jilikl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by jilikl ("jilikl," "we," "us," "our") and applies to all personal data collected from individuals ("you," "Player," "User") who access or use the jilikl website at jilikl.org, its sub-pages, and all associated services, games, and features (collectively, the "Platform").

jilikl recognises the fundamental right of every Filipino to informational privacy, as enshrined in the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations issued by the National Privacy Commission of the Philippines ("NPC"). This Policy is designed to meet or exceed the obligations imposed by the DPA, along with the data handling requirements of the Philippine Amusement and Gaming Corporation ("PAGCOR") under whose regulatory framework jilikl operates.

By registering an account, accessing the Platform, or otherwise providing personal data to jilikl, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree, please discontinue use of the jilikl Platform and contact us to arrange deletion of any personal data we hold about you.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, jilikl acts as the personal information controller ("PIC") in respect of all personal data collected through the Platform. jilikl determines the purposes and means of processing personal data of its registered players and website visitors.

jilikl has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with the DPA and this Policy. Contact details for the DPO are provided in Section 15 of this Policy.

3. Data We Collect

3.1 Registration and Account Data

When you register a jilikl account, we collect the following data, which is necessary to establish and maintain your account and comply with PAGCOR's Know Your Customer ("KYC") requirements:

• Full legal name, as it appears on a Philippine government-issued identification document;
• Date of birth (to verify you meet the 21+ age requirement);
• Registered Philippine mobile number;
• Email address;
• Home address within the Philippines;
• Government-issued identification number and document images (for KYC verification);
• Selfie photograph for identity verification purposes (where required).

3.2 Financial and Transaction Data

To process deposits, withdrawals, and comply with anti-money laundering ("AML") obligations under the Philippine AMLA (Republic Act No. 9160, as amended), jilikl collects:

• GCash, PayMaya, or bank account details linked to deposits and withdrawals;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment methods;
• Source of funds documentation for high-value accounts as required by PAGCOR and AMLA regulations.

3.3 Gaming Activity Data

• Game session logs, bet history, win/loss records, and bonus utilisation records;
• Responsible gaming settings selected by the player, including deposit limits, session limits, and self-exclusion status.

3.4 Technical and Device Data

• IP address and geolocation data (to verify Philippines-based access);
• Device type, operating system, and browser information;
• Session duration, pages visited, and click-stream data;
• Cookie and similar tracking technology data, as described in Section 8.

3.5 Communications Data

• Records of communications with jilikl's support team, including live chat transcripts and email correspondence;
• Feedback, complaints, and dispute records.

4. How We Collect Your Data

jilikl collects personal data through the following means:

• Directly from you: when you register an account, complete the KYC process, make a deposit or withdrawal, contact support, or submit feedback through the jilikl Platform;
• Automatically: through cookies, server logs, and similar technologies when you browse and interact with the jilikl Platform;
• From third parties: identity verification service providers, payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank), and fraud prevention partners, where you have authorised such sharing or where we are permitted to obtain the data under applicable law.

5. How We Use Your Data

jilikl processes your personal data for the following purposes:

• To create, maintain, and manage your jilikl account;
• To verify your identity and age (21+) in compliance with PAGCOR KYC requirements;
• To process deposits and withdrawals in Philippine Peso via GCash, PayMaya, and Philippine bank accounts;
• To detect, investigate, and prevent fraud, money laundering, and other unlawful activity in compliance with the AMLA;
• To provide, personalise, and improve the jilikl Platform, game offerings, and user experience;
• To administer jilikl bonuses, promotions, and the VIP loyalty programme;
• To operate responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods;
• To communicate with you regarding your account, transactions, platform updates, and (with your consent) promotional offers;
• To respond to and resolve support queries, complaints, and disputes;
• To comply with jilikl's obligations under PAGCOR's licensing conditions, the DPA, and other applicable Philippine laws;
• To generate anonymised, aggregated analytics data for internal platform improvement purposes.

6. Legal Basis for Processing

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

• Contractual necessity: processing required to perform our obligations under the jilikl Terms and Conditions, including account management and transaction processing;
• Legal obligation: processing required to comply with PAGCOR licensing conditions, AMLA obligations, the DPA, and other applicable Philippine laws;
• Legitimate interests: processing for fraud prevention, security, and platform analytics, where our legitimate interests are not overridden by your rights and freedoms;
• Consent: processing for direct marketing communications, where we rely on your freely given, specific, informed, and unambiguous consent, which you may withdraw at any time.

7. Data Sharing and Disclosure

jilikl does not sell your personal data to any third party. We may share your personal data with the following categories of recipients, only to the extent necessary for the stated purpose:

• PAGCOR and Philippine regulatory authorities: as required under jilikl's PAGCOR licence conditions, including for audit, compliance, and enforcement purposes;
• Philippine law enforcement and government agencies: where required by court order, legal process, or applicable Philippine law;
• Payment processors: GCash, PayMaya, and Philippine banks, solely to process your deposit and withdrawal transactions;
• KYC and identity verification providers: licensed third-party services that assist jilikl in verifying player identity and age in compliance with PAGCOR requirements;
• Game software providers: limited technical data necessary to deliver the game experience, subject to confidentiality obligations;
• IT infrastructure and security providers: cloud hosting, cybersecurity, and fraud prevention partners operating under strict data processing agreements.

All third-party processors engaged by jilikl are required to implement appropriate technical and organisational security measures and to process personal data only in accordance with jilikl's documented instructions and applicable Philippine law.

8. Cookies and Tracking Technologies

jilikl uses cookies and similar technologies (collectively, "Cookies") on the Platform. Cookies are small data files placed on your device that enable us to recognise your browser, remember your preferences, and understand how you use the jilikl Platform.

Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function, including your login session, security tokens, and responsible gaming settings. These cannot be disabled without impairing your ability to use jilikl.
• Functional Cookies: Remember your language preferences and account settings to personalise your jilikl experience.
• Analytical Cookies: Collect anonymised data on how players use the jilikl Platform to help us improve game performance, navigation, and overall user experience.
• Security Cookies: Detect and prevent fraudulent activity, including bot access and account takeover attempts.

You may control non-essential Cookies through your browser settings. Note that disabling certain Cookies may affect your experience on the jilikl Platform.

9. Data Retention

jilikl retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by applicable Philippine law:

• Account and KYC data: Minimum of five (5) years from account closure, as required by PAGCOR and AMLA regulations;
• Financial transaction records: Minimum of five (5) years from the date of the transaction, in compliance with AMLA requirements;
• Gaming activity records: Three (3) years from the date of the activity, or as required by PAGCOR;
• Support communications: Three (3) years from the date of the last communication, or longer where a dispute is ongoing;
• Marketing consent records: Until withdrawal of consent, plus six (6) months thereafter for audit purposes.

Following the expiry of the applicable retention period, personal data will be securely deleted, anonymised, or rendered inaccessible in accordance with jilikl's data disposal procedures.

10. Data Security

jilikl implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, destruction, or accidental loss. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jilikl's servers;
• Encryption of sensitive personal data fields at rest within jilikl's databases;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Multi-factor authentication requirements for all jilikl internal system access;
• Regular penetration testing and vulnerability assessments of jilikl's Platform infrastructure;
• Incident response procedures aligned with the NPC's mandatory data breach notification requirements.

In the event of a personal data breach that is likely to result in serious harm to you, jilikl will notify the NPC within seventy-two (72) hours of discovery and will notify affected players without undue delay, as required by the DPA.

11. Your Rights Under the Philippine Data Privacy Act

As a data subject under Republic Act No. 10173, you hold the following rights with respect to your personal data held by jilikl:

• Right to be Informed: You have the right to know that jilikl is collecting your personal data and to be informed of the purposes, scope, and method of processing;
• Right of Access: You may request a copy of the personal data jilikl holds about you and information about how it is processed;
• Right to Rectification: You may request correction of any personal data that is inaccurate, incomplete, or outdated;
• Right to Erasure or Blocking: You may request deletion or blocking of your personal data where processing is no longer necessary, consent has been withdrawn, or processing is unlawful — subject to jilikl's legal obligations to retain certain data;
• Right to Object: You may object to jilikl's processing of your personal data, particularly for direct marketing purposes;
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format for transfer to another controller;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe jilikl has mishandled your personal data.

To exercise any of these rights, please contact jilikl's Data Protection Officer using the contact details in Section 15. jilikl will respond to all verified data subject requests within fifteen (15) business days, in accordance with the DPA's requirements.

12. Children's Privacy

The jilikl Platform is strictly intended for persons aged twenty-one (21) years and older, in accordance with PAGCOR regulations and Philippine law. jilikl does not knowingly collect personal data from individuals under the age of 21. If jilikl becomes aware that personal data has been submitted by an individual below the required age, such data will be promptly deleted and the account permanently closed in accordance with jilikl's Terms and Conditions and PAGCOR's underage gambling prevention requirements.

Parents and guardians who believe that a minor may have provided personal data to jilikl should contact the DPO immediately using the contact details in Section 15.

13. Cross-Border Data Transfers

jilikl's primary data processing infrastructure is located within or accessible from the Philippines. Where personal data is transferred outside the Philippines — for example, to cloud infrastructure providers or game software licensors — jilikl ensures that such transfers are subject to appropriate safeguards, including data processing agreements that impose obligations equivalent to the protections required by the Philippine Data Privacy Act of 2012 and the NPC's guidelines on cross-border data transfers.

jilikl will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first obtaining your explicit consent or implementing appropriate contractual safeguards as recognised by the NPC.

14. Changes to This Privacy Policy

jilikl reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidance, PAGCOR requirements, or jilikl's data processing practices. Material changes will be communicated to registered players via in-platform notification or email to the address registered on your jilikl account at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the jilikl Platform after the effective date of a revised Policy constitutes your acknowledgement of and agreement to the revised terms.

15. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or jilikl's processing of your personal data, please contact jilikl's Data Protection Officer:

• Data Protection Officer: jilikl DPO
• Email: [email protected] (subject line: "Privacy / DPO Request")
• Live Chat: Available 24/7 on the jilikl Platform
• Response Time: Within 15 business days, Philippine Standard Time (UTC+8)

If you are not satisfied with jilikl's response to your data privacy concern, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines.