jilliapp Privacy Policy

1.Introduction

jilliapp ("jilliapp," "we," "us," or "our") is committed to protecting the privacy and personal data of all players who use the jilliapp online gaming platform at jilliapp.club (the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect your personal information in connection with your use of the Platform and all related services.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Privacy Policy should be read together with our Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Privacy Policy have the meanings given to them in the Terms & Conditions.

2.Personal Data We Collect

jilliapp collects the following categories of personal data from players:

jilliapp does not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance, in which case such collection will be clearly disclosed to you at the time of collection.

3.How We Collect Your Data

jilliapp collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the Platform, including through cookies, web beacons, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data from accredited KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash and PayMaya.
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with our licensing obligations.

4.How We Use Your Personal Data

jilliapp uses your personal data for the following purposes:

• To create, verify, and manage your jilliapp account.
• To process deposits, withdrawals, and other financial transactions.
• To verify your identity and age in compliance with Philippine gambling regulations (minimum age: 21 years).
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
• To provide customer support and respond to your inquiries.
• To send you transactional communications, including account notifications, deposit confirmations, and withdrawal updates.
• To send you promotional communications about jilliapp offers and new games, where you have consented to receive such communications.
• To personalize your experience on the Platform based on your preferences and activity.
• To improve the Platform's functionality, security, and user experience.
• To enforce our Terms & Conditions and resolve disputes.

jilliapp will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

5.Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AML obligations, and tax reporting.
• Legitimate interests: Processing necessary for jilliapp's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6.Sharing Your Personal Data

jilliapp 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:

• Payment processors: GCash, PayMaya, and Philippine banking partners, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Accredited KYC and age verification service providers engaged to verify your identity and age.
• Fraud prevention partners: Third-party fraud detection and anti-money laundering service providers.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or regulation.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by jilliapp in connection with legal proceedings or compliance activities.
• Technology service providers: Cloud hosting providers, database administrators, and IT security partners who process data on our behalf under strict data processing agreements.

All third parties with whom jilliapp shares personal data are required to handle such data in accordance with the Philippine Data Privacy Act of 2012 and are prohibited from using your data for any purpose other than the specific service they provide to jilliapp.

7.Data Retention

jilliapp retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation. 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 compliance with PAGCOR licensing requirements and AML regulations.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and related regulations.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and usage data: Retained for up to twelve (12) months from collection, after which it is anonymized or deleted.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

When personal data is no longer required, jilliapp will securely delete or anonymize it in accordance with our internal data disposal procedures.

8.Cookies & Tracking Technologies

jilliapp uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session security, and analyze Platform usage. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and game display options, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the Platform, including pages visited and features used. This data helps jilliapp improve the Platform over time.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats.

You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. jilliapp does not use cookies to serve third-party advertising or to track your activity on other websites.

9.Data Security

jilliapp 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:

• SSL/TLS encryption: All data transmitted between your device and the jilliapp Platform is encrypted using industry-standard SSL/TLS protocols.
• Secure data storage: Personal and financial data is stored on secure, access-controlled servers with restricted physical and logical access.
• Access controls: Access to personal data within jilliapp is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Regular security audits: jilliapp conducts regular security assessments and penetration testing to identify and address potential vulnerabilities.
• Incident response: jilliapp maintains a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by NPC regulations.

While jilliapp takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account login credentials and for notifying jilliapp immediately if you suspect unauthorized access to your account.

10.Your Data Rights

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

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data jilliapp holds about you, along with information about how it is being used.
• 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 jilliapp'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 jilliapp's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of the above rights, please contact jilliapp's Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days, as required by NPC regulations. We may need to verify your identity before processing your request.

11.Children's Privacy

The jilliapp Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. jilliapp does not knowingly collect personal data from persons under the age of 21.

If jilliapp becomes aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete the personal data, and return any deposited funds to the source of payment. If you believe that a minor has registered an account on the Platform, please contact us immediately at [email protected].

12.Third-Party Links

The jilliapp Platform may contain links to third-party websites or services, such as payment provider portals. This Privacy Policy applies solely to the jilliapp Platform and does not cover the privacy practices of any third-party websites or services. jilliapp is not responsible for the privacy practices or content of any third-party sites.

We encourage you to review the privacy policies of any third-party services you access in connection with your use of the Platform, particularly payment providers such as GCash and PayMaya, which have their own privacy policies governing the handling of your financial data.

13.Changes to This Privacy Policy

jilliapp reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered players via the email address associated with their account and/or by displaying a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed of how jilliapp protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy.

14.Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by jilliapp, please contact our Data Protection Officer through the following channel:

jilliapp is committed to resolving all privacy-related concerns promptly and transparently. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission.