Privacy Policy

1. Introduction

This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal data by jiliho ("jiliho", "we", "us", "our") in connection with the online gaming platform operated at jiliho.org. This Policy applies to all registered players, visitors, and other individuals whose personal data is processed by jiliho in the course of delivering our services to the Philippine market.

jiliho is the data controller responsible for your personal data. We process personal information in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations (IRR), as overseen by the National Privacy Commission (NPC). We also comply with relevant PAGCOR data-handling directives applicable to licensed online gaming operators.

By registering a jiliho account, accessing the platform, or otherwise interacting with our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, please do not access or use the jiliho platform.

This Policy should be read together with our Terms & Conditions, which govern your use of the jiliho platform, and our Responsible Gaming guidelines, which include additional provisions relating to player protection data.

2. Personal Data We Collect

jiliho collects only the personal data that is necessary and proportionate to deliver our services, meet our regulatory obligations, and protect the integrity of our platform. The categories of data we collect are described below.

jiliho does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly required for identity verification and AML compliance. We do not collect information relating to your health, political views, religious beliefs, or racial or ethnic origin unless you voluntarily provide such details in a support communication context.

3. How We Use Your Personal Data

jiliho uses your personal data for the following clearly defined purposes:

• Account Management: To create, verify, maintain, and close your jiliho player account, including processing your registration, verifying your identity (KYC), and authenticating your login sessions.
• Service Delivery: To process your deposits and withdrawals, credit bonus offers to your account, and facilitate your participation in all jiliho games including Color Game, live casino, jackpot slots, sabong, and bingo.
• Regulatory Compliance: To meet our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012. This includes filing required reports with PAGCOR, AMLC, and the NPC.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, bonus abuse, account takeovers, money laundering, and other prohibited conduct on the jiliho platform.
• Customer Support: To respond to your queries, resolve disputes, process complaints, and communicate account-related notifications including security alerts and policy updates.
• Responsible Gaming: To monitor gaming patterns, enforce responsible gaming tools you have activated (such as deposit limits and self-exclusion), and identify players who may need support.
• Platform Improvement: To analyse aggregated usage data, improve game performance, personalise your experience, and develop new features on the jiliho platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and event announcements — but only where you have provided explicit consent to receive marketing materials. You may opt out at any time.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, jiliho processes your personal data on one or more of the following lawful bases:

• Contractual Necessity: Processing is required to perform our contract with you — specifically to deliver the services described in our Terms & Conditions, including operating your jiliho account, processing transactions, and resolving disputes.
• Legal Obligation: Processing is necessary for jiliho to comply with applicable Philippine laws, including PAGCOR licensing conditions, AMLA reporting requirements, and NPC registration obligations.
• Legitimate Interests: Processing is necessary for jiliho's legitimate interests in preventing fraud, maintaining platform security, improving our services, and protecting the integrity of our gaming environment — provided these interests are not overridden by your data rights.
• Consent: For marketing communications and certain non-essential cookies, processing is based on your explicit, freely given, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Third Parties

jiliho does not sell your personal data. We share personal data with third parties only where strictly necessary and only under appropriate data protection agreements. The categories of third parties with whom we may share your data are:

• Payment Processors: GCash, Maya (PayMaya), BPI, BDO, Metrobank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20 network providers — to process your deposits and withdrawals. These providers receive only the minimum data required to execute transactions.
• KYC & Identity Verification Providers: Licensed third-party providers who assist jiliho in verifying your identity documents and performing AML screening as required by Philippine law.
• Game Content Suppliers: Licensed game studios and live dealer platform providers who deliver game content on the jiliho platform. These suppliers may receive anonymised session data for technical integration purposes only.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies — where jiliho is legally required to disclose information.
• IT & Hosting Providers: Cloud infrastructure and cybersecurity vendors who provide the technical backbone for the jiliho platform, operating under strict data processing agreements and confidentiality obligations.
• Professional Advisors: Legal counsel, auditors, and compliance consultants who require access to certain data in the course of providing professional services to jiliho.

All third-party data processors engaged by jiliho are contractually bound to process personal data only on jiliho's documented instructions, to maintain appropriate security standards, and to notify jiliho promptly in the event of a data breach affecting jiliho player data.

6. Cookies & Tracking Technologies

jiliho uses cookies and similar tracking technologies (such as web beacons and local storage objects) to operate and improve the jiliho platform. The cookies we use fall into the following categories:

• Strictly Necessary Cookies: These cookies are essential for the jiliho platform to function. They enable core functionality such as session management, login authentication, and security token validation. These cookies cannot be disabled.
• Performance & Analytics Cookies: These cookies collect anonymised data about how players use the jiliho platform — for example, which games are most popular and where players encounter errors. This data helps us improve platform performance. These cookies are only set with your consent.
• Functional Cookies: These cookies remember your preferences — such as your preferred language, display settings, and responsible gaming tool configurations — to provide a more personalised experience. These cookies are only set with your consent.

jiliho does not use third-party advertising cookies, retargeting pixels, or social media tracking scripts. When you first visit jiliho.org, you will be presented with a cookie consent notice that allows you to accept or decline non-essential cookies. You can update your cookie preferences at any time via your account settings.

Please note that disabling strictly necessary cookies may prevent certain parts of the jiliho platform from functioning correctly. Disabling performance and functional cookies will not affect your ability to play games or process transactions.

7. Data Security

jiliho implements a comprehensive, multi-layered security framework to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• Encryption in Transit: All data transmitted between your device and jiliho's servers is protected with TLS 1.3 / 256-bit SSL encryption.
• Encryption at Rest: Sensitive data stored in jiliho's databases — including financial data and identity documents — is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within jiliho's systems is strictly role-based and limited to staff members who require it to perform their specific functions. All access is logged and regularly audited.
• Multi-Factor Authentication: jiliho's internal administrative systems require multi-factor authentication for all staff access. We strongly encourage players to enable two-factor authentication on their jiliho accounts as well.
• Regular Security Audits: jiliho's platform and data infrastructure are subject to regular penetration testing and security audits conducted by independent cybersecurity specialists.
• Incident Response: jiliho maintains a documented data breach response plan. In the event of a breach that is likely to affect your rights or interests, we will notify you and the NPC within seventy-two (72) hours of becoming aware of the incident, as required by the Data Privacy Act.

8. Data Retention

jiliho retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, and in compliance with PAGCOR regulations and Philippine law. The following retention schedule applies:

Upon expiry of the applicable retention period, personal data is securely and permanently deleted from all jiliho systems, or irreversibly anonymised so that it can no longer be associated with any identifiable individual. Anonymised and aggregated data may be retained indefinitely for statistical and platform improvement purposes.

9. Your Data Rights

Under the Philippine Data Privacy Act of 2012, jiliho players have the following rights with respect to their personal data. These rights may be exercised by submitting a written request to our Data Protection Officer (DPO) at the contact details provided in Section 13.

• Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data jiliho holds about you, along with information about how it is being used.
• Right to Correction / Rectification: You have the right to request that inaccurate, incomplete, or outdated personal data in your jiliho account be corrected without undue delay.
• Right to Erasure / Right to be Forgotten: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jiliho's legal retention obligations under PAGCOR regulations and the AMLA.
• Right to Data Portability: You have the right to receive a copy of the personal data you have provided to jiliho in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to jiliho's assessment of overriding grounds.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission (NPC) if you believe that your data rights have been violated. The NPC can be reached via their official website at privacy.gov.ph.

jiliho will respond to all data rights requests within thirty (30) calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days and will notify you accordingly. jiliho reserves the right to decline requests that are manifestly unfounded, excessive, or repetitive, or that would conflict with our legal obligations under Philippine law.

10. Children & Minors

The jiliho platform is strictly intended for adults aged 21 years and above, as required by PAGCOR and the laws governing online gambling in the Philippines. jiliho does not knowingly collect personal data from individuals under 21 years of age.

During the registration process, all applicants are required to declare their date of birth and confirm that they are at least 21 years old. jiliho reserves the right to request age-verification documentation at any time. If jiliho becomes aware that personal data has been collected from a player who is under 21 years of age:

• The account will be immediately suspended pending investigation.
• All personal data associated with the underage account will be securely deleted once the investigation is complete and any regulatory reporting obligations have been fulfilled.
• Any funds or winnings in the account will be handled in accordance with PAGCOR guidelines on underage gambling accounts.
• The incident will be reported to PAGCOR and, where required, to the relevant law enforcement authorities.

11. Cross-Border Data Transfers

jiliho primarily processes and stores personal data within the Philippines. In certain circumstances — for example, when using internationally based cloud infrastructure providers or game content suppliers — personal data may be transferred to or accessed from servers located outside the Philippines.

Where such cross-border transfers occur, jiliho ensures that adequate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act of 2012. These safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission.
• Transfer to countries or organisations that the NPC has determined provide an adequate level of data protection.
• Binding corporate rules where transfers occur within a group of companies.
• Your explicit consent, where required by law and none of the above safeguards apply.

jiliho does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate contractual safeguards. If you would like further information about the specific safeguards applicable to any cross-border transfer of your data, please contact our Data Protection Officer.

12. Amendments to This Policy

jiliho reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or the services we offer. The "Last Updated" date at the top of this page will always indicate when the most recent revision was made.

Where changes to this Policy are material — for example, changes to the categories of data we collect, new purposes for which we use your data, or changes to how you can exercise your data rights — jiliho will notify you via email to your registered jiliho account address and/or via a prominent notice on the jiliho platform, at least fourteen (14) days before the changes take effect.

Minor amendments — such as typographical corrections, clarifications of existing language, or updates required by regulatory guidance — may be made without advance notice. Your continued use of the jiliho platform following any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with a material change, you have the right to close your jiliho account and request deletion of your personal data, subject to our legal retention obligations.

13. Contact Us & Data Protection Officer

jiliho has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact us using the details below. Our team is available 24 hours a day, 7 days a week, 365 days a year.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe that jiliho has not handled your personal data in accordance with the Data Privacy Act of 2012. The NPC's official website is privacy.gov.ph.