Privacy Policy — jilima

1.1 The data controller responsible for the personal information of jilima users is the operator of jilima.club, a PAGCOR-licensed online gambling operator established and operating in the Philippines.

1.2 For all privacy-related inquiries, requests to exercise data subject rights, or complaints regarding jilima's data processing practices, you may contact jilima's designated Data Protection Officer (DPO) using the contact details set out in Section 14 of this Policy.

2.1 This Privacy Policy applies to all personal data collected, processed, and stored by jilima in connection with your use of the jilima Platform at jilima.club, including:

• Account registration and identity verification (KYC).
• Deposits, withdrawals, and financial transactions conducted through the Platform.
• Game play, sports betting activity, and bonus interactions.
• Customer support communications, including live chat, email, and any other channel through which you contact jilima.
• Your use of jilima's responsible gaming tools, including self-exclusion and deposit limit configurations.
• Technical data automatically collected when you access and navigate the jilima Platform.

2.2 This Policy does not apply to websites, applications, or services operated by third parties that may be linked to or from the jilima Platform. jilima is not responsible for the privacy practices of third-party providers, payment processors, or game suppliers.

3.1 jilima collects the following categories of personal data from users. Collection occurs at registration, during KYC verification, during your ongoing use of the Platform, and through automated technical means:

3.2 jilima does not intentionally collect sensitive personal information (as defined under the Data Privacy Act of 2012) beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive personal information — such as government ID numbers required for KYC — is collected, it is handled with the heightened security requirements applicable to such data.

4.1 jilima processes your personal data only for specified, legitimate purposes. The legal basis for each category of processing is identified below:

• Account Creation and Platform Access: Processing your registration data is necessary to perform the contract between you and jilima — your jilima account. Without this processing, jilima cannot provide you with access to the Platform.
• Identity Verification (KYC): jilima is legally required by PAGCOR regulations and its Anti-Money Laundering (AML) obligations under Republic Act 9160 (as amended) to verify the identity and age of all players. This processing is carried out pursuant to a legal obligation.
• Payment Processing: Financial data is processed to facilitate deposits and withdrawals through GCash, PayMaya, and Philippine bank channels. This is necessary for the performance of your contract with jilima.
• Responsible Gaming Compliance: jilima is required by PAGCOR to implement and maintain responsible gaming tools. Processing your gaming activity data to enforce deposit limits, identify problem gambling indicators, and administer self-exclusions is a legal obligation.
• Fraud Prevention and Security: jilima has a legitimate interest in protecting the Platform from fraud, money laundering, and abuse, which requires processing technical data and gaming activity patterns.
• Marketing Communications: With your prior consent, jilima may send promotional communications about bonuses, new games, and Platform updates. You may withdraw consent at any time from your account settings.
• Customer Support: Communications data is processed to respond to your support inquiries and resolve disputes, which is necessary for the performance of your account contract.

5.1 jilima does not sell your personal data to third parties for their independent commercial use. jilima may share your personal data with the following categories of recipients only to the extent necessary for the specified purpose:

• Payment Service Providers: GCash (GXI), PayMaya, BancNet, BPI, BDO, Metrobank, and other payment processors integrated into the jilima Platform receive the financial and identity data necessary to process your transactions. These providers are bound by their own data protection obligations and Philippine financial regulations.
• Identity Verification Providers: Third-party KYC and identity verification services engaged by jilima receive your identity documents and personal data for the purpose of verifying your age and identity as required by PAGCOR and AML law.
• Game Suppliers: Third-party game software providers may receive anonymized or pseudonymized gaming session data for the purposes of game performance monitoring, fairness auditing, and technical support. These providers do not receive your directly identifying personal data unless required for a specific compliance purpose.
• Regulatory and Law Enforcement Authorities: jilima is required to disclose player data to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities upon lawful request or as required by jilima's regulatory obligations. jilima will disclose the minimum information necessary to satisfy the applicable legal requirement.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers may have access to personal data as part of providing technical services to jilima. All such providers operate under data processing agreements that impose binding data protection obligations.

5.2 Any third party receiving personal data from jilima is required to process that data only for the specified purpose, maintain appropriate security measures, and comply with applicable Philippine data protection law.

6.1 jilima retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following retention guidelines apply:

• Account and Identity Data: Retained for the duration of your active account relationship with jilima, and for a minimum of five (5) years following account closure, as required by AML obligations under Republic Act 9160.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC record-keeping requirements.
• Gaming Activity Data: Retained for a period of three (3) years from the date of each gaming session, or longer where required by an ongoing investigation or dispute.
• Customer Support Communications: Retained for two (2) years from the date of the last communication, or until all associated matters are fully resolved.
• Self-Exclusion Records: Retained indefinitely to ensure the integrity of jilima's responsible gaming program and to prevent re-registration by self-excluded players during their exclusion period.
• Marketing Consent Records: Retained for the duration of your account relationship, updated on each change to your marketing preferences.

6.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC-approved data disposal procedures.

7.1 jilima implements a layered set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include, but are not limited to:

• Transport Layer Security (TLS): All data transmitted between your device and jilima servers is encrypted using 256-bit TLS encryption, preventing interception in transit.
• Data Encryption at Rest: Sensitive personal and financial data stored in jilima's systems is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within jilima's internal systems is restricted on a strict need-to-know basis. All access is logged and subject to periodic review.
• Two-Factor Authentication: Players are strongly encouraged to enable 2FA on their jilima accounts. Internal system access by jilima staff requires multi-factor authentication.
• Intrusion Detection: jilima deploys automated intrusion detection and anomaly monitoring systems across all production infrastructure.
• Security Audits: jilima conducts regular internal and third-party security audits of its Platform infrastructure and data handling practices.
• Staff Training: All jilima employees who handle personal data receive mandatory data protection training at onboarding and on an annual basis.

8.1 The jilima Platform uses cookies and similar tracking technologies to operate the Platform, enhance your user experience, and analyze Platform performance. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that prevent cross-site request forgery. These cookies cannot be disabled without breaking Platform functionality.
• Functional Cookies: Remember your preferences, such as language settings, game display preferences, and responsible gaming notification settings. These improve your experience but are not required for core Platform operation.
• Analytics Cookies: Used to collect anonymized information about how players use the jilima Platform — which games are most popular, how users navigate the lobby, and where technical issues occur. This data is used to improve the Platform. It does not identify you personally.
• Marketing Cookies: Used only where you have provided prior consent, to help jilima understand which promotional channels are effective and personalize bonus offers. You may withdraw consent and disable marketing cookies from your account settings at any time.

8.2 You may control cookie settings through your browser. Note that disabling strictly necessary cookies will prevent you from using the jilima Platform. Instructions for managing cookies are available in your browser's help documentation.

9.1 The jilima Platform is strictly intended for adults aged 21 years and over in accordance with PAGCOR regulations and Philippine gambling law. jilima does not knowingly collect, process, or store personal data from individuals under 21 years of age.

9.2 Age is declared at registration and is verified through mandatory KYC documentation before any withdrawal is processed. Where jilima becomes aware that personal data has been collected from an individual under 21 years of age, that data will be immediately deleted, the associated account will be permanently suspended, and the matter will be reported to PAGCOR as required.

10.1 Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by jilima. jilima will respond to all verified rights requests within 15 business days:

10.2 To exercise any of the above rights, contact jilima's Data Protection Officer at the details provided in Section 14. You will be asked to verify your identity before your request is processed. jilima will not charge a fee for exercising your rights unless a request is manifestly unfounded or excessive.

11.1 The jilima Platform may involve the transfer of certain personal data to servers or service providers located outside of the Philippines — for example, in connection with cloud infrastructure, game supplier integrations, or international payment processing.

11.2 Any cross-border transfer of personal data by jilima is carried out in compliance with the requirements of the Philippine Data Privacy Act of 2012 and NPC regulations governing overseas transfers. Specifically, jilima ensures that:

• Personal data is transferred only to countries, organizations, or service providers that provide an adequate level of data protection as assessed by jilima or as recognized by the NPC.
• Cross-border transfers are governed by appropriate contractual safeguards, including data processing agreements incorporating standard contractual clauses approved under Philippine DPA regulations.
• The minimum amount of personal data necessary to fulfill the transfer purpose is shared with overseas recipients.

11.3 You may request information about the specific countries to which your data may be transferred and the safeguards in place by contacting jilima's Data Protection Officer.

12.1 If you have a concern about how jilima handles your personal data, you are encouraged to contact jilima's Data Protection Officer in the first instance using the contact details in Section 14. jilima will investigate your concern and respond within 15 business days.

12.2 If your concern is not resolved to your satisfaction through jilima's internal process, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the regulatory authority responsible for enforcing the Data Privacy Act of 2012.

13.1 jilima reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, PAGCOR requirements, or jilima's data processing practices.

13.2 Where amendments are material, jilima will notify registered account holders via their registered email address at least 7 days before the amended policy takes effect. The effective date at the top of this page will be updated on each revision.

13.3 Your continued use of the jilima Platform after an amended Privacy Policy takes effect constitutes your acknowledgment of the revised policy. If you do not accept the revised policy, you should close your jilima Account before the effective date of the change.

14.1 For any questions, concerns, or requests regarding this Privacy Policy or jilima's data processing practices — including the exercise of your data subject rights under the Data Privacy Act of 2012 — please contact jilima's Data Protection Officer.

14.2 All privacy-related correspondence should be directed to the following contact. To protect your data, you will be required to verify your identity before any data access, correction, or erasure request is processed:

14.3 Response timelines: jilima targets acknowledgment of all data subject requests within 2 business days and full resolution within 15 business days. Complex requests or those requiring additional verification may take up to 30 business days; jilima will inform you of any extension within the initial 15-day period.