Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") sets out the basis on which jili77a ("we", "us", "our", the "Company") collects, processes, stores, and uses personal data relating to individuals ("you", "your", the "Player") who access or use the jili77a platform at jili77a.net and all associated pages, features, games, and services ("the Platform").

This Policy applies to all personal data collected through:

• The account registration and KYC verification process.
• Your use of games, betting markets, promotions, and other Platform features.
• Deposits, withdrawals, and all financial transactions conducted through the Platform.
• Communications with jili77a's customer support team via email, live chat, or any other channel.
• Technical data collected automatically through cookies and similar technologies when you access the Platform.

This Policy is incorporated into jili77a's Terms & Conditions by reference and forms part of the legally binding agreement between you and jili77a. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, jili77a is the personal information controller responsible for the personal data collected through the Platform.

jili77a operates under regulation by the Philippine Amusement and Gaming Corporation (PAGCOR). Our Data Protection Officer (DPO) is responsible for overseeing compliance with the Data Privacy Act and can be contacted as described in Section 13 of this Policy.

3. Data We Collect

jili77a collects personal data in the following categories. The table below summarises each category, the specific data points collected, and the context in which they are collected.

jili77a does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data unless specifically required for KYC compliance purposes and only to the extent mandated by PAGCOR or Philippine law.

4. How We Use Your Data

jili77a uses the personal data collected for the following specific purposes:

• Account Administration: To create, verify, maintain, and manage your jili77a player account, including processing your registration, verifying your identity through KYC, and keeping your account records up to date.
• Service Delivery: To provide access to all games, betting markets, promotions, and platform features available on jili77a, including processing deposits, settling bets, and processing withdrawal requests.
• Regulatory Compliance: To fulfil jili77a's mandatory obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and all other applicable Philippine laws and regulations. This includes filing Suspicious Transaction Reports (STRs) with the Anti-Money Laundering Council (AMLC) where legally required.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming patterns for indicators of problem gambling, to administer self-exclusion and deposit limit requests, and to fulfil responsible gaming obligations under jili77a's PAGCOR licence.
• Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance through jili77a's 24/7 support team.
• Platform Improvement: To analyse aggregated usage data to improve the Platform's performance, game selection, user experience, and feature set. This analysis uses anonymised or pseudonymised data wherever possible.
• Marketing Communications: To send you promotional offers, bonus notifications, and relevant platform updates — but only where you have provided your consent to receive such communications. You may withdraw your marketing consent at any time through your account settings.

5. Legal Basis for Processing

jili77a processes your personal data on one or more of the following legal grounds as recognised under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and jili77a as set out in the Terms & Conditions — for example, processing your deposits, settling your bets, and managing your account.
• Legal Obligation: Processing is required for jili77a to comply with its legal obligations under PAGCOR licensing conditions, the AMLA, tax laws, and other applicable Philippine regulations.
• Legitimate Interests: Processing is necessary for jili77a's legitimate interests in operating a secure, fair, and commercially viable gaming platform — including fraud detection, security monitoring, and platform analytics — provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications or the use of non-essential cookies — jili77a relies on your consent, which you may withdraw at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Data

jili77a does not sell your personal data. We may share your data with the following categories of third parties strictly for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and any other payment service providers used to process your deposits and withdrawals. These processors receive only the data necessary to complete your transaction.
• KYC and Identity Verification Providers: Third-party identity verification services engaged to assist with mandatory KYC compliance. These providers process your identity documents under strict confidentiality obligations.
• Game Content Providers: Software providers whose games are available on the jili77a Platform may receive anonymised or pseudonymised session data for the purpose of game performance monitoring and RNG certification. They do not receive your identifiable personal data.
• IT Infrastructure and Security Providers: Cloud hosting, cybersecurity, and infrastructure providers who support the technical operation of the Platform. These providers are contractually bound to process your data only on jili77a's instructions.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), courts of law, and other competent Philippine authorities where disclosure is required by law, court order, or regulatory direction.
• Professional Advisers: Legal, audit, and financial advisers who provide professional services to jili77a and who are bound by professional confidentiality obligations.

7. Cookies & Tracking Technologies

jili77a uses cookies and similar tracking technologies on the Platform to support essential functionality, analyse Platform usage, and — where you have consented — deliver relevant promotional content. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function and cannot be disabled. They include session management cookies that keep you logged in during your visit, security cookies that protect against cross-site request forgery, and load balancing cookies. No consent is required for these cookies.
• Analytics Cookies: These cookies allow jili77a to understand how players use the Platform — which pages are visited most, how long sessions last, and where technical errors occur. This data is used in aggregated, anonymised form to improve Platform performance. These cookies are set only with your consent.
• Preference Cookies: These cookies remember your Platform settings, such as your preferred language or display preferences, to provide a more personalised experience. These cookies are set only with your consent.
• Marketing Cookies: Where you have opted into marketing communications, certain cookies may be used to track the effectiveness of promotional campaigns served through the Platform. These cookies are set only with your explicit consent and can be withdrawn at any time through your account settings.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies may impair the functionality of the Platform and prevent you from accessing certain features, including your account.

8. Data Security

jili77a implements a layered, defence-in-depth approach to data security. The technical and organisational security measures we maintain include:

• Encryption in Transit: All data exchanged between your device and jili77a's servers is encrypted using industry-standard TLS 1.2 or higher. We do not permit unencrypted HTTP connections to the Platform.
• Encryption at Rest: Sensitive personal data and financial records stored on jili77a's infrastructure are encrypted at rest using AES-256 or equivalent encryption standards.
• Access Controls: Access to personal data within jili77a's organisation is restricted on a strict need-to-know basis. Staff with access to player data are subject to background checks, confidentiality agreements, and regular data protection training.
• Penetration Testing and Vulnerability Management: jili77a engages independent security professionals to conduct regular penetration tests and vulnerability assessments of the Platform's infrastructure and codebase.
• Incident Response: jili77a maintains a documented data breach incident response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, jili77a will notify the National Privacy Commission and affected players in accordance with the timelines required under the Data Privacy Act.

9. Data Retention

jili77a retains personal data for as long as necessary to fulfil the purposes described in this Policy or as required by applicable Philippine law. The following general retention periods apply:

• Account and Identity Data: Retained for a minimum of five (5) years following permanent account closure, in compliance with PAGCOR licensing conditions and AMLA record-keeping requirements.
• Transaction and Financial Records: Retained for a minimum of five (5) years in compliance with AMLA obligations and applicable tax laws.
• Gaming and Betting History: Retained for a minimum of three (3) years for dispute resolution purposes and PAGCOR audit compliance.
• Customer Support Records: Retained for two (2) years following the resolution of the relevant support interaction, unless the matter relates to an ongoing dispute or investigation.
• Marketing Preference Records: Retained for the duration of your account and for one (1) year following account closure, to evidence consent compliance.
• Technical and Log Data: Retained for up to twelve (12) months for security monitoring and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

10. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jili77a:

• Right to Be Informed: The right to be notified of how your personal data is being processed, which this Policy fulfils.
• Right of Access: The right to obtain confirmation of whether jili77a holds personal data about you and to receive a copy of that data in a commonly used electronic format.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update certain account details directly through your account settings. For data that cannot be self-corrected, contact our support team.
• 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 and where no legal retention obligation applies. Please note that jili77a's regulatory obligations under PAGCOR and AMLA may prevent full erasure during the mandatory retention period.
• 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 Object: The right to object to processing of your personal data for direct marketing purposes at any time. You may exercise this right through the unsubscribe function in any marketing email or through your account settings.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that jili77a has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please submit your request in writing to [email protected] with the subject line "Data Subject Rights Request". jili77a will acknowledge your request within five (5) business days and respond fully within thirty (30) days, or within such extended period as permitted by the Data Privacy Act where the request is complex or numerous.

11. Children & Minors

jili77a is strictly an adults-only platform. In compliance with PAGCOR's mandatory age requirements, the minimum age for all players is 21 years. jili77a does not knowingly collect personal data from individuals under the age of 21.

During the registration and KYC verification process, jili77a takes active steps to verify the age of all applicants. Where jili77a discovers or has reasonable grounds to believe that personal data has been collected from an individual under the age of 21, the following steps will be taken immediately:

• The relevant account will be permanently suspended.
• All personal data collected in connection with the underage account will be deleted from jili77a's systems, except to the extent that retention is required by law.
• Any funds deposited into the account will be dealt with in accordance with PAGCOR's guidelines on underage gambling.
• The matter may be reported to PAGCOR and relevant Philippine authorities.

If you are a parent or guardian and believe that your child has registered an account on jili77a, please contact us immediately at [email protected].

12. Changes to This Policy

jili77a reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, our data processing practices, or Platform features. The "Last Updated" date at the top of this Policy will be revised whenever a material change is made.

Where changes are material — meaning they significantly affect how your personal data is processed or your rights as a data subject — jili77a will notify registered players via the Platform or by email to the address registered on your account at least fourteen (14) days prior to the changes taking effect.

Continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of and agreement to the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure by contacting jili77a support.

13. Contact & Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or jili77a's data processing practices, or if you wish to exercise your rights under the Data Privacy Act, please contact jili77a's Data Protection Officer:

• Email: [email protected]
• Subject Line: "Privacy Enquiry" or "Data Subject Rights Request"
• Support Hours: 24 hours a day, 7 days a week
• Response Time: Acknowledgement within 5 business days; full response within 30 days
• Language: English (Filipino-English fluency available)

If you are not satisfied with jili77a's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through the NPC's official government channels.

For matters relating to jili77a's gaming licence and regulatory compliance, you may also contact the Philippine Amusement and Gaming Corporation (PAGCOR) through PAGCOR's official regulatory channels.