorities, adequacy decisions recognizing equivalent data protection standards in the destination country, and binding corporate rules for intra-group transfers. We review the security and data protection practices of all international service providers before engaging them and require contractual commitments to comply with Philippine data protection standards.

9. Data Security and Protection Measures

jili52 employs industry-standard technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. Our security measures include:

9.1 Technical Security

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• End-to-end encryption for sensitive data including passwords and financial information
• Secure, hardened servers protected by firewalls and intrusion detection systems
• Regular security audits, vulnerability assessments, and penetration testing
• Multi-factor authentication for administrative access to systems
• Secure backup and disaster recovery procedures

9.2 Organizational Security

• Role-based access controls limiting data access to authorized personnel only
• Employee training on data protection, confidentiality, and security best practices
• Confidentiality agreements and data processing agreements with all staff and contractors
• Incident response and data breach notification procedures
• Regular review and update of security policies and procedures

While we implement robust security measures, no system is entirely invulnerable. You are responsible for maintaining the confidentiality of your account credentials and for any activity occurring under your account. Immediately notify us if you suspect unauthorized access.

10. Data Retention and Deletion

jili52 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and resolve disputes. Retention periods vary depending on data type and legal requirements:

10.1 Active Account Data

Personal information associated with active accounts is retained for the duration of your account's active status and for a reasonable period thereafter to handle any pending transactions, disputes, or regulatory inquiries. Account information, transaction history, and gaming records are retained as long as your account remains open.

10.2 Closed Account Data

Following account closure, personal data is retained for a minimum of five (5) years as required by PAGCOR regulations and Philippine AML/CTF laws. After this mandatory retention period, data is either anonymized for statistical purposes or securely deleted unless longer retention is justified by ongoing legal proceedings, unresolved disputes, or other legitimate reasons.

10.3 Marketing Data

Marketing consent records and communication history are retained until you withdraw consent or for three (3) years from the last interaction, whichever is longer, to demonstrate compliance with marketing regulations.

10.4 Financial Records

Transaction records, payment details, and financial documentation are retained for seven (7) years as required by Philippine tax law and financial regulations.

10.5 Security and Fraud Data

Data collected for security, fraud prevention, and investigation purposes may be retained longer where necessary to protect jili52's interests, assist law enforcement investigations, or defend against legal claims.

Upon expiration of retention periods, personal data is securely deleted or anonymized in accordance with data protection best practices, ensuring data cannot be recovered or reconstructed.

11. Your Privacy Rights

Under the Philippine Data Privacy Act and other applicable laws, you have the following rights regarding your personal data:

11.1 Right to Access

You have the right to obtain confirmation of whether jili52 is processing your personal data and to access a copy of the personal data we hold about you. You can view much of your account information directly in your jili52 account dashboard. For comprehensive data access requests, contact our Data Protection Officer.

11.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You can update your contact information, preferences, and certain profile details directly in your account settings. For changes to verified identity information (name, date of birth), contact customer support with supporting documentation.

11.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data in certain circumstances, including when data is no longer necessary for the purposes collected, you withdraw consent (where consent was the basis for processing), you object to processing and there are no overriding legitimate grounds, or data has been unlawfully processed. This right is subject to legal exceptions, including mandatory retention periods required by PAGCOR regulations, AML/CTF laws, and tax regulations. We will inform you if deletion is not possible and explain the reason.

11.4 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes, including profiling for marketing. You can opt out of marketing communications at any time through your account settings or by clicking unsubscribe links in promotional emails. You may also object to processing based on legitimate interests by contacting our DPO, who will evaluate your request against jili52's interests.

11.5 Right to Restrict Processing

You may request restriction of processing in certain situations, such as when you contest the accuracy of data (restriction applies during verification), you object to processing (restriction applies pending determination of legitimate grounds), processing is unlawful but you prefer restriction over deletion, or data is no longer needed by jili52 but required by you for legal claims.

11.6 Right to Data Portability

Where technically feasible, you have the right to receive personal data you provided to jili52 in a structured, commonly used, machine-readable format (such as CSV or JSON) and to transmit that data to another service provider. This right applies to data processed based on consent or contract and processed by automated means.

11.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal. Note that withdrawing consent may affect our ability to provide certain services or benefits.

11.8 Right to Lodge a Complaint

If you believe jili52 has violated your data protection rights, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). Contact details for the NPC are available at privacy.gov.ph. You may also contact our Data Protection Officer to resolve concerns directly.

To exercise any of these rights, submit a request through your account settings, contact customer support, or email our Data Protection Officer at the address provided in Section 16. We will respond to your request within fifteen (15) days or as otherwise required by law. Identity verification may be required before processing your request to protect against unauthorized access.

12. Cookies and Tracking Technologies

jili52 uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience, analyze platform usage, deliver personalized content, and support security and fraud prevention. Cookies are small text files stored on your device that allow websites to remember your preferences and recognize repeat visits.

12.1 Types of Cookies We Use

Essential Cookies: Required for platform functionality, authentication, security, and basic operations. These cannot be disabled without affecting core services.
Performance and Analytics Cookies: Collect aggregated data on how visitors use our site, helping us improve functionality and user experience.
Functional Cookies: Remember your preferences (language, region, game settings) to provide enhanced, personalized features.
Marketing and Advertising Cookies: Used to deliver relevant promotional content and measure campaign effectiveness. These require your consent.

12.2 Managing Cookies

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, though this may affect platform functionality. You can also adjust cookie preferences through our cookie consent banner displayed upon first visit. Disabling essential cookies may prevent you from using certain services.

13. Marketing and Communications

jili52 may send promotional communications including bonus offers, special events, new game announcements, and VIP program updates via email, SMS, push notifications, and in-platform messages. You control your communication preferences and can opt out at any time without affecting your ability to use gaming services.

To unsubscribe from marketing emails, click the unsubscribe link in any promotional email, adjust your communication preferences in account settings, or contact customer support. To opt out of SMS marketing, reply STOP to any promotional SMS or adjust settings in your account. Note that transactional and service-related communications (deposit confirmations, withdrawal notifications, security alerts, account statements) are essential to account management and cannot be opted out of without closing your account.

14. Children's Privacy

jili52 services are strictly restricted to individuals aged twenty-one (21) years or older. We do not knowingly collect, process, or retain personal data from minors. Our registration process includes age verification checks, and we employ monitoring systems to detect potential underage access. If we discover that a minor has created an account or provided personal information, we will immediately terminate the account, delete all associated personal data, and refund any deposited funds (where legally permissible) to the payment source. Parents and guardians are encouraged to monitor their children's internet usage and use parental control software to restrict access to gambling sites. If you believe a minor has accessed jili52 services, contact us immediately at the details provided in Section 16.

15. Changes to This Privacy Policy

jili52 reserves the right to update, modify, or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, regulatory guidance, or business operations. Material changes will be communicated via email to the address registered on your account, prominent notice on our website, or in-platform notification upon login. The "Last Updated" date at the top of this policy indicates the most recent revision. Your continued use of jili52 services following notification of changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your personal information. If you do not agree with any changes, you may close your account by contacting customer support.

16. Contact and Data Protection Officer

For questions, concerns, or requests regarding this Privacy Policy, your personal data, or your privacy rights, please contact jili52's Data Protection Officer (DPO):

When contacting us regarding privacy matters, please include your full name, registered email address, account username (if applicable), and a clear description of your request or concern. For data access, rectification, or deletion requests, we may require identity verification to protect against unauthorized access to your personal information.