Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how jiliwn Operations ("jiliwn," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal information of users ("you," "Player," or "User") who access or use the jiliwn gaming platform available at jiliwn.cam (the "Platform"). This Policy applies to all personal data processed by jiliwn in connection with the provision of online casino, sports betting, and related gaming services to residents of the Philippines.

By creating an account, depositing funds, placing bets, or otherwise using the Platform, you acknowledge that you have read, understood, and agree to the data collection and processing practices described in this Policy. If you do not agree with any aspect of this Policy, you must discontinue use of the Platform immediately.

jiliwn is committed to compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable data protection standards issued by the National Privacy Commission (NPC) and the Philippine Amusement and Gaming Corporation (PAGCOR).

2. Data Controller Information

jiliwn Operations is the data controller responsible for the processing of your personal information under this Policy. For all inquiries, requests, or complaints related to data privacy, you may contact our Data Protection Officer (DPO) using the following channels:

• Email: [email protected]
• Postal Address: jiliwn Operations Data Protection Office, Metro Manila, Philippines
• Customer Support: 24/7 live chat available via the Platform (for general account inquiries)

If you believe your data protection rights have been violated, you also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

3. Personal Data We Collect

jiliwn collects several categories of personal data necessary to provide gaming services, verify player identity, process financial transactions, prevent fraud, and comply with legal and regulatory obligations. The types of data collected include:

3.1 Account Registration Data

• Full legal name (as appears on government-issued ID)
• Date of birth (to verify 21+ age requirement)
• Email address
• Mobile phone number
• Username and password (hashed and encrypted)
• Residential address
• Security questions and answers (optional)

3.2 Identity Verification Data (KYC)

• Government-issued identification documents (PhilSys National ID, Passport, Driver's License, Voter's ID)
• Selfie or photograph for biometric comparison
• Proof of address (utility bill, bank statement, government correspondence)
• Tax Identification Number (TIN), if applicable for high-value transactions

3.3 Financial & Transaction Data

• Payment method details (GCash account number, PayMaya account, bank account numbers, card last four digits)
• Deposit and withdrawal transaction histories
• Wagering activity, bet placements, game outcomes, and account balances
• Bonus claims, promotions redeemed, and wagering progress

3.4 Technical & Usage Data

• IP address, device type, operating system, browser type
• Session duration, pages visited, clickstream data
• Geolocation data (to verify access from the Philippines)
• Cookies and similar tracking technologies (see Section 11)

3.5 Communications Data

• Live chat transcripts, email correspondence, support tickets
• Feedback forms, surveys, and promotional preferences

4. How We Use Your Data

jiliwn processes your personal data for the following purposes, each supported by a legitimate legal basis as outlined in Section 5:

• Account Creation & Management: To register and maintain your player account, authenticate login sessions, and provide customer support.
• Transaction Processing: To process deposits, execute withdrawals, manage account balances, and facilitate payments through GCash, PayMaya, BPI, BDO, and other supported methods.
• Identity Verification (KYC/AML): To verify your age (21+ requirement), confirm your identity, prevent underage gambling, detect fraud, and comply with PAGCOR anti-money laundering (AML) obligations.
• Game Integrity & Fairness: To monitor gaming activity, detect collusion, identify suspicious patterns, prevent bonus abuse, and ensure fair play.
• Regulatory Compliance: To fulfill legal obligations under PAGCOR regulations, report suspicious transactions to authorities, and cooperate with law enforcement investigations when legally required.
• Responsible Gaming: To implement self-exclusion tools, deposit limits, reality checks, and other responsible gaming features designed to protect vulnerable players.
• Marketing & Promotions (Opt-In): To send promotional offers, bonus announcements, and personalized recommendations — only if you have consented to receive marketing communications. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct A/B testing, optimize user experience, and develop new features based on aggregated, anonymized data.
• Security & Fraud Prevention: To detect unauthorized access attempts, identify fraudulent activity, prevent hacking, and protect player accounts from security breaches.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, jiliwn processes your personal data based on one or more of the following legal grounds:

• Consent: You have provided explicit consent for specific processing activities, such as receiving marketing communications or participating in surveys.
• Contractual Necessity: Processing is necessary to fulfill our contractual obligations under the Terms & Conditions, including account creation, transaction processing, and gaming services delivery.
• Legal Obligation: Processing is required to comply with Philippine laws, PAGCOR regulations, AML requirements, tax obligations, and court orders.
• Legitimate Interests: Processing is necessary to protect jiliwn's legitimate business interests, such as fraud prevention, security monitoring, and platform optimization — provided these interests do not override your fundamental rights and freedoms.

6. Data Sharing & Disclosure

jiliwn does not sell, rent, or trade your personal information to third-party marketers. However, we may share your data with the following categories of recipients under strict confidentiality and data protection obligations:

6.1 Service Providers

Third-party vendors who provide essential services to jiliwn, including payment processors (GCash, PayMaya, banks), KYC verification providers, customer support platforms, cloud hosting services, and fraud detection tools. These providers access personal data only to the extent necessary to perform their functions and are contractually bound to protect your information.

6.2 Game Providers

Licensed casino game providers (slots, live dealer studios, table games) receive limited data necessary to deliver game content and track gameplay for integrity purposes. Game providers are prohibited from using player data for independent marketing or commercial purposes.

6.3 Regulatory Authorities

PAGCOR, the National Privacy Commission (NPC), and other Philippine government agencies with legal authority to request player data for regulatory compliance, investigations, or enforcement actions.

6.4 Law Enforcement

Law enforcement agencies, courts, or other governmental bodies when legally compelled by subpoena, court order, or statute — or when disclosure is necessary to prevent imminent harm, investigate suspected criminal activity, or protect public safety.

6.5 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy.

7. International Data Transfers

jiliwn primarily stores and processes personal data within the Philippines. However, certain service providers (cloud hosting, payment processors, game providers) may transfer data to servers located outside the Philippines. When international transfers occur, jiliwn ensures that adequate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the National Privacy Commission
• Transfers to jurisdictions with adequate data protection standards recognized by the NPC
• Explicit consent from players for specific cross-border data transfers where required by law

Players have the right to request information about specific data transfers and the safeguards applied by contacting our Data Protection Officer.

8. Data Retention

jiliwn retains personal data only for as long as necessary to fulfill the purposes outlined in this Policy and to comply with legal, regulatory, and contractual obligations. Specific retention periods include:

• Account Data: Retained for the duration of your active account, plus seven (7) years after account closure to comply with PAGCOR financial record-keeping requirements.
• Transaction Records: Retained for seven (7) years after the transaction date in accordance with Philippine tax and AML regulations.
• KYC Documents: Retained for seven (7) years after the account relationship ends, as required by PAGCOR and AML laws.
• Communications Data: Live chat transcripts and email correspondence retained for three (3) years for customer service quality assurance and dispute resolution.
• Marketing Consent: Retained until you withdraw consent, after which your contact information is removed from marketing databases within thirty (30) days.

After applicable retention periods expire, personal data is securely deleted or anonymized in accordance with industry best practices.

9. Your Rights as a Data Subject

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

• Right to Access: You may request a copy of the personal data jiliwn holds about you, including details about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data in your account profile.
• Right to Erasure: You may request deletion of your personal data, subject to legal retention requirements. Note that PAGCOR regulations require jiliwn to retain certain financial records for seven years.
• Right to Data Portability: You may request that jiliwn provide your personal data in a structured, commonly used, machine-readable format for transfer to another service provider.
• Right to Object: You may object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time, though this will not affect the lawfulness of processing conducted prior to withdrawal.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

To exercise any of these rights, submit a written request to our Data Protection Officer at [email protected]. jiliwn will respond to all requests within thirty (30) calendar days as required by Philippine law.

10. Security Measures

jiliwn employs a comprehensive range of technical, organizational, and administrative security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and jiliwn servers is encrypted using TLS 1.3 protocol. Sensitive data stored on our servers (passwords, payment details) is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized jiliwn employees and service providers on a strict need-to-know basis, protected by role-based access controls and multi-factor authentication.
• Firewalls & Intrusion Detection: jiliwn servers are protected by enterprise-grade firewalls, intrusion detection systems (IDS), and continuous security monitoring.
• Regular Audits: jiliwn undergoes annual security audits conducted by independent third-party firms to identify and remediate vulnerabilities.
• Employee Training: All jiliwn staff undergo mandatory data protection and cybersecurity training to ensure they understand and comply with privacy obligations.

Despite these measures, no system is completely secure. Players are responsible for maintaining the confidentiality of their login credentials and should immediately report any suspected unauthorized account access to [email protected].

11. Cookies & Tracking Technologies

jiliwn uses cookies and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that allow jiliwn to recognize you on subsequent visits and remember your preferences.

Types of Cookies Used:

• Essential Cookies: Required for basic platform functionality, including login authentication, session management, and security features. These cookies cannot be disabled.
• Performance Cookies: Collect anonymized usage statistics to help jiliwn understand how players interact with the platform and identify areas for improvement.
• Functionality Cookies: Remember your language preference, display settings, and other customization choices.
• Marketing Cookies: Track your activity across jiliwn pages to deliver personalized bonus offers and promotional content — only if you have consented to marketing communications.

You can manage cookie preferences through your browser settings. Blocking essential cookies may impair platform functionality. For more details, see our Cookie Policy (if applicable) or contact our Data Protection Officer.

12. Children's Privacy

jiliwn strictly prohibits use of the Platform by individuals under the age of twenty-one (21) years. We do not knowingly collect personal data from minors. If jiliwn becomes aware that a user is underage, the account will be immediately suspended, all winnings forfeited, and deposits returned (subject to verification).

Parents or guardians who believe their child has created a jiliwn account should contact our Data Protection Officer at [email protected] immediately. jiliwn will delete the account and any associated personal data in accordance with applicable law.

13. Changes to This Policy

jiliwn reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. Material changes will be communicated via registered email and a prominent notice on the Platform at least thirty (30) calendar days before the updated Policy takes effect.

Your continued use of the Platform after the effective date of the revised Policy constitutes acceptance of the changes. If you do not agree with the updated Policy, you must discontinue use of the Platform and may request account closure.

We encourage you to review this Policy periodically to stay informed about how jiliwn protects your privacy.

14. Contact & Complaints

If you have questions, concerns, or complaints regarding this Privacy Policy or jiliwn's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Response Time: We aim to respond to all privacy inquiries within thirty (30) calendar days as required by Philippine law.

If you believe jiliwn has violated your data protection rights and are not satisfied with our response, you have the right to lodge a complaint with:

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