jilliby Privacy Policy

1. Introduction

jilliby ("jilliby," "we," "us," or "our") operates the online gaming platform accessible at https://jilliby.net and its associated mobile applications (collectively, the "Platform"). We are committed to protecting the privacy and personal data of every player who uses our Platform.

This Privacy Policy ("Policy") describes how jilliby collects, uses, stores, shares, and protects your personal data when you access or use the Platform. It also explains the rights available to you under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations ("DPA"), and how you can exercise those rights.

By registering an account on jilliby or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

2. Personal Data We Collect

jilliby collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify you are at least 21 years of age)
• Email address
• Mobile phone number
• Residential address (city, province, region)
• Username and encrypted password
• Nationality and country of residence

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID)
• Proof of address documents (e.g., utility bill, bank statement)
• Selfie or live photo for identity verification purposes

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash account number, Maya account, bank account name and number — stored in tokenized or masked form)
• Transaction amounts, dates, and reference numbers
• Account balance history

2.4 Gaming Activity Data

• Game session logs, including games played, wagers placed, and outcomes
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Unique device identifiers
• Log files, error reports, and crash data
• Cookie identifiers and session tokens

2.6 Communications Data

• Records of your communications with jilliby's customer support team, including live chat transcripts and email correspondence
• Survey responses and feedback submissions
• Marketing communication preferences

3. How We Collect Your Data

jilliby collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey.
• Automatically — through cookies, web beacons, and similar tracking technologies when you access and use the Platform. See Section 7 for more details on cookies.
• From third-party service providers — including identity verification providers, payment processors (GCash, Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), fraud detection services, and analytics providers, who may share data with us in connection with the services they provide to jilliby.
• From publicly available sources — such as public records or social media profiles, where permitted by applicable law and relevant to our compliance obligations.

4. How We Use Your Personal Data

jilliby uses the personal data we collect for the following purposes:

• Account creation and management — to register your account, verify your identity, and manage your player profile on the jilliby platform.
• Age verification — to confirm that you are at least 21 years of age, as required by Philippine law and PAGCOR guidelines.
• Service delivery — to provide you with access to jilliby's games, promotions, bonuses, and customer support services.
• Payment processing — to process your deposits and withdrawals through your chosen payment method.
• Legal and regulatory compliance — to comply with our obligations under the DPA, PAGCOR regulations, Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform.
• Responsible gaming — to monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, session limits, and self-exclusion.
• Platform improvement — to analyze usage patterns, troubleshoot technical issues, and improve the features and performance of the jilliby platform.
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Dispute resolution — to investigate and resolve disputes, complaints, and legal claims relating to your use of the Platform.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jilliby processes your personal data on the following legal bases:

• Consent — where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity — where processing is necessary to perform our contract with you (i.e., the Terms & Conditions), including account management, payment processing, and service delivery.
• Legal obligation — where processing is required to comply with applicable laws and regulations, including PAGCOR licensing requirements, AMLA obligations, and KYC/AML verification.
• Legitimate interests — where processing is necessary for jilliby's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.

6. Data Sharing & Disclosure

jilliby does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

6.1 Service Providers

We share data with trusted third-party service providers who assist us in operating the Platform, including identity verification providers, payment processors, cloud hosting providers, analytics platforms, customer support software providers, and fraud detection services. These providers are contractually bound to process your data only on jilliby's instructions and in accordance with applicable data protection laws.

6.2 Regulatory and Law Enforcement Authorities

jilliby may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jilliby's business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

6.4 With Your Consent

jilliby may share your personal data with other third parties where you have given your explicit consent to such sharing.

7. Cookies & Tracking Technologies

jilliby uses cookies and similar tracking technologies (such as web beacons and local storage) to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly necessary cookies — Required for the Platform to function correctly. These cookies enable core features such as session management, login authentication, and security. They cannot be disabled.
• Functional cookies — Used to remember your preferences, such as language settings and responsible gaming tool configurations, to provide a more personalized experience.
• Analytics cookies — Used to collect aggregated, anonymized data about how players use the Platform, helping us identify areas for improvement. We use this data internally and do not share it in identifiable form.
• Security cookies — Used to detect and prevent fraudulent activity, bot access, and unauthorized account access attempts.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of jilliby.

8. Data Retention

jilliby retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting obligations. The following general retention periods apply:

• Account and identity data — Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Transaction and financial data — Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC documents — Retained for a minimum of five (5) years after account closure or the end of the business relationship.
• Gaming activity logs — Retained for a minimum of two (2) years from the date of the gaming session.
• Customer support communications — Retained for two (2) years from the date of the last communication.
• Marketing preferences — Retained until you withdraw your consent or request deletion, subject to applicable legal retention requirements.

Upon expiry of the applicable retention period, jilliby will securely delete or anonymize your personal data in accordance with its data disposal procedures.

9. Data Security

jilliby implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and jilliby's servers;
• Encryption of sensitive data at rest, including payment method details and identity documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Intrusion detection and prevention systems;
• Multi-factor authentication for administrative access to systems containing personal data;
• Staff training on data protection and information security best practices.

While jilliby takes every reasonable precaution to protect your data, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jilliby will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jilliby:

• Right to be informed — You have the right to be informed about how your personal data is collected, used, and processed, as described in this Policy.
• Right of access — You have the right to request a copy of the personal data jilliby holds about you, along with information about how it is being processed.
• Right to rectification — You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure — You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jilliby's legal retention obligations.
• Right to object — You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on jilliby's legitimate interests.
• Right to data portability — You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to lodge a complaint — You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe jilliby has violated your data privacy rights.

11. Children's Privacy

The jilliby Platform is strictly intended for individuals who are at least 21 years of age. jilliby does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted during the registration process and as part of KYC procedures.

If jilliby becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please notify us immediately at [email protected].

12. Cross-Border Data Transfers

jilliby primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where jilliby uses cloud infrastructure or third-party service providers with operations in other jurisdictions.

Where personal data is transferred outside the Philippines, jilliby ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act, including contractual data protection clauses with the receiving party and verification that the receiving jurisdiction provides an adequate level of data protection.

13. Third-Party Links

The jilliby Platform may contain links to third-party websites or services for informational purposes. jilliby is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Policy applies solely to data collected by jilliby through the Platform.

14. Updates to This Privacy Policy

jilliby reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or Platform features. When material changes are made, we will notify registered players via email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this Policy. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how jilliby protects your data.

15. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or jilliby's data processing practices, please contact our Data Protection Officer (DPO):

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. Information about the NPC and how to file a complaint is available through official Philippine government channels.