jlili1 Privacy Policy

1. Data Controller and Contact Information

jlili1 (referred to in this policy as "jlili1," "we," "us," or "our") is the data controller responsible for the personal data you provide when registering an account and using the jlili1 platform. As a PAGCOR-regulated online gaming operator serving Filipino players, jlili1 is committed to processing personal data in strict accordance with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable directives issued by the National Privacy Commission (NPC).

If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, our designated Data Protection Officer (DPO) can be reached through the following contact:

• Email: [email protected] (displayed as plain text – not a clickable link)
• Live Chat: Available 24/7 from the jlili1 platform
• Response Time: Within 5 business days for data privacy inquiries

2. Personal Data We Collect

jlili1 collects personal data through several channels, including account registration, identity verification processes, gameplay activity, payment transactions, customer support interactions, and your use of the jlili1 website and platform. The categories of personal data we may collect include:

2.1 Identity and Registration Data

• Full legal name as it appears on a government-issued identification document
• Date of birth (used for mandatory 21+ age verification)
• Gender
• Philippine residential address (including barangay, city or municipality, and province)
• Nationality
• Account username and encrypted password

2.2 Contact Information

• Philippine mobile number (used for OTP verification and account communications)
• Email address where provided

2.3 Identity Verification (KYC) Documents

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, UMID, SSS ID, PhilSys National ID, Voter's ID)
• Proof of address documentation where required
• Selfie or liveness verification images collected during the KYC process
• Source of funds documentation for high-volume account activity in compliance with PAGCOR and AMLA requirements

2.4 Financial and Transaction Data

• Deposit and withdrawal transaction records including amounts, dates, and payment reference numbers
• Payment method details (e.g., GCash account reference, BPI or BDO account number, Maya account reference) – jlili1 does not store full credit or debit card numbers
• Account balance history and gaming transaction records
• Bonus and promotion participation records

2.5 Gaming Activity Data

• Game session records including games played, wagers placed, wins, losses, and session duration
• Sports betting selections, stake amounts, and settlement records
• Responsible gaming tool settings including deposit limits, loss limits, and self-exclusion status

2.6 Technical and Device Data

• IP address and approximate geolocation (used to verify Philippine residency and PAGCOR jurisdiction compliance)
• Device type, operating system, and browser type
• Session timestamps and login history
• Cookies and similar tracking technologies (see Section 9 for details)

2.7 Communications Data

• Records of customer support interactions including live chat transcripts and email correspondence
• Feedback, complaints, and dispute records
• Marketing communication preferences and consent records

3. Legal Basis and Purpose of Data Processing

jlili1 processes your personal data on the following legal bases and for the following specific purposes:

4. How We Share Your Personal Data

jlili1 does not sell, rent, or trade your personal data to third parties for commercial marketing purposes. We share your personal data only in the following limited and necessary circumstances:

4.1 Service Providers and Data Processors

jlili1 engages trusted third-party service providers who process personal data on our behalf and under our instructions. These include payment processing companies (such as GCash, Maya, and banking partners), identity verification and KYC service providers, cloud hosting and infrastructure providers, customer support platform operators, and analytics service providers. All third-party data processors engaged by jlili1 are contractually required to maintain data security standards and to process personal data only for the specified purposes.

4.2 Regulatory and Law Enforcement Authorities

jlili1 is required by Philippine law to share personal data with relevant regulatory authorities in certain circumstances. This includes mandatory reporting to PAGCOR as part of our licensing obligations, reports to the Anti-Money Laundering Council (AMLC) as required under the Anti-Money Laundering Act (Republic Act No. 9160 as amended), responses to valid orders, subpoenas, or warrants from Philippine courts or law enforcement agencies, and compliance with lawful requests from the National Privacy Commission (NPC).

4.3 Game Content Providers

Where jlili1 offers games developed by third-party game studios, limited technical data (such as player session tokens and bet amounts) may be transmitted to the game provider solely for the purpose of delivering the game experience. Third-party game providers are not permitted to use this data for any other purpose and are bound by confidentiality obligations.

4.4 Business Transfers

In the event that jlili1 undergoes a merger, acquisition, restructuring, or sale of assets, personal data held by jlili1 may be transferred to the successor entity as part of that transaction. In such cases, jlili1 will notify affected players and ensure that the successor entity continues to honor the commitments made in this Privacy Policy.

5. Data Retention

jlili1 retains personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory retention obligations, and to resolve any disputes or enforce our agreements. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and Anti-Money Laundering regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction in compliance with AMLA requirements.
• Customer support records: Retained for three (3) years from the date of the final interaction.
• Marketing consent records: Retained for the duration of the marketing relationship and for two (2) years thereafter as evidence of consent.
• Technical and device logs: Retained for up to twelve (12) months for security and fraud detection purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with National Privacy Commission guidelines.

6. Data Security

jlili1 takes the security of your personal data seriously and implements a comprehensive range of technical and organizational security measures designed to protect your information against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jlili1 platform
• Encryption at rest for sensitive personal data stored in our database systems
• Multi-factor authentication requirements for account access and sensitive account changes
• Role-based access controls ensuring that employee access to personal data is limited to what is strictly necessary for their role
• Regular security audits and penetration testing conducted by independent security specialists
• Comprehensive employee training on data protection obligations and security procedures
• Incident response procedures compliant with NPC breach notification requirements

7. International Data Transfers

Where jlili1 engages service providers located outside the Philippines (for example, cloud infrastructure providers or international game studios), your personal data may be transferred to and processed in countries other than the Philippines. In all such cases, jlili1 ensures that adequate safeguards are in place to protect your personal data in accordance with the requirements of the Philippine Data Privacy Act, including contractual clauses that impose data protection obligations on recipient parties equivalent to those required under Philippine law.

8. Your Rights Under the Philippine Data Privacy Act

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 jlili1. You may exercise any of these rights by contacting our Data Protection Officer via live chat or at [email protected]:

8.1 Right to Be Informed

You have the right to be informed about what personal data jlili1 collects about you, the purpose for which it is collected, how it is processed, and with whom it is shared. This Privacy Policy is jlili1's primary means of fulfilling this obligation.

8.2 Right of Access

You have the right to request a copy of the personal data that jlili1 holds about you. Upon receiving a valid access request, jlili1 will provide you with a summary of your personal data within fifteen (15) business days, subject to verification of your identity.

8.3 Right to Rectification

If any personal data jlili1 holds about you is inaccurate or incomplete, you have the right to request that we correct or update it. Many basic account details can be updated directly through your jlili1 account settings. For changes to identity-critical information (such as your registered name or date of birth), you will be required to submit supporting documentation.

8.4 Right to Erasure or Blocking

You have the right to request the deletion or blocking of personal data that is no longer necessary for the purpose for which it was collected, where your consent has been withdrawn, or where the data was processed unlawfully. Note that this right is subject to jlili1's legal obligations to retain certain data under PAGCOR licensing conditions and Anti-Money Laundering regulations – data subject to statutory retention requirements cannot be deleted until the applicable retention period expires.

8.5 Right to Data Portability

Where technically feasible and where processing is based on your consent or a contract, you have the right to receive personal data that you have provided to jlili1 in a structured, commonly used, and machine-readable format.

8.6 Right to Object

You have the right to object to the processing of your personal data on the basis of legitimate interests, including direct marketing. If you object to receiving marketing communications from jlili1, you may withdraw your consent at any time by updating your communication preferences in your account settings or by contacting our support team.

8.7 Right to Lodge a Complaint

If you believe jlili1 has handled your personal data in a manner that violates the Philippine Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC). We encourage you to contact us directly first so we have the opportunity to address your concern, but we fully support your right to escalate to the NPC if you remain unsatisfied with our response.

9. Cookies and Tracking Technologies

jlili1 uses cookies and similar tracking technologies on the jlili1 website and platform to enhance your experience, maintain session security, and analyze platform usage. The types of cookies used by jlili1 include:

• Strictly necessary cookies: Required for the platform to function correctly, including session management, login state, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game display options, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymized data about how players use the jlili1 platform to help us improve the user experience. No personally identifiable information is shared with analytics providers.
• Security cookies: Used for fraud detection and to identify unusual account activity patterns that may indicate unauthorized access.

You may configure your browser settings to block or delete cookies. However, disabling strictly necessary or security cookies may impair the functionality of the jlili1 platform and your ability to log in or use certain features.

10. Marketing Communications

jlili1 may send you promotional messages about bonuses, new games, platform updates, and special offers via SMS or push notification to your registered Philippine mobile number, subject to your consent. You will be given the opportunity to opt in to marketing communications during the account registration process. You may withdraw your marketing consent at any time by updating your communication preferences in your jlili1 account settings or by contacting customer support. Withdrawing marketing consent does not affect the lawfulness of communications sent prior to withdrawal and will not affect jlili1's ability to send you transactional communications (such as deposit confirmations, withdrawal notifications, and security alerts) which are necessary for account management purposes.

11. Children's Privacy

The jlili1 platform is strictly intended for adults aged 21 years or older as required by PAGCOR regulations. jlili1 does not knowingly collect personal data from individuals under the age of 21. If jlili1 becomes aware that personal data has been collected from a person under 21 years of age, that account will be immediately suspended, the personal data will be deleted, and any funds associated with the account will be handled in accordance with our underage account policy. If you are a parent or guardian and believe that a minor has registered a jlili1 account, please contact us immediately at [email protected].

12. Data Breach Notification

In the event of a personal data breach that is likely to result in a significant risk to the rights and freedoms of affected players, jlili1 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required by the Philippine Data Privacy Act. jlili1 will also notify affected players without undue delay where the breach is likely to result in a high risk to their personal rights and freedoms. Breach notifications to players will be sent via the mobile number or email address registered to their jlili1 account and will include a description of the breach, the categories of data affected, the likely consequences, and the steps jlili1 has taken or will take to address the breach.

13. Changes to This Privacy Policy

jlili1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Any material changes to this Privacy Policy will be communicated to players via a notification on the jlili1 platform or via SMS to your registered mobile number. The updated Privacy Policy will be posted on this page with a revised "Last Updated" date. Continued use of the jlili1 platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

14. Governing Law

This Privacy Policy is governed by the laws of the Republic of the Philippines, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable PAGCOR regulatory directives. Any disputes relating to data privacy matters shall be subject to the jurisdiction of the National Privacy Commission and, where appropriate, the courts of the Republic of the Philippines.