jilljuck Privacy Policy

jilljuck ("we," "us," or "our") operates the online casino and sports betting platform accessible at jilljuck.org (the "Platform"). We are committed to protecting the privacy and personal data of every player who registers and plays on jilljuck. This Privacy Policy sets out what personal information we collect from Filipino players, how we use it, with whom we share it, how long we keep it, and what rights you have with respect to your data.

This Policy is written in plain English — not just to meet our legal obligations under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations, but because we believe players in Manila, Cebu, Davao, and across the Philippines deserve to understand exactly how their information is handled before trusting us with it.

By registering an account or continuing to use the jilljuck Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform and request account closure through our support team.

jilljuck acts as the data controller with respect to the personal information of players registered on the Platform. As data controller, jilljuck determines the purposes and means by which your personal data is processed. Where jilljuck engages third-party service providers to process data on its behalf (for example, payment processors or fraud detection services), those parties act as data processors under jilljuck's instruction and are bound by contractual obligations to protect your data in accordance with applicable law.

For all privacy-related inquiries, players may contact jilljuck's designated Data Protection Officer (DPO) using the contact details set out in Section 14 of this Policy.

jilljuck collects personal information in the following categories:

jilljuck does not collect sensitive personal information (as defined under the DPA, such as health data, religious beliefs, or political affiliations) unless specifically required for responsible gaming compliance purposes, in which case explicit consent will be sought.

jilljuck uses the personal information we collect for the following purposes:

• Account creation and management: To register your jilljuck account, verify your identity, and maintain your account profile;
• Service delivery: To process deposits, execute withdrawals to your GCash, Maya, or bank account, and credit winnings to your wallet;
• Legal and regulatory compliance: To fulfil obligations under Philippine anti-money laundering law (RA 9160 as amended), PAGCOR reporting requirements, and the DPA;
• Fraud prevention and security: To detect and prevent unauthorised account access, bonus abuse, multi-accounting, and suspicious financial transactions;
• Responsible gaming: To monitor play patterns for indicators of problem gambling, enforce self-exclusion requests, and apply deposit/loss limits set by players;
• Customer support: To respond to your queries, complaints, and support requests via Live Chat or email;
• Platform improvement: To analyse usage patterns across the Platform and improve game performance, navigation, and the overall player experience;
• Marketing communications: To send promotional emails, SMS notifications, and in-Platform messages about bonuses and new games — only where you have provided consent or where we have a legitimate interest, with the right to opt out at any time.

jilljuck does not use personal data for automated decision-making that produces significant legal effects on players, except where this is required for fraud detection or responsible gaming limit enforcement, in which case a human review process is available upon request.

Under the Philippine Data Privacy Act, jilljuck processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our agreement with you as a registered player (account management, payment processing, game delivery);
• Legal obligation: Processing required to comply with Philippine law, including AML reporting, PAGCOR regulatory requirements, and tax obligations;
• Legitimate interests: Processing conducted to detect fraud, secure the Platform, and improve services — where jilljuck's legitimate interests are not overridden by your rights;
• Consent: For marketing communications and for the collection of any sensitive personal information, where your explicit, informed consent has been obtained and may be withdrawn at any time.

jilljuck does not sell your personal data to third parties. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment processors: GCash (Globe Fintech Innovations), PayMaya/Maya, BPI, BDO, Metrobank, Coins.ph, and 7-Eleven payment partners receive financial and identity data solely to process your transactions;
• Game providers: JILI Games and other software providers may receive anonymized technical data required to deliver and audit game performance and RTP compliance;
• Identity verification services: KYC providers receive identity documents submitted during the verification process, under strict confidentiality obligations;
• Regulatory authorities: PAGCOR and Philippine law enforcement agencies where disclosure is required by law, court order, or regulatory directive;
• Fraud and AML service providers: Third-party fraud detection and anti-money laundering screening services, bound by data processing agreements;
• Professional advisers: Legal, accounting, and auditing firms engaged by jilljuck, subject to professional confidentiality obligations.

All third-party data processors engaged by jilljuck are contractually required to maintain appropriate technical and organisational security measures and to process personal data only as directed by jilljuck.

jilljuck uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: Required for the Platform to function, including session management, login state, and security features. These cannot be disabled without affecting Platform functionality;
• Performance cookies: Collect anonymized data on how players navigate the Platform (pages visited, errors encountered) to improve site performance;
• Functional cookies: Remember your language preferences, display settings, and last-used game categories to personalise your experience;
• Analytics cookies: Used to understand aggregate player behaviour and platform usage patterns for product development purposes.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing the Platform or playing games. On mobile browsers (Chrome on Android, Safari on iOS), cookie preferences can be managed through the browser's privacy settings menu.

jilljuck retains personal data for as long as your account remains active and for a period thereafter as required by applicable law or legitimate business purposes:

• Active account data: Retained for the duration of your account's active status;
• Closed account data: Identity and transaction records are retained for a minimum of five (5) years after account closure, in compliance with Philippine AML record-keeping requirements under RA 9160;
• Communication logs: Support chat and email records are retained for two (2) years;
• Marketing consent records: Retained for three (3) years or until withdrawn, whichever is earlier;
• Technical/log data: Server access logs are retained for ninety (90) days.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be attributed to an identifiable individual.

jilljuck implements appropriate technical and organisational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the jilljuck Platform;
• Encryption at rest for sensitive personal and financial data stored in our databases;
• Multi-factor authentication (2FA via SMS OTP) for player accounts;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Incident response procedures aligned with DPA breach notification requirements (notification to the National Privacy Commission within 72 hours of discovering a reportable breach).

Notwithstanding the above, no internet transmission is completely secure. jilljuck cannot guarantee absolute security of data transmitted to the Platform over the internet and players transmit data at their own risk. We strongly recommend enabling 2FA on your account and using mobile data rather than public Wi-Fi when accessing jilljuck.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jilljuck:

• Right to be informed: To be notified of how your personal data is collected and processed — which this Policy fulfils;
• Right of access: To request a copy of the personal data jilljuck holds about you;
• Right to rectification: To request correction of inaccurate or incomplete personal data;
• Right to erasure: To request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to object: To object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability: To receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: To file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jilljuck has processed your data in breach of the DPA.

To exercise any of the above rights, contact jilljuck's Data Protection Officer using the details in Section 14. jilljuck will respond to verified requests within thirty (30) calendar days.

The jilljuck Platform is strictly for individuals aged 21 years and above. jilljuck does not knowingly collect personal data from individuals under 21 years of age. Where jilljuck discovers or has reasonable grounds to believe that personal data has been collected from a person under 21 years old, the relevant account will be suspended immediately, all balances forfeited, and the personal data deleted in accordance with applicable law.

Parents and guardians who believe a minor under their care may have registered on jilljuck should contact support at jilljuck.org immediately so that the account can be investigated and closed without delay.

Some of jilljuck's service providers and game technology partners operate infrastructure outside the Philippines. Where personal data is transferred to servers or processors in other countries, jilljuck ensures that adequate protections are in place, including contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under Philippine law. Such transfers are conducted only to the extent necessary for service delivery and never for purposes that would not be permitted under this Policy or the DPA.

jilljuck reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform services. Where changes are material, jilljuck will notify registered players via the email address or mobile number on file at least fourteen (14) days before the revised Policy takes effect. The updated Policy will be published on this page with a revised "Last Updated" date. Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy. If you disagree with the revised terms, you may request account closure through our support team.

For privacy-related inquiries, data subject rights requests, or complaints regarding jilljuck's handling of your personal data, please contact our Data Protection Officer:

• Email (DPO): support at jilljuck.org (subject line: "Privacy / DPO Request")
• Live Chat: Available 24/7 on the Platform — state that your query is a privacy matter so it is routed to the DPO team
• Response time: Privacy and data subject requests will be acknowledged within 5 business days and resolved within 30 calendar days

If you are not satisfied with jilljuck's response to your privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC) — the independent regulatory body responsible for administering the Data Privacy Act of 2012.