36jili Privacy Policy

1 Introduction

At 36jili, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy has been drafted in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations ("DPA 2012"), as well as applicable regulations issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and the Anti-Money Laundering Council (AMLC).

This Policy applies to all users of the 36jili platform, including visitors, registered players, and any person who interacts with our website, mobile applications, customer support channels, or promotional communications. We encourage you to read this Policy carefully and to contact us if you have any questions regarding how your personal data is collected or processed.

By continuing to use the 36jili platform, you consent to the data practices described in this Privacy Policy. If you do not agree with any part of this Policy, you should discontinue use of our services immediately.

2 Data Controller

36jili acts as the data controller for all personal information collected through the 36jili platform. As data controller, 36jili determines the purposes and means of processing your personal data and is responsible for ensuring that all processing activities comply with applicable data protection laws.

For all data privacy inquiries, requests to exercise your rights under the DPA 2012, or complaints regarding data processing, you may contact our Data Protection Officer at the contact details provided in Section 14 of this Policy.

3 Information We Collect

36jili collects various categories of personal information to provide, secure, and improve our services. The types of information we collect include:

3.1 Information You Provide Directly

• Registration Information: Full name, date of birth, gender, email address, Philippine mobile number, residential address, and chosen username and password.
• Identity Verification Documents: Government-issued identification documents (e.g., Philippine Passport, PhilSys National ID, Driver's License, SSS/GSIS ID) and proof of address documents (e.g., utility bills, bank statements) required for KYC (Know Your Customer) compliance.
• Payment Information: GCash, Maya, or bank account details, transaction history, deposit and withdrawal records, and payment method identifiers. Credit/debit card information, if provided, is processed by secure third-party payment processors and is not stored on 36jili servers.
• Communications: Content of your communications with 36jili customer support, including chat transcripts, emails, and telephone call recordings (where permitted by law and with prior notice).
• Survey and Feedback Data: Responses to customer satisfaction surveys, promotional questionnaires, and feedback forms.

3.2 Information We Collect Automatically

• Device Information: IP address, browser type and version, operating system, device identifiers (IMEI, MAC address), screen resolution, and device language settings.
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, click paths, referral URLs, and time stamps of all account activity.
• Location Data: Approximate geographic location derived from your IP address to ensure compliance with geographic restrictions and regulatory requirements.
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, pixel tags, and similar technologies as described in Section 9.

3.3 Information from Third Parties

36jili may receive information about you from third-party sources, including payment processors (e.g., GCash, Maya), identity verification service providers, fraud prevention agencies, and publicly available sources such as social media profiles (only if you choose to link your account). Third-party data is used solely to verify your identity, prevent fraud, and comply with legal obligations.

4 How We Use Your Data

36jili processes your personal information for the following purposes:

• Account Management: To create and maintain your 36jili account, authenticate your identity, and process your login credentials.
• Transaction Processing: To process deposits, withdrawals, and other financial transactions, and to maintain accurate financial records.
• Service Delivery: To provide access to casino games, live dealer tables, slots, sports betting, and other gaming services available on the platform.
• Customer Support: To respond to your inquiries, resolve technical issues, handle disputes, and provide assistance through live chat, email, or telephone support.
• Identity Verification and KYC: To verify your age (21+ requirement), identity, and address in compliance with PAGCOR regulations and anti-money laundering (AML) laws.
• Fraud Prevention and Security: To detect, prevent, and investigate fraudulent activity, unauthorized access, money laundering, match-fixing, collusion, and other prohibited conduct.
• Regulatory Compliance: To comply with legal obligations imposed by PAGCOR, the AMLC, the National Privacy Commission, and other regulatory authorities, including record-keeping, reporting, and audit requirements.
• Marketing and Promotions: To send promotional offers, bonuses, newsletters, and marketing communications (where you have provided consent or where permitted by law). You may opt out of marketing communications at any time.
• Analytics and Improvement: To analyze user behavior, improve our platform's functionality, optimize game offerings, and enhance user experience.
• Responsible Gaming: To monitor gaming patterns, identify signs of problem gambling, and enforce deposit limits, loss limits, and self-exclusion measures.

5 Legal Basis for Processing

Under the DPA 2012, 36jili processes your personal data based on one or more of the following legal grounds:

• Consent: You have given explicit consent for us to process your personal data for a specific purpose (e.g., receiving marketing communications).
• Contractual Necessity: Processing is necessary for the performance of the contract between you and 36jili, including the Terms & Conditions governing your use of the platform.
• Legal Obligation: Processing is required to comply with a legal obligation to which 36jili is subject, including KYC requirements, AML regulations, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for 36jili's legitimate business interests, such as fraud prevention, network security, and business analytics, provided such interests are not overridden by your fundamental rights and freedoms.

6 Data Sharing & Disclosure

36jili does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality and data protection obligations:

6.1 Service Providers

We engage third-party service providers to perform functions on our behalf, including payment processing (GCash, Maya, bank partners), identity verification services, cloud hosting providers, customer support platforms, and analytics tools. These service providers have access only to the data necessary to perform their functions and are contractually obligated to protect your information.

6.2 Game Providers

Your gaming activity data (e.g., bets placed, games played, win/loss records) may be shared with third-party game providers such as JILI Games, PG Soft, Pragmatic Play, Evolution Gaming, and others to facilitate gameplay and ensure game integrity. Game providers process this data under their own privacy policies and are required to comply with applicable data protection standards.

6.3 Regulatory Authorities

36jili may be required to disclose your personal data to PAGCOR, the AMLC, the Bureau of Internal Revenue (BIR), the National Privacy Commission, law enforcement agencies, or courts of law when required by applicable laws, regulations, legal processes, or governmental requests. Such disclosures are made only to the extent necessary to comply with the legal obligation.

6.4 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor as part of the transaction. In such cases, 36jili will notify affected users and ensure that the receiving party agrees to handle your data in accordance with this Privacy Policy.

6.5 Affiliate and Partner Programs

If you were referred to 36jili through an affiliate or marketing partner, we may share limited information (e.g., registration confirmation, deposit activity) with that partner for commission tracking purposes. No sensitive personal information is shared in these cases.

7 Data Security

36jili employs industry-standard technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• 256-Bit SSL Encryption: All data transmitted between your device and 36jili servers is encrypted using 256-bit Secure Socket Layer (SSL) technology.
• Secure Data Storage: Personal data is stored on secure servers with restricted access. Passwords are hashed using advanced cryptographic algorithms and are never stored in plain text.
• Access Controls: Access to personal data is limited to authorized 36jili personnel who require the information to perform their job functions. All employees are bound by confidentiality agreements.
• Regular Security Audits: 36jili conducts regular security audits, vulnerability assessments, and penetration testing to identify and address potential security risks.
• Firewall and Intrusion Detection: Our servers are protected by firewalls and intrusion detection systems to prevent unauthorized access and cyberattacks.
• Two-Factor Authentication (2FA): Players are encouraged to enable 2FA on their accounts for an additional layer of security.

While 36jili takes all reasonable measures to protect your data, no method of transmission over the internet or electronic storage is 100% secure. 36jili cannot guarantee absolute security and is not liable for unauthorized access resulting from circumstances beyond our reasonable control, such as hacking by malicious third parties or force majeure events.

8 Data Retention

36jili retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal and regulatory obligations. The retention periods for different categories of data are as follows:

• Account Data: Retained for the duration of your account's active status and for up to seven (7) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements.
• Transaction Records: Retained for a minimum of seven (7) years following the transaction date to comply with AML and tax regulations.
• Identity Verification Documents: Retained for seven (7) years following account closure or the last KYC update, whichever is later.
• Customer Support Communications: Retained for up to three (3) years following the date of the communication for quality assurance and dispute resolution purposes.
• Marketing Communications: Retained until you withdraw consent or opt out of receiving marketing materials, after which your contact information is removed from marketing lists within thirty (30) days.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents recovery or reconstruction. If you request deletion of your data before the end of the retention period, 36jili may be unable to comply if retention is required by law.

9 Cookies & Tracking Technologies

36jili uses cookies and similar tracking technologies to enhance your user experience, analyze site traffic, and deliver personalized content. A "cookie" is a small text file stored on your device by your web browser. The types of cookies used by 36jili include:

9.1 Essential Cookies

These cookies are necessary for the operation of the 36jili platform. They enable core functionality such as user authentication, session management, and secure access to your account. Without these cookies, the platform cannot function properly.

9.2 Functional Cookies

Functional cookies remember your preferences (e.g., language selection, display settings) and provide enhanced features such as live chat support. These cookies improve your user experience but are not essential for basic platform operation.

9.3 Analytics Cookies

Analytics cookies collect information about how visitors use the 36jili platform, including pages visited, time spent on each page, and navigation paths. This data is aggregated and anonymized and is used to improve site performance and user experience. 36jili may use third-party analytics tools such as Google Analytics for this purpose.

9.4 Marketing Cookies

Marketing cookies track your activity across the 36jili platform and other websites to deliver targeted advertisements and promotional content. These cookies are set only with your consent and can be disabled through your browser settings or cookie preference center.

9.5 Managing Cookies

You can manage or disable cookies through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the 36jili platform. For instructions on managing cookies in your browser, please refer to your browser's help documentation.

10 Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal data:

• Right to Be Informed: You have the right to be informed about the collection, use, and processing of your personal data. This Privacy Policy serves as the primary disclosure of our data practices.
• Right to Access: You have the right to obtain confirmation of whether 36jili is processing your personal data and to access a copy of that data. You may request access by contacting our Data Protection Officer.
• Right to Rectification: You have the right to correct inaccurate or incomplete personal data. You can update most account information directly through your 36jili account settings. For changes to verified identity documents, please contact customer support.
• Right to Erasure (Right to Be Forgotten): You have the right to request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. Erasure requests are subject to legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data where processing is based on legitimate interests or for direct marketing purposes. To opt out of marketing communications, use the unsubscribe link in any promotional email or contact customer support.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another data controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted before withdrawal.
• Right to Lodge a Complaint: If you believe 36jili has violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 14. 36jili will respond to your request within fifteen (15) business days, or within the timeframe prescribed by applicable law, whichever is shorter.

11 Third-Party Links

The 36jili platform may contain links to third-party websites, including payment processors, game providers, and social media platforms. 36jili is not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party site you visit.

When you click on a third-party link or interact with a third-party service (e.g., logging in via Facebook), you may be subject to that third party's terms of service and privacy policy. 36jili has no control over and assumes no responsibility for third-party data practices.

12 Children's Privacy

If 36jili becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such information and terminate the associated account. If you believe that 36jili has inadvertently collected data from a minor, please contact us immediately at the details provided in Section 14.

13 Changes to This Privacy Policy

36jili reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When material changes are made, 36jili will update the "Last Updated" date at the top of this page and, where practicable, provide notice to registered users through in-platform notifications or email.

It is your responsibility to review this Privacy Policy periodically. Your continued use of the 36jili platform following the posting of changes constitutes your acceptance of those changes. If you do not agree with the revised Privacy Policy, you must cease using the platform and may request account closure in accordance with our Terms & Conditions.

14 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or 36jili's data processing practices, or if you wish to exercise any of your privacy rights, please contact our Data Protection Officer:

• Email: [email protected]
• Customer Support Email: [email protected]
• Live Chat: Available 24/7 through the 36jili platform

36jili is committed to resolving all privacy-related inquiries and complaints promptly and fairly. We will acknowledge receipt of your request within three (3) business days and endeavor to provide a substantive response within fifteen (15) business days.

If you are not satisfied with our response, you have the right to file a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission
• 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto Street, Pasay City, Metro Manila 1307, Philippines
• Email: [email protected]
• Website: privacy.gov.ph