jillie Privacy Policy

This Privacy Policy ("Policy") describes how jillie ("jillie," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal data of individuals ("you," "Player," or "User") who register an account on or otherwise interact with the jillie online casino and sports betting platform at jillie.club.

This Policy applies to all personal data processed by jillie in connection with your use of the jillie platform, including data collected through the jillie website, mobile-optimised browser interfaces, customer support communications, and payment transactions. It does not apply to data practices of third-party game providers, payment processors, or other external services that have their own, separate privacy policies.

By registering a jillie account and accepting the jillie Terms and Conditions, you acknowledge that you have read this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, you should not register or continue to use the jillie platform.

jillie is the personal information controller ("PIC") as defined under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) with respect to all personal data processed in connection with the jillie platform. As PIC, jillie determines the purposes and means of processing your personal data and is accountable for ensuring that all processing activities comply with applicable Philippine data privacy law and regulations issued by the National Privacy Commission ("NPC").

For all data privacy enquiries, requests to exercise your data subject rights, or formal complaints related to jillie's handling of your personal data, please contact jillie's designated Data Protection Officer at: [email protected] with the subject line "Data Privacy Request."

jillie collects and processes the following categories of personal data from registered players and platform visitors:

jillie collects personal data through the following channels and mechanisms:

• Direct Registration: Information you provide when creating a jillie account, including your name, Philippine mobile number, email address, and date of birth.
• Identity Verification: Government-issued ID documents submitted in response to jillie's KYC verification requests, either at registration or upon reaching transaction thresholds set by PAGCOR guidelines.
• Transaction Processing: Financial data generated when you make deposits via GCash, Maya, bank transfer, or other accepted Philippine payment methods, and when you request withdrawals.
• Platform Use: Technical and gaming data automatically generated as you navigate the jillie platform, access games, and interact with platform features.
• Customer Support: Information you provide when contacting jillie's support team via live chat or email, including descriptions of account issues or game disputes.
• Cookies and Tracking Technologies: Data collected automatically through browser cookies, session tokens, and similar technologies as described in Section 10 of this Policy.
• Third-Party Sources: In limited circumstances, jillie may receive personal data from Philippine payment processors confirming transaction completion, or from fraud prevention and identity verification service providers.

jillie processes your personal data for the following specific purposes, each of which is necessary to deliver the jillie platform to you or to comply with legal obligations applicable to jillie as a Philippine gaming platform:

1. Account Creation and Management: To register your jillie account, verify your identity and age (21+), maintain your account records, and manage your login security.
2. Platform Service Delivery: To provide access to jillie's games, process bets and game results, credit winnings to your wallet, and maintain your game history.
3. Payment Processing: To process GCash deposits, Maya top-ups, bank transfers, InstaPay transactions, and withdrawal requests accurately and securely.
4. Regulatory Compliance: To meet jillie's obligations under PAGCOR regulations for licensed online gaming operators, the Anti-Money Laundering Act of 2001 (Republic Act No. 9160 as amended), and the Philippine Data Privacy Act. This includes filing reports with the Anti-Money Laundering Council (AMLC) where required by law.
5. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, account takeovers, money laundering, and abuse of promotional offers on the jillie platform.
6. Responsible Gaming: To monitor gaming behaviour for signs of problem gambling, enforce responsible gaming limits set by players, and act on self-exclusion requests in accordance with jillie's Responsible Gaming Policy.
7. Customer Support: To respond to your enquiries, resolve game disputes, process account requests, and improve jillie's support quality.
8. Platform Improvement: To analyse aggregated, anonymised usage data to improve the performance, stability, and user experience of the jillie platform for Filipino players.
9. Marketing Communications: To send you information about jillie promotions, new games, and platform updates — but only where you have given your explicit consent to receive marketing communications, and subject to your right to withdraw that consent at any time.

Under the Philippine Data Privacy Act, jillie relies on the following legal bases for processing your personal data:

• Consent: For optional data processing activities such as marketing communications, you provide explicit consent at the point of data collection, which you may withdraw at any time without affecting the lawfulness of prior processing.
• Contract Performance: Processing necessary to deliver the jillie platform services to you under the jillie Terms and Conditions — including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR regulations, AMLC reporting requirements under the Anti-Money Laundering Act, data retention obligations, and any court or regulatory order directing disclosure.
• Legitimate Interests: Processing undertaken to protect jillie's legitimate interests in platform security, fraud prevention, and responsible gaming monitoring, where those interests are not overridden by your fundamental privacy rights.

jillie does not sell your personal data to third-party commercial advertisers or data brokers. jillie may disclose your personal data to the following categories of recipients where necessary and lawful:

• Payment Service Providers: GCash (GXI Inc.), Maya (Voyager Innovations), participating Philippine banks (BPI, BDO, Metrobank), and InstaPay/PesoNet network operators, solely to the extent required to process your deposits and withdrawals.
• Game Technology Providers: Third-party game studios and RNG certification bodies that supply game software or live dealer streaming to the jillie platform, who process game session data to deliver game results.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where jillie is required to disclose information by law, court order, or regulatory directive.
• Identity and Fraud Verification Services: Third-party KYC and fraud detection providers engaged by jillie to verify player identities and detect suspicious transactions, who act as data processors under jillie's instructions.
• IT and Cloud Service Providers: Infrastructure and hosting providers who store and process jillie platform data on servers located in secure data centres, operating under contractual data processing agreements that require compliance with Philippine data privacy standards.
• Professional Advisers: Legal counsel, auditors, and compliance advisers who are subject to professional confidentiality obligations and access personal data only to the extent necessary for their engagement.

All third parties who process personal data on jillie's behalf are required to handle that data in accordance with applicable Philippine privacy law and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

jillie retains personal data for only as long as is necessary for the purpose for which it was collected, or as required by Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of the active account relationship plus a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLC record-keeping obligations.
• Gaming Session Data: Retained for a minimum of three (3) years from the date of the session, for the purpose of dispute resolution, responsible gaming monitoring, and regulatory audit.
• Customer Support Records: Retained for three (3) years from the date of the most recent support interaction, for quality assurance and dispute documentation purposes.
• Marketing Consent Records: Retained for the duration of the marketing relationship plus three (3) years to demonstrate consent compliance.
• Technical and Log Data: Retained for twelve (12) months from collection, unless specific records are required for an active investigation or regulatory inquiry.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymised, or aggregated in a manner that permanently prevents re-identification. Where data cannot be immediately deleted due to technical constraints, jillie will isolate and cease active processing of that data pending deletion at the next practicable scheduled purge cycle.

jillie implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and jillie's servers is protected using TLS 1.2 or higher (256-bit SSL encryption), the same standard used by Philippine digital banks including BPI and BDO online banking.
• Encryption at Rest: Sensitive personal data — including financial details, identity document references, and authentication credentials — is encrypted at rest using industry-standard AES-256 encryption in jillie's database infrastructure.
• Password Security: jillie stores passwords as one-way cryptographic hashes using a modern, salted hashing algorithm. jillie staff cannot view your password in plain text under any circumstances.
• Two-Factor Authentication: OTP-based two-factor authentication is applied to account logins from new or unrecognised devices, protecting your jillie account even in the event that your password is compromised.
• Access Controls: Access to personal data within jillie's operations is restricted on a need-to-know basis. Staff who access player data are subject to confidentiality obligations and access logging.
• Security Monitoring: jillie maintains continuous monitoring of its platform infrastructure for intrusion attempts, unusual access patterns, and other indicators of security compromise.
• Data Breach Response: jillie maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, jillie will notify the National Privacy Commission and affected players within the timeframes required under the Philippine Data Privacy Act.

jillie uses cookies and similar tracking technologies to operate the platform, maintain your login session, and gather aggregated usage analytics. The following types of cookies are used on jillie:

• Strictly Necessary Cookies: Essential session cookies that maintain your login state, carry your wallet balance display, and ensure secure navigation across the jillie platform. These cookies cannot be disabled without preventing normal platform use.
• Functional Cookies: Cookies that remember your language preference, game lobby display settings, and responsible gaming notification preferences to improve your jillie experience across sessions.
• Analytics Cookies: Anonymised or pseudonymised cookies that help jillie understand how players navigate the platform — for example, which game categories are most used and where players encounter friction. jillie uses this data only for internal platform improvement, not for advertising profiling.
• Security Cookies: Short-lived tokens used for CSRF protection, session integrity verification, and fraud detection signals associated with your device and browser environment.

jillie does not use third-party advertising cookies or permit external ad networks to set cookies through the jillie platform. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to use the jillie platform. Guidance on managing cookies in Chrome, Safari, Firefox, and other browsers used by Filipino players is available through your browser's help documentation.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jillie. jillie will respond to all properly submitted data subject rights requests within thirty (30) days of receipt, or within such shorter period as may be required by the NPC.

To exercise any of the rights above, please submit a written request to [email protected] with the subject line "Data Privacy Request" and include your registered mobile number and a description of the right you wish to exercise. jillie may require you to verify your identity before processing your request.

The jillie platform is strictly restricted to persons who are 21 years of age or older. jillie does not knowingly collect, process, or store personal data from persons under 21 years of age. If jillie discovers or has reasonable grounds to suspect that an account is held by a person under 21, that account will be immediately suspended and jillie will take steps to delete the personal data associated with that account in accordance with applicable law, retaining only such records as are necessary for legal and regulatory compliance purposes.

If you are a parent or guardian and believe that a person under 21 in your care has registered a jillie account, please contact jillie's support team at [email protected] immediately. jillie will investigate and act on all such reports promptly.

Some of jillie's third-party service providers — including certain game technology suppliers and cloud infrastructure providers — may process personal data on servers located outside the Philippines. Where such cross-border transfers occur, jillie takes steps to ensure that adequate safeguards are in place to protect your personal data to a standard consistent with the Philippine Data Privacy Act. These safeguards may include contractual clauses that require the overseas recipient to apply equivalent data protection standards, or transfers to jurisdictions that have been determined to provide an adequate level of data protection.

By using the jillie platform and accepting this Privacy Policy, you consent to the transfer of your personal data to overseas recipients where required for the delivery of jillie's services, subject to the safeguards described above.

jillie reviews and updates this Privacy Policy periodically to reflect changes in jillie's data processing practices, changes to Philippine data privacy law or PAGCOR regulations, or developments in technology and security best practices. Material changes — meaning changes that significantly affect the way jillie processes your personal data or your rights as a data subject — will be communicated via in-platform notification and, where practicable, via your registered email address, at least fourteen (14) days before the revised Policy takes effect.

The effective date of the current version of this Policy is displayed prominently at the top of this page. We encourage you to review this Policy periodically to stay informed about how jillie is protecting your personal data. Your continued use of the jillie platform following the effective date of any revision constitutes your acknowledgment of the updated Policy.

For all questions about this Privacy Policy, requests to exercise your data subject rights, or concerns about jillie's handling of your personal data, please contact jillie's Data Protection Officer through the following channel:

• Email: [email protected] — Subject line: "Data Privacy Request"
• Live Chat: Available 24/7 through the jillie platform dashboard after login — ask to be connected to the Data Privacy team
• Response Time: jillie will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days

If you are not satisfied with jillie's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC handles complaints from Filipino data subjects against personal information controllers for violations of the Philippine Data Privacy Act. Information about the NPC complaints process is available through the NPC's official website.