jilli Privacy Policy

Introduction

jilli ("we," "us," "our," or "the Platform") operates the online casino platform accessible at jilli.cc. We understand that your personal information is important to you, and we take our obligations as a data controller seriously. This Privacy Policy sets out in clear terms what personal data jilli collects from you, why we collect it, how we use it, who we may share it with, and what rights you have over your own data.

This Privacy Policy applies to all personal data collected through the jilli website, mobile browser interface, customer support channels, and any other touchpoint through which you interact with jilli. It applies to all registered players, prospective players, and visitors to jilli.cc.

By registering a jilli account or continuing to use the jilli platform, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read together with jilli's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, jilli is the data controller responsible for the personal information collected through jilli.cc. As data controller, jilli determines the purposes and means by which your personal data is processed.

jilli has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws and for handling data subject requests and complaints. You may contact jilli's DPO through the contact details provided in Section 15 of this Policy.

Where jilli engages third-party service providers to process personal data on its behalf, those providers act as data processors and are bound by contractual obligations to process your data only in accordance with jilli's instructions and applicable law.

Data We Collect

jilli collects personal data that is necessary to provide you with a safe, compliant, and functional online casino experience. The categories of personal data we collect include:

jilli does not collect sensitive personal information (as defined under RA 10173) unless strictly required for identity verification or regulatory compliance purposes, and only with your explicit consent where required by law.

How We Collect Your Data

jilli collects personal data through the following means:

• Direct collection: Information you provide when registering your jilli account, completing identity verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access jilli.cc, including through cookies, session logs, and server-side analytics. See Section 8 for details on cookies.
• Third-party sources: Identity verification data from document verification service providers; fraud signals from payment processors; and, where applicable, information from regulatory databases used for anti-money laundering (AML) screening purposes.
• Payment providers: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other approved Philippine payment channels used in connection with your jilli account.

You are not obligated to provide all requested personal data, but failure to provide information that is required for regulatory compliance — such as identity verification documents — may prevent jilli from activating your account or processing withdrawal requests.

How We Use Your Data

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

• Account management: Creating and maintaining your jilli player account, verifying your identity and age, and managing your account settings and preferences.
• Service delivery: Processing deposits and withdrawals, recording game activity, delivering bonuses and promotions, and providing customer support.
• Legal and regulatory compliance: Meeting our obligations under Philippine gaming regulations, anti-money laundering laws, and the Data Privacy Act of 2012, including filing required reports with relevant authorities.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, unauthorized account access, multi-accounting, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible gaming: Monitoring gaming patterns to identify potentially problematic behavior, administering deposit limits and self-exclusion requests, and delivering responsible gaming notifications.
• Platform improvement: Analyzing usage data to improve the performance, design, and content of jilli.cc and to develop new features and game offerings.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may withdraw this consent at any time by contacting jilli support.
• Dispute resolution: Maintaining records of transactions and communications necessary to investigate and resolve player disputes and complaints.

jilli will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you — that is, to operate your jilli account, process transactions, and deliver the services described in our Terms & Conditions.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including gaming regulations, anti-money laundering requirements, and tax reporting obligations.
• Legitimate interests: Processing carried out for jilli's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your data privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and for the processing of sensitive personal information where required by law.

Where jilli relies on consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Data Sharing & Disclosure

jilli does not sell your personal data to third parties. 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:

• Game providers: Third-party game studios and live dealer platform operators whose games are available on jilli. These providers receive only the technical data necessary to deliver game sessions and record outcomes.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other approved payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and document verification services used to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention services: Providers of fraud detection, risk scoring, and AML screening tools used to protect the integrity of the jilli platform.
• Regulatory and law enforcement authorities: Philippine government agencies, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement bodies, where disclosure is required by law or a valid legal order.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by jilli in connection with its business operations, subject to professional confidentiality obligations.

Cookies & Tracking Technologies

jilli uses cookies and similar tracking technologies to operate and improve the jilli.cc platform. Cookies are small text files stored on your device when you visit a website. They help us recognize your browser, maintain your session, and understand how you use the Platform.

The following categories of cookies are used on jilli.cc:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management, login authentication, and security functions. These cookies cannot be disabled without affecting core Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use jilli.cc, including pages visited, session duration, and navigation paths. This data helps us improve the Platform.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may impair your ability to log in to or use the jilli platform. jilli does not use third-party advertising or behavioral tracking cookies.

Data Retention

jilli retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

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 following account closure, in accordance with applicable Philippine AML and gaming record-keeping requirements.
• Transaction and game records: Retained for a minimum of five (5) years from the date of each transaction or game session, as required by applicable regulations.
• Support communications: Retained for three (3) years from the date of the last communication, or longer if the communication relates to an unresolved dispute or regulatory matter.
• Technical and usage data: Retained for up to twelve (12) months from collection, after which it is aggregated or anonymized for analytical purposes.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given.

When personal data is no longer required for any lawful purpose, jilli will securely delete or anonymize it in accordance with our internal data disposal procedures.

Data Security

jilli implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption in transit: All data transmitted between your device and jilli.cc is encrypted using 256-bit SSL/TLS technology.
• Encryption at rest: Sensitive personal data stored in jilli's databases is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to personal data is restricted to jilli personnel and authorized third-party processors who have a legitimate need to access it. All access is logged and audited.
• Two-factor authentication: jilli uses OTP-based authentication for player logins and for sensitive account actions such as withdrawal requests.
• Vulnerability management: jilli conducts regular security assessments and penetration testing of its platform infrastructure to identify and remediate security vulnerabilities.
• Incident response: jilli maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, jilli will notify the National Privacy Commission and affected players in accordance with the requirements of RA 10173.

Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jilli. You may exercise any of these rights by contacting jilli's Data Protection Officer using the details in Section 15.

jilli will respond to all data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case jilli will notify you of the extension and the reasons for it.

Children's Privacy

The jilli platform is strictly intended for adults aged 21 years and above. jilli does not knowingly collect personal data from persons under the age of 21. Registration by minors is prohibited under both jilli's Terms & Conditions and applicable Philippine gaming regulations.

If jilli becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to suspend the associated account, delete the personal data in question, and, where required, report the matter to the appropriate regulatory authority.

If you are a parent or guardian and believe that your child has registered on jilli or provided personal data to jilli without your knowledge, please contact our Data Protection Officer immediately using the contact details in Section 15.

Cross-Border Data Transfers

Some of jilli's third-party service providers — including game platform operators, cloud infrastructure providers, and fraud prevention services — may be located outside the Philippines. Where personal data is transferred to recipients in other countries, jilli ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of the Data Privacy Act of 2012.

Such safeguards may include:

• Contractual clauses that impose data protection obligations on the recipient equivalent to those applicable under Philippine law;
• Transfers to countries that the National Privacy Commission has recognized as providing an adequate level of data protection;
• Other legally recognized transfer mechanisms as permitted under RA 10173 and its Implementing Rules and Regulations.

You may request further information about the specific safeguards applicable to cross-border transfers of your personal data by contacting jilli's Data Protection Officer.

Policy Updates

jilli reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The effective date of the current version is displayed at the top of this page.

When material changes are made to this Privacy Policy, jilli will notify registered players by posting a prominent notice on the jilli.cc platform and, where practicable, by sending a notification to your registered contact details. We encourage you to review this Privacy Policy periodically to stay informed of how jilli handles your personal data.

Your continued use of the jilli platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with any changes, you should stop using the Platform and may close your account in accordance with the Terms & Conditions.

Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data privacy rights, or have a complaint about how jilli has handled your personal data, please contact jilli's Data Protection Officer through the following channels:

• Email: [email protected] — for all data privacy inquiries, data subject access requests, and formal privacy complaints.
• Live Chat: Available 24/7 on the jilli platform for general privacy questions and to initiate a data subject request.

jilli will acknowledge receipt of your privacy inquiry or request within five (5) business days and will provide a substantive response within thirty (30) calendar days, subject to any extensions permitted under applicable law.

If you are not satisfied with jilli's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information about filing a complaint with the NPC is available through official Philippine government channels.