jililo Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how jililo ("jililo," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "Member," or "User") who access or use the jililo platform at jililo.app and any associated services.

jililo is committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner. This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable PAGCOR data governance requirements.

By registering a jililo account or using any jililo service, you acknowledge that you have read and understood this 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 jililo.

2. Personal Data We Collect

jililo collects personal data in the following categories:

• Identity Data: Full legal name, date of birth, nationality, and government-issued ID details (e.g., Philippine passport, SSS, UMID, driver's licence, PhilSys ID) collected during account registration and KYC verification.
• Contact Data: Philippine mobile number, email address, and residential address.
• Financial Data: GCash number, Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details, transaction history, deposit and withdrawal records.
• Account Data: Username, encrypted password, account preferences, gaming history, bonus usage, and session logs.
• Technical Data: IP address, device type, browser type and version, operating system, time zone, and cookies or similar tracking identifiers.
• Usage Data: Pages visited on jililo.app, games played, session duration, click patterns, and referral source.
• Communications Data: Records of your interactions with jililo's customer support team, including live chat transcripts and email correspondence.

jililo collects this data directly from you during registration and account use, automatically through cookies and analytics tools, and from third-party identity verification and payment processing partners.

3. How We Use Your Personal Data

jililo uses your personal data for the following purposes:

• To create and manage your jililo account and verify your identity in accordance with PAGCOR KYC requirements.
• To process deposits, withdrawals, and other financial transactions through your registered Philippine payment methods.
• To provide access to jililo's games, features, and services, and to personalise your gaming experience.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities in compliance with the Anti-Money Laundering Act (RA 9160).
• To send you account-related notifications, security alerts, and service updates via SMS or email.
• To send you promotional communications about jililo bonuses and offers, where you have consented to receive such communications.
• To analyse platform usage and improve jililo's games, features, and user experience.
• To comply with applicable Philippine laws, regulations, and PAGCOR directives.
• To enforce jililo's Terms & Conditions and resolve disputes.

4. Legal Basis for Processing

jililo processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to fulfil our obligations to you under the jililo Terms & Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with Philippine laws, including KYC verification, anti-money laundering reporting, and PAGCOR regulatory requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

5. Data Sharing and Disclosure

jililo does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only where necessary and lawful:

• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and age in compliance with PAGCOR requirements.
• Payment processors: Philippine payment service providers (GCash, Maya, and partner banks) used to process your deposits and withdrawals.
• Game providers: Licensed game software providers whose titles are available on jililo, to the extent necessary to deliver game services.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulatory directive.
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate criminal activity.
• Service providers: IT infrastructure, analytics, customer support, and security vendors engaged by jililo under strict data processing agreements that prohibit further disclosure or use of your data.

All third parties with whom jililo shares personal data are required to handle it in accordance with applicable Philippine data protection laws and jililo's data security standards.

6. Cookies and Tracking Technologies

jililo uses cookies and similar tracking technologies on jililo.app to operate the platform, remember your preferences, analyse usage patterns, and deliver relevant content. The following types of cookies are used:

• Essential cookies: Required for the platform to function, including session management and security features. These cannot be disabled.
• Analytics cookies: Used to understand how members use jililo.app, which pages are most visited, and where improvements can be made. Data collected is aggregated and anonymised.
• Preference cookies: Used to remember your language, display, and notification preferences across sessions.
• Marketing cookies: Used to deliver relevant promotional content about jililo, where you have consented. You may opt out at any time through your account settings or browser controls.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use jililo's core gaming services.

7. Data Retention

jililo retains your personal data for as long as your account is active and for a period thereafter as required by Philippine law. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years in accordance with the Anti-Money Laundering Act.
• Communications data: Retained for up to two (2) years from the date of the communication, unless required for longer by an ongoing investigation or legal proceeding.
• Technical and usage data: Retained for up to twelve (12) months, after which it is aggregated or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

8. Data Security

jililo 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:

• SSL/TLS encryption for all data transmitted between your device and jililo.app.
• AES-256 encryption for sensitive personal and financial data stored on jililo's servers.
• Multi-factor authentication options for jililo account access.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need.
• Comprehensive security awareness training for all jililo staff who handle personal data.

While jililo takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your jililo login credentials and for notifying us immediately if you suspect unauthorised access to your account.

9. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by jililo:

• Right to be informed: You have the right to know what personal data jililo collects about you and how it is used, as described in this Policy.
• Right of access: You may request a copy of the personal data jililo holds about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data in your jililo account.
• 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 jililo's legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe jililo has not handled your personal data in accordance with Philippine law.

To exercise any of these rights, please contact jililo's Data Protection Officer using the contact details in Section 13 of this Policy. We will respond to all verified data subject requests within thirty (30) days.

10. Children's Privacy

jililo's services are strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations. jililo does not knowingly collect personal data from individuals under the age of 21.

If jililo becomes aware that personal data has been collected from a person under 21, the relevant account will be immediately suspended and the data will be deleted. If you believe a minor has registered a jililo account, please contact us immediately at privacy@jililo.app so we can take prompt action.

11. International Data Transfers

jililo's primary data processing infrastructure is located within the Philippines. Where it is necessary to transfer your personal data to service providers or partners located outside the Philippines — for example, to international game software providers or cloud infrastructure vendors — jililo ensures that such transfers are conducted in accordance with the requirements of the Philippine Data Privacy Act.

Specifically, jililo requires all international data recipients to implement data protection standards equivalent to those required under Philippine law, through contractual data processing agreements, and will only transfer data to jurisdictions that provide an adequate level of data protection.

12. Updates to This Privacy Policy

jililo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. The date of the most recent revision is indicated at the top of this page.

Where changes are material, jililo will notify registered members via email or an in-platform notification prior to the changes taking effect. Your continued use of jililo following the effective date of any update constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how jililo protects your personal information.

13. Contact and Data Protection Officer

jililo has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy and the Philippine Data Privacy Act. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact our DPO:

Data Protection Officer — jililo

Email: privacy@jililo.app

General support: support@jililo.app

Our support and privacy teams are available 24/7 and can assist you in both English and Filipino. We aim to acknowledge all privacy-related enquiries within 72 hours and to resolve them within 30 days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.