Privacy Policy – jilima Data Protection Statement

1. Information We Collect

To provide you with secure and personalized gaming services, jilima collects several categories of personal information. The types of data we collect include:

1.1 Information You Provide Directly

When you register for a jilima account, participate in promotions, or communicate with customer support, you voluntarily provide us with personal information, including:

• Identity Information: Full name, date of birth, gender, nationality, and government-issued identification documents (passport, driver's license, national ID) for age and identity verification purposes.
• Contact Information: Email address, mobile phone number, residential address, and postal code.
• Financial Information: Payment method details (GCash account number, Maya account number, bank account information), transaction history, deposit and withdrawal records, and billing information.
• Authentication Credentials: Username, password, security questions and answers, and two-factor authentication settings.
• Communication Data: Messages you send through customer support channels, chat logs, email correspondence, and feedback submissions.

1.2 Information Collected Automatically

When you access or use the jilima platform, we automatically collect certain technical and usage data, including:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, UDID, advertising ID), and mobile network information.
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, click patterns, search queries, and referral sources.
• Location Data: IP address, geolocation data (approximate location based on IP address), and time zone information.
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, pixels, and similar technologies to track user behavior, preferences, and session information. You can control cookie settings through your browser, but disabling certain cookies may limit platform functionality.

1.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction verification, fraud detection data, and payment success/failure information from GCash, Maya, and other payment partners.
• Identity Verification Services: Verification results from third-party KYC (Know Your Customer) providers used to confirm your identity and age.
• Marketing Partners: Referral information, affiliate data, and campaign performance metrics from authorized marketing partners.
• Social Media Platforms: If you choose to connect your jilima account with social media accounts, we may receive profile information you authorize us to access.

2. How We Use Your Information

jilima uses your personal information for the following purposes:

2.1 Account Management and Service Delivery

• Creating, managing, and maintaining your jilima account;
• Verifying your identity and age to comply with legal requirements (21+ age restriction);
• Processing deposits, withdrawals, and other financial transactions;
• Providing access to games, sports betting markets, and other platform features;
• Tracking gaming activity, account balances, and transaction history;
• Delivering customer support and responding to your inquiries.

2.2 Security and Fraud Prevention

• Detecting, preventing, and investigating fraudulent activity, money laundering, and other illegal conduct;
• Monitoring for unauthorized access, account takeovers, and suspicious betting patterns;
• Enforcing our Terms & Conditions and preventing abuse of bonuses and promotions;
• Complying with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations;
• Protecting the security and integrity of the jilima platform and our users.

2.3 Personalization and Marketing

• Personalizing your gaming experience based on your preferences, play history, and device type;
• Recommending games, betting markets, and promotions that match your interests;
• Sending promotional offers, bonuses, newsletters, and marketing communications via email, SMS, push notifications, and in-app messages (you may opt out at any time);
• Conducting market research, surveys, and analysis to improve our services;
• Measuring the effectiveness of our marketing campaigns and affiliate partnerships.

2.4 Legal and Regulatory Compliance

• Complying with applicable gaming laws, regulations, and licensing requirements in the Philippines;
• Responding to legal requests, court orders, subpoenas, and government inquiries;
• Maintaining records required by law or regulatory authorities;
• Reporting suspicious transactions to relevant authorities as required by AML/CTF regulations;
• Enforcing our legal rights and defending against legal claims.

2.5 Platform Improvement and Analytics

• Analyzing user behavior and platform performance to identify bugs, errors, and areas for improvement;
• Conducting A/B testing and usability studies to enhance user experience;
• Developing new features, games, and services based on user feedback and usage patterns;
• Generating aggregated and anonymized statistics for internal business purposes.

3. Legal Basis for Processing

Under the Data Privacy Act of 2012 and other applicable laws, jilima processes your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you under the Terms & Conditions, including account management, transaction processing, and service delivery.
• Legal Obligation: Processing is required to comply with legal and regulatory obligations, including age verification, AML/CTF compliance, and responding to lawful requests from authorities.
• Consent: You have provided explicit consent for specific processing activities, such as receiving marketing communications or connecting social media accounts.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform improvement, and customer support, provided such interests are not overridden by your fundamental rights and freedoms.

4. Data Sharing and Disclosure

jilima does not sell your personal information to third parties. However, we may share your data with the following categories of recipients for the purposes described in this Privacy Policy:

4.1 Service Providers and Business Partners

• Payment Processors: GCash, PayMaya, banks, and other payment service providers that facilitate deposits and withdrawals.
• Game Providers: Third-party software providers (Pragmatic Play, PG Soft, Evolution Gaming, etc.) whose games and live dealer services are integrated into the jilima platform.
• Identity Verification Services: KYC and AML compliance providers that verify user identities and screen for fraud.
• Cloud Hosting Providers: Infrastructure and hosting services that store and process data on our behalf.
• Customer Support Tools: Live chat platforms, helpdesk software, and CRM systems used to manage customer inquiries.
• Marketing and Analytics Partners: Advertising networks, affiliate platforms, email service providers, and analytics tools used to deliver and measure marketing campaigns.

All third-party service providers are contractually obligated to protect your data, use it only for specified purposes, and comply with applicable data protection laws.

4.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, regulators, law enforcement, and courts when required by law, legal process, or regulatory obligation. This includes disclosures related to:

• Compliance with subpoenas, court orders, and lawful requests for information;
• Reporting suspicious transactions under AML/CTF regulations;
• Cooperating with investigations into fraud, money laundering, or other criminal activity;
• Protecting the rights, property, and safety of jilima, our users, and the public.

4.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or other corporate transaction, your personal information may be transferred to the acquiring entity. We will notify you of any such transfer and provide you with choices regarding your data if required by law.

5. Data Retention

jilima retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Retention periods vary depending on the type of data and the purpose for which it was collected:

• Account Data: Retained for the duration of your active account and for up to seven (7) years after account closure to comply with legal, regulatory, and tax obligations.
• Transaction Records: Retained for a minimum of seven (7) years as required by AML/CTF regulations and tax laws.
• Identity Verification Documents: Retained for the period required by regulatory authorities, typically seven (7) years from account closure.
• Marketing Data: Retained until you opt out of marketing communications or request deletion, subject to legal retention requirements.
• Anonymized Data: Aggregated and anonymized data that cannot identify you may be retained indefinitely for statistical and analytical purposes.

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with industry best practices.

6. Data Security

jilima employs industry-standard technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• Encryption: All sensitive data transmitted between your device and our servers is protected using 256-bit SSL/TLS encryption.
• Secure Storage: Personal data is stored on secure servers with restricted access controls, firewalls, and intrusion detection systems.
• Access Controls: Only authorized personnel with a legitimate business need can access your personal information, and all access is logged and monitored.
• Two-Factor Authentication: Optional 2FA adds an extra layer of security to your account login.
• Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing to identify and address potential risks.
• Employee Training: All jilima staff undergo data protection and security awareness training.

While we implement robust security measures, no system is completely secure. You also have a responsibility to protect your account by choosing a strong password, not sharing your login credentials, and promptly reporting any suspicious activity.

7. Your Privacy Rights

Under the Data Privacy Act of 2012 and other applicable laws, you have the following rights regarding your personal information:

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data, subject to legal retention requirements and our legitimate interests.
• Right to Data Portability: You may request a machine-readable copy of your personal data for transfer to another service provider.
• Right to Object: You may object to processing of your personal data for direct marketing purposes or based on legitimate interests.
• Right to Restrict Processing: You may request that we temporarily suspend processing of your personal data in certain circumstances.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time (though this will not affect the lawfulness of processing prior to withdrawal).
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission of the Philippines if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the contact details provided in Section 11 below. We will respond to your request within thirty (30) days.

8. Cookies and Tracking Technologies

jilima uses cookies, web beacons, pixels, and similar technologies to enhance your experience, analyze platform usage, and deliver personalized content and advertising. Cookies are small text files stored on your device that allow us to recognize you on subsequent visits.

8.1 Types of Cookies We Use

• Essential Cookies: Necessary for the platform to function properly, including session management, authentication, and security features. These cookies cannot be disabled.
• Performance Cookies: Collect anonymous data about how you use the platform, including pages visited, errors encountered, and load times, to help us improve performance.
• Functionality Cookies: Remember your preferences, language settings, and other personalization choices to enhance your experience.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising and measure campaign effectiveness. These cookies may be set by third-party advertising networks.

8.2 Managing Cookies

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies, but doing so may limit platform functionality and prevent you from accessing certain features. To learn more about managing cookies, visit your browser's help section.

9. International Data Transfers

jilima primarily operates within the Philippines, but some of our service providers and partners are located in other countries. When we transfer personal data outside the Philippines, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws. These safeguards may include:

• Standard contractual clauses approved by data protection authorities;
• Adequacy decisions recognizing the data protection standards of the recipient country;
• Binding corporate rules and other approved data transfer mechanisms.

10. Children's Privacy

jilima services are intended exclusively for adults aged 21 and older. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete such information and terminate the associated account. If you believe a minor has created an account on jilima, please contact us immediately at the details provided below.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact us:

• Data Protection Officer Email: [email protected]
• Customer Support Email: [email protected]
• Live Chat: Available 24/7 through the jilima platform

We are committed to addressing your privacy concerns promptly and transparently. All privacy inquiries will be responded to within thirty (30) days.

12. Changes to This Privacy Policy

jilima reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or platform features. We will post any changes on this page and update the "Last Updated" date at the top of the document. Material changes that significantly affect your privacy rights will be communicated via email or prominent notice on the platform. Your continued use of jilima services after changes are posted constitutes acceptance of the revised Privacy Policy.