Privacy Policy

1 Who We Are

jili165 ("jili165," "we," "us," or "our") is the operator of the online gaming platform accessible at jili165.app. jili165 is a PAGCOR-regulated online gaming platform serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and nationwide.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA") and its Implementing Rules and Regulations, jili165 acts as the Personal Information Controller (PIC) in respect of the personal data it collects from registered players and website visitors.

jili165 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the DPA and this Privacy Policy. Contact details for the DPO are provided in Section 13 of this policy.

2 Personal Data We Collect

jili165 collects the following categories of personal data, depending on how you interact with the platform:

2.1 Registration & Identity Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify the 21+ age requirement under Philippine law)
• Gender
• Nationality and country of residence
• Registered email address
• Philippine mobile number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

To comply with PAGCOR licensing requirements and the Philippine Anti-Money Laundering Act (AMLA), jili165 is required to verify the identity of all players before processing withdrawals. KYC data may include:

• Copies of government-issued photo ID (e.g., Philippine passport, PhilSys National ID, SSS ID, UMID, driver's license, PRC ID, Voter's ID)
• Proof of address documents (e.g., utility bill, bank statement dated within 90 days)
• Proof of payment method ownership (e.g., GCash account screenshot showing your registered name)
• Selfie or live photo for identity matching purposes

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash registered mobile number, bank account name — jili165 does not store full bank account numbers or card numbers)
• Transaction amounts, dates, and reference numbers
• Bonus and promotional credit history

2.4 Gaming Activity Data

• Game session logs (games played, wager amounts, outcomes, session duration)
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Bonus wagering progress

2.5 Technical & Device Data

• IP address and approximate geolocation (country/region level)
• Device type, operating system, and browser type
• Cookie identifiers and session tokens
• Platform access logs (login timestamps, pages visited)

2.6 Communications Data

• Customer support chat transcripts and email correspondence
• Survey responses and feedback submissions
• Promotional communication preferences (opt-in/opt-out status)

3 How We Collect Your Data

jili165 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, session tracking, and server logs when you browse or use the jili165 platform. See Section 7 for full details on cookies.
• From payment processors — when you initiate a deposit or withdrawal via GCash, PayMaya, BPI, BDO, or Metrobank, we receive transaction confirmation data from those providers.
• From identity verification services — jili165 may use third-party KYC verification providers to assist in validating government-issued ID documents. These providers act as Personal Information Processors (PIPs) under jili165's instruction.
• From regulatory bodies — jili165 may receive information from PAGCOR or the Anti-Money Laundering Council (AMLC) in connection with regulatory compliance obligations.

4 How We Use Your Personal Data

jili165 uses your personal data for the following purposes:

jili165 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by the DPA.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jili165 processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and jili165 — specifically, to operate your account, process transactions, and provide gaming services.
• Legal obligation: Processing is required to comply with jili165's obligations under Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act (RA 10173).
• Legitimate interests: Processing is necessary for jili165's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and improving our services — provided these interests are not overridden by your rights and freedoms.
• Consent: For optional processing activities such as sending promotional emails or SMS notifications, jili165 relies on your freely given, specific, and informed consent. You may withdraw consent at any time by updating your communication preferences in your account settings or by contacting support.

6 Data Sharing & Third Parties

6.1 Payment Processors

When you make a deposit or withdrawal, jili165 shares the minimum necessary transaction data with your chosen payment provider (GCash, PayMaya, BPI, BDO, or Metrobank) to process the transaction. These providers have their own privacy policies and are independently responsible for their data handling practices.

6.2 Identity Verification Providers

jili165 may engage third-party KYC verification service providers to assist in validating identity documents. These providers act as Personal Information Processors under written agreements that require them to process data only on jili165's instructions and to maintain appropriate security standards.

6.3 Regulatory Authorities

jili165 is required by Philippine law to share certain data with regulatory and law enforcement authorities, including PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC), when lawfully requested or as required by our licensing conditions.

6.4 IT and Platform Service Providers

jili165 uses third-party service providers for cloud hosting, data storage, cybersecurity, and platform analytics. These providers are contractually bound to process personal data only as instructed by jili165 and to maintain security standards consistent with the DPA.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of jili165's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and your rights under the DPA will be preserved.

7 Cookies & Tracking Technologies

jili165 uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain your login session, and analyze platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming tool configurations, and display preferences.
• Analytics Cookies: Help jili165 understand how players use the platform so we can improve the user experience. Data collected is aggregated and anonymized where possible.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the jili165 platform. jili165 does not use third-party advertising or retargeting cookies.

8 Data Retention

jili165 retains personal data for the periods set out below, after which data is securely deleted or anonymized:

Where jili165 is required by law to retain data for longer periods, the statutory retention period will apply. Data subject to a legal hold (e.g., in connection with ongoing regulatory investigation) will be retained until the hold is lifted.

9 Data Security

jili165 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:

• 256-bit SSL/TLS encryption for all data in transit between your device and jili165 servers.
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records.
• Bcrypt password hashing — your jili165 password is never stored in plain text.
• Multi-factor authentication (MFA) options for player accounts and mandatory MFA for all jili165 administrative access.
• Role-based access controls ensuring that jili165 staff can only access personal data necessary for their specific job function.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Intrusion detection and prevention systems (IDS/IPS) monitoring for suspicious activity 24/7.
• Data breach response plan with defined procedures for detection, containment, notification, and remediation.

While jili165 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials. If you suspect unauthorized access to your jili165 account, contact support immediately.

10 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jili165:

To exercise any of these rights, contact jili165's Data Protection Officer using the details in Section 13. jili165 will respond to all valid data subject requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 30 days, with notice provided to you.

If you are not satisfied with jili165's response to your data subject request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Children's Privacy

jili165 does not knowingly collect personal data from individuals under the age of 21. All registration attempts are subject to age verification, and accounts found to belong to persons under 21 will be immediately closed. If you believe that a minor has registered on jili165, please contact our support team immediately so we can take appropriate action.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gaming platforms. jili165 supports the responsible gaming initiatives of PAGCOR and is committed to protecting young people from the potential harms of gambling.

12 Updates to This Privacy Policy

jili165 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made, jili165 will notify registered players via the email address on file and/or by displaying a prominent notice on the platform.

The "Last Updated" date at the top of this policy indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically. Your continued use of jili165 following the posting of any changes constitutes your acceptance of the updated policy.

13 Contact Us & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the jili165 Data Protection Officer (DPO):

If you wish to file a complaint with the Philippine data protection authority, you may contact the National Privacy Commission (NPC) directly. jili165 encourages players to reach out to us first so we can resolve any concerns promptly.