jilliwin Privacy Policy

jilliwin is an online gaming and entertainment platform operating under applicable Philippine online gaming regulations. For the purposes of the Data Privacy Act of 2012, jilliwin acts as the Personal Information Controller ("PIC") in respect of the personal data it collects from users of the Platform.

As a Personal Information Controller, jilliwin is responsible for determining the purposes and means of processing your personal data. We are committed to processing your data lawfully, fairly, and transparently, in full compliance with Republic Act No. 10173 and its Implementing Rules and Regulations.

Our designated Data Protection Officer ("DPO") oversees all data privacy matters at jilliwin. You may contact our DPO directly at [email protected] for any privacy-related concerns, requests, or complaints.

jilliwin 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 (for age verification — you must be 21 years or older)
• Email address and mobile number
• Username and encrypted password
• Residential address (city, province, region)
• Nationality and country of residence

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID)
• Proof of address documents (e.g., utility bill, bank statement)
• Selfie or liveness check images submitted during KYC verification
• Payment method verification documents where required

2.3 Financial & Transaction Data

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

2.4 Gaming Activity Data

• Game session records, including games played, wager amounts, 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 information
• Session timestamps and login history
• Cookie identifiers and similar tracking technologies (see Section 6)

2.6 Communications Data

• Records of your communications with jilliwin support (live chat transcripts, email correspondence)
• Feedback, complaints, and dispute records
• Marketing preferences and communication opt-in/opt-out records

jilliwin uses the personal data we collect for the following specific purposes:

• Account Creation & Management: To register your jilliwin account, verify your identity, and maintain your account in good standing.
• Age Verification: To confirm that you are at least 21 years of age before allowing access to real-money gaming features, as required under Philippine law.
• KYC & Anti-Money Laundering Compliance: To fulfill our obligations under Philippine anti-money laundering laws, including the Anti-Money Laundering Act (AMLA) and its amendments. This includes verifying your identity and monitoring transactions for suspicious activity.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya / Maya, and Philippine bank transfers (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and to reconcile financial records.
• Platform Operation & Improvement: To deliver, maintain, and improve the jilliwin gaming platform, including game performance, user interface, and customer support services.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other prohibited conduct.
• Responsible Gaming: To administer responsible gaming tools such as deposit limits, loss limits, cooling-off periods, and self-exclusion, and to monitor for signs of problem gambling behavior.
• Customer Support: To respond to your inquiries, complaints, and support requests in a timely and effective manner.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent to receive such communications. You may withdraw consent at any time.
• Legal & Regulatory Compliance: To comply with applicable Philippine laws, regulations, and lawful requests from regulatory authorities including PAGCOR and the National Privacy Commission.

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

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

• Contractual Necessity: Processing is necessary to perform the contract between you and jilliwin — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, age verification requirements, and data retention obligations imposed by regulatory authorities.
• Legitimate Interests: Processing is necessary for jilliwin's legitimate interests in fraud prevention, platform security, and responsible gaming enforcement, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookies, jilliwin relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

jilliwin does not sell, rent, or trade 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:

• Payment Processors: GCash (Mynt), PayMaya / Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive the minimum data necessary to process your financial transactions.
• Identity Verification Providers: Third-party KYC and identity verification service providers who assist jilliwin in verifying your identity and age in compliance with Philippine regulations.
• Game Software Providers: Game developers and content providers whose games are hosted on the jilliwin platform may receive anonymized or pseudonymized session data for game performance and fairness auditing purposes.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or lawful order.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on jilliwin's behalf under strict data processing agreements.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

jilliwin uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting core Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming tool configurations, and display preferences to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how users interact with the Platform — such as pages visited, session duration, and navigation paths — to help jilliwin improve the user experience. Used only with your consent.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of jilliwin's marketing campaigns. Used only with your explicit consent.

You can manage your cookie preferences through your browser settings or through the cookie consent tool available on the jilliwin Platform. Please note that disabling certain cookies may affect the functionality of the Platform.

jilliwin retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account & Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the AMLA and its implementing regulations.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a specific regulatory obligation or ongoing investigation.
• Support Communications: Retained for three (3) years from the date of the communication, unless the matter relates to an ongoing dispute or legal proceeding.
• Marketing Preferences: Retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations.
• Technical & Device Data: Retained for up to twelve (12) months for security and fraud prevention purposes, after which it is anonymized or deleted.

When personal data is no longer required, jilliwin will securely delete or anonymize it in accordance with industry best practices and NPC guidelines.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jilliwin:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data jilliwin holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: 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 jilliwin's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

Please note that certain rights may be subject to limitations where jilliwin has overriding legal obligations — for example, we cannot delete transaction records that we are required to retain under anti-money laundering law.

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

• Encryption: All data transmitted between your device and the jilliwin Platform is encrypted using TLS (Transport Layer Security). Sensitive data at rest, including payment details and identity documents, is encrypted using AES-256 or equivalent standards.
• Access Controls: Access to personal data is restricted to jilliwin personnel and authorized third parties who have a legitimate need to access it. All access is logged and subject to regular review.
• Two-Factor Authentication: jilliwin supports and encourages the use of two-factor authentication (2FA) for all player accounts to provide an additional layer of security.
• Regular Security Audits: jilliwin conducts regular internal and third-party security assessments, penetration testing, and vulnerability scans to identify and remediate potential security weaknesses.
• Incident Response: jilliwin maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, jilliwin will notify the National Privacy Commission and affected data subjects within the timeframes prescribed by RA 10173.

While jilliwin takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. You are also responsible for maintaining the security of your jilliwin account credentials.

jilliwin takes its age verification obligations seriously. During the registration and KYC process, we verify the age of all players using government-issued identification. Any account found to belong to a person under 21 years of age will be immediately suspended, and any funds in the account will be handled in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor has registered a jilliwin account or provided personal data to jilliwin without your consent, please contact us immediately at [email protected]. We will investigate and take appropriate action, including deletion of the minor's data, as quickly as possible.

jilliwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory guidance from the National Privacy Commission.

When material changes are made to this Policy, jilliwin will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision.

Your continued use of the jilliwin Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must stop using the Platform and may request account closure by contacting our support team.

We recommend reviewing this Privacy Policy periodically — at least once every 90 days — to stay informed about how jilliwin protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or jilliwin's handling of your personal data, please contact us through any of the following channels:

• Data Protection Officer (DPO): [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the jilliwin Platform
• Response Time: Data subject requests are responded to within 15 business days

If you are not satisfied with jilliwin's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC can be reached through their official website at privacy.gov.ph or via their official contact channels.