Jiliwim Privacy
Policy

1. Introduction

This Privacy Policy ("Policy") describes how Jiliwim ("we," "us," or "our") collects, uses, stores, and discloses personal information obtained from players and visitors ("you") who access or use the Jiliwim website, mobile application, and related services (collectively, the "Platform").

Jiliwim is committed to protecting the privacy and personal data of all users, particularly Filipino players who trust us with their information. This Policy is designed to be transparent, straightforward, and compliant with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC).

By registering an account on Jiliwim, making a deposit, or otherwise 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. If you do not agree with this Policy, you must not use the Jiliwim Platform.

This Policy should be read alongside Jiliwim's Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of the Platform.

2. Data Controller

For the purposes of applicable data protection law, Jiliwim is the data controller responsible for the personal information collected through the Platform. As data controller, Jiliwim determines the purposes and means of processing your personal data and is accountable for ensuring that such processing is carried out lawfully, fairly, and transparently.

Jiliwim has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO directly for any privacy-related queries or requests using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

Jiliwim collects personal data from you in the following categories, depending on how you interact with the Platform:

3.1 Registration and Identity Data

When you create a Jiliwim account, we collect:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

To comply with anti-money laundering regulations and verify player identity, Jiliwim may collect:

• Copies of government-issued identification (e.g., Philippine passport, SSS card, UMID, driver's license, PhilSys ID)
• Proof of residential address (e.g., utility bill, bank statement)
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account)
• Selfie or live photo for identity confirmation

3.3 Financial and Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method details (GCash number, PayMaya number, bank account details — stored in tokenized or masked form)
• Transaction history and account balance records

3.4 Gaming Activity Data

• Games played, bet amounts, win/loss records, and session durations
• Bonus and promotion usage history
• Responsible gaming tool usage (deposit limits, self-exclusion requests)

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session logs, access timestamps, and platform interaction data
• Cookie identifiers and similar tracking technologies

3.6 Communications Data

• Records of your communications with Jiliwim's customer support team
• Feedback, complaints, and survey responses
• Email and in-app message history

4. How We Use Your Personal Data

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

Jiliwim 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 applicable law.

5. Legal Basis for Processing

Jiliwim processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and Jiliwim — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing is required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, and regulatory reporting obligations.
• Legitimate interests: Processing is necessary for Jiliwim's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — Jiliwim will obtain your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing of Personal Data

Jiliwim 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 and subject to appropriate data protection safeguards:

6.1 Payment Service Providers

To process deposits and withdrawals, Jiliwim shares necessary financial data with payment providers including GCash, PayMaya, BPI, BDO, and Metrobank. These providers process your data solely to facilitate your transactions and are bound by their own privacy policies and applicable financial regulations.

6.2 Identity Verification and KYC Providers

Jiliwim may engage third-party KYC and identity verification service providers to assist with age verification and document authentication. These providers process your identity documents under strict confidentiality agreements and are prohibited from using your data for any other purpose.

6.3 Technology and Infrastructure Providers

Jiliwim uses third-party cloud hosting, data storage, and platform infrastructure providers to operate the Platform. These providers act as data processors on Jiliwim's behalf and are contractually required to implement appropriate security measures and process data only on Jiliwim's instructions.

6.4 Game Content Providers

Certain games available on Jiliwim are provided by third-party game studios. Limited technical data (such as session identifiers) may be shared with these providers to facilitate gameplay. Game providers do not receive your full personal profile.

6.5 Regulatory and Law Enforcement Authorities

Jiliwim may disclose your personal data to relevant Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law, court order, or regulatory instruction. This includes reporting obligations under anti-money laundering legislation.

7. Data Retention

Jiliwim retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. 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 anti-money laundering record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Gaming activity data: Retained for the duration of your account and for up to three (3) years following account closure for responsible gaming and dispute resolution purposes.
• Communications data: Retained for up to three (3) years from the date of the communication, unless a longer period is required for dispute resolution.
• Technical and device data: Retained for up to twelve (12) months from collection, unless required for longer for fraud investigation purposes.

Upon expiry of the applicable retention period, Jiliwim will securely delete or anonymize your personal data in accordance with its data disposal procedures.

8. Cookies and Tracking Technologies

Jiliwim uses cookies and similar tracking technologies on the Platform to enhance your experience, analyze usage patterns, and support platform security. 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.
• Performance and analytics cookies: Used to collect anonymized data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data helps Jiliwim improve the Platform.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and measure the effectiveness of Jiliwim's marketing campaigns. You may opt out of marketing cookies at any time.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Jiliwim Platform. For more information on managing cookies, refer to your browser's help documentation.

9. Data Security

Jiliwim 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:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Jiliwim Platform.
• Encryption of sensitive data at rest, including payment method details and identity documents.
• Role-based access controls ensuring that only authorized Jiliwim personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures to detect, contain, and report data breaches in accordance with applicable law.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Jiliwim will notify the National Privacy Commission and affected players in accordance with the timeframes and requirements prescribed by the Philippine Data Privacy Act and its implementing rules.

10. Your Data Protection Rights

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 Jiliwim:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed. This Privacy Policy fulfills that obligation.
• Right of access: You have the right to request a copy of the personal data Jiliwim holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by Jiliwim. You may update certain information directly through your account settings.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to Jiliwim's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on Jiliwim's legitimate interests.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact Jiliwim's Data Protection Officer using the contact details in Section 15. Jiliwim will respond to all verified data subject requests within fifteen (15) business days of receipt, or within such other timeframe as required by applicable law.

11. Children's Privacy and Age Restriction

The Jiliwim Platform is strictly intended for individuals who are 21 years of age or older. Jiliwim does not knowingly collect, process, or store personal data from individuals under the age of 21. This age restriction is a firm requirement under Philippine gaming regulations and is actively enforced through our KYC verification process.

If Jiliwim becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be handled in accordance with applicable regulatory requirements.

12. International Data Transfers

Jiliwim primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from locations outside the Philippines — for example, where Jiliwim uses cloud infrastructure or technology service providers with servers in other countries.

Where such international transfers occur, Jiliwim ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law. These safeguards may include contractual clauses, data processing agreements, or transfers to jurisdictions recognized as providing adequate data protection.

By using the Jiliwim Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

13. Third-Party Links and Services

The Jiliwim Platform may contain references to third-party services, such as payment providers and game studios. These third parties operate their own platforms and are governed by their own privacy policies. Jiliwim is not responsible for the privacy practices of third-party services and encourages you to review their privacy policies before providing any personal data to them.

Jiliwim does not include external links to unrelated third-party websites on the Platform. Any links present on the Platform are limited to services directly related to your use of Jiliwim.

14. Changes to This Privacy Policy

Jiliwim 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 date of the most recent revision is displayed at the top of this page.

When material changes are made to this Policy, Jiliwim will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the Jiliwim Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how Jiliwim protects your personal data. If you have any questions about changes to this Policy, please contact our Data Protection Officer.

15. Contact Us and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way Jiliwim handles your personal data, please contact our Data Protection Officer. We are committed to resolving all privacy-related queries promptly and transparently.

If you are not satisfied with Jiliwim'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 is the government body responsible for administering and implementing the Data Privacy Act of 2012 and ensuring compliance by personal information controllers operating in the Philippines.

For responsible gaming concerns, account restrictions, or self-exclusion requests, please visit our Responsible Gaming page or contact our support team directly. All such requests are handled with the utmost confidentiality and priority.