Privacy Policy — How 991jili.com Collects, Uses, and Protects Your Personal Data

1. Introduction

991jili.com ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all users ("you," "your," or "Player") who access or use our online gaming services. We understand that Filipino players entrust us with sensitive personal and financial information, and we take that responsibility seriously.

This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (DPA), its Implementing Rules and Regulations (IRR), and the guidelines issued by the National Privacy Commission (NPC). It also reflects applicable international best practices for data protection in the online gaming industry.

This Policy should be read alongside our Terms & Conditions, which govern your overall use of the 991jili.com Platform. Defined terms used but not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data We Collect

991jili.com collects the following categories of personal data from players and visitors:

2.1 Identity & Contact Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (to verify the 21+ age requirement);
• Nationality and country of residence;
• Mobile number and email address;
• Residential address (barangay, city/municipality, province, ZIP code).

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, UMID, PhilSys National ID, driver's license, PRC ID);
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie photographs submitted for liveness verification;
• Source of funds declarations where required by AML regulations.

2.3 Financial Data

• GCash mobile number or PayMaya account details;
• Bank account details (BPI, BDO, Metrobank, UnionBank, or other Philippine banks) where used for deposits or withdrawals;
• Transaction history, including deposit amounts, withdrawal requests, and timestamps;
• Bonus and promotional credit history.

2.4 Gaming & Behavioural Data

• Game session logs, including games played, wager amounts, wins, and losses;
• Login timestamps, session durations, and device information;
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, cooling-off periods);
• Customer support interaction records.

2.5 Technical Data

• IP address and approximate geolocation;
• Browser type and version, operating system, and device identifiers;
• Cookies, pixel tags, and similar tracking technologies (see Section 7);
• Referral source and navigation paths within the Platform.

3. How We Collect Data

991jili.com collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and behavioural data collected automatically when you access or use the Platform, including through cookies, server logs, and analytics tools;
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment data from GCash, PayMaya, and banking partners;
• Publicly available sources: Information from public records or databases used for fraud prevention and regulatory compliance purposes.

4. How We Use Your Data

991jili.com processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your 991jili.com account;
• Identity verification: Confirming your identity and age (21+) in compliance with PAGCOR regulations and Philippine law;
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods;
• Regulatory compliance: Meeting our obligations under anti-money laundering (AML), counter-terrorism financing (CTF), and PAGCOR reporting requirements;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, cheating, and unauthorized account access;
• Responsible gaming: Monitoring gaming behaviour to identify potential problem gambling patterns and administering self-exclusion and limit-setting tools;
• Customer support: Responding to your queries, complaints, and support requests;
• Platform improvement: Analysing usage patterns to improve the Platform's features, performance, and user experience;
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates — only where you have provided consent or where permitted by applicable law. You may opt out at any time;
• Legal proceedings: Establishing, exercising, or defending legal claims.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its IRR, 991jili.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you (i.e., providing gaming services, processing payments, managing your account);
• Legal obligation: Processing required to comply with applicable laws, including AML regulations, PAGCOR requirements, and NPC guidelines;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

991jili.com does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, B DO, Metrobank, and other payment partners, for the purpose of processing your deposits and withdrawals;
• KYC and identity verification providers: Third-party services that assist in verifying your identity and age in compliance with regulatory requirements;
• AML and fraud screening providers: Compliance technology partners that help us detect and prevent money laundering, fraud, and other prohibited activities;
• Game software providers: Licensed game studios and aggregators whose games are available on the 991jili.com Platform, to the extent necessary for game operation and dispute resolution;
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under strict data processing agreements;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where disclosure is required by law or regulatory order;
• Legal and professional advisers: Lawyers, auditors, and accountants, subject to professional confidentiality obligations;
• Business successors: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7. Cookies & Tracking Technologies

991jili.com uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage, and deliver relevant content. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function, including session management, login authentication, and security features. These cannot be disabled;
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming limits you have set;
• Analytics cookies: Collect anonymised data about how players use the Platform to help us improve performance and user experience;
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our campaigns. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For full details, refer to our Cookie Policy, which is available on the Platform.

8. Data Retention

991jili.com retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Specifically:

• Account and KYC data is retained for a minimum of five (5) years from the date of account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• Transaction records are retained for a minimum of five (5) years from the date of each transaction;
• Customer support records are retained for three (3) years from the date of the interaction;
• Marketing consent records are retained for as long as you remain a registered player and for two (2) years after account closure;
• Technical and log data is typically retained for twelve (12) months, unless required for longer periods for security or legal purposes.

When personal data is no longer required, it is securely deleted or anonymised in accordance with our data disposal procedures.

9. Data Security

991jili.com implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest, including financial and identity verification records;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication for internal systems and administrative access;
• Regular penetration testing and vulnerability assessments conducted by independent security specialists;
• 24/7 security monitoring and intrusion detection systems;
• Staff training on data protection obligations and security best practices.

10. Your Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 991jili.com:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy;
• Right of access: You may request a copy of the personal data we hold about you, along with information about how it is being processed;
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you;
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time, and to processing based on legitimate interests where your rights override those interests;
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to withdraw consent: Where processing is based on your consent, you may 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) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified requests within thirty (30) days, as required by the DPA IRR.

11. Children's Privacy

991jili.com is strictly an adult platform. In the Philippines, the minimum legal age to participate in casino-style gambling is 21 years old. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that a person under 21 has registered an account or provided personal data, we will immediately suspend the account, delete the associated data, and report the incident as required by applicable regulations.

If you are a parent or guardian and believe that a minor has accessed or registered on 991jili.com, please contact us immediately at the details provided in Section 15.

12. Third-Party Links

The 991jili.com Platform may contain references to third-party services such as payment processors and game providers. These third parties operate under their own privacy policies, and 991jili.com is not responsible for their data practices. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the Platform.

13. International Data Transfers

Some of 991jili.com's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, 991jili.com ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law. Such transfers are conducted in compliance with the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers.

14. Changes to This Privacy Policy

991jili.com 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 email or a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable. The "Last Updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer (DPO):

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated. The NPC can be reached through its official government channels.