jiliwim Privacy Policy

jiliwim ("jiliwim," "we," "us," or "our") operates the online gaming platform accessible at jiliwim.app (the "Platform"). jiliwim is the data controller responsible for the personal information collected through the Platform and is committed to protecting that information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

This Privacy Policy applies to all personal data collected from users ("you," "your") who access or use the jiliwim Platform, including registered account holders and visitors who browse the Platform without registering. By using the jiliwim Platform, you acknowledge that you have read and understood this Privacy Policy.

jiliwim has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with the DPA and this Privacy Policy. You may contact the DPO through the contact details provided in Section 15 of this Policy.

jiliwim collects the following categories of personal data, depending on how you interact with the Platform:

jiliwim collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 7 for more details on cookies.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment data from GCash, Maya, and banking partners as part of transaction processing.
• Publicly available sources: Information from public records or databases where permitted by Philippine law for the purpose of identity verification or fraud prevention.

jiliwim does not collect personal data from social media platforms or third-party data brokers for marketing profiling purposes.

jiliwim uses your personal data for the following specific purposes:

• Account management: Creating and maintaining your jiliwim account, verifying your identity and age (21+), and managing your account preferences and settings.
• Payment processing: Processing deposits and withdrawals through GCash, Maya, bank transfer, and debit card; verifying payment method ownership; and maintaining accurate transaction records.
• Legal and regulatory compliance: Fulfilling obligations under the DPA, PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws, including reporting requirements to regulatory authorities.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the Platform.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling; administering deposit limits, cooling-off periods, and self-exclusion requests; and complying with PAGCOR's responsible gaming framework.
• Customer support: Responding to your inquiries, resolving disputes, and improving the quality of jiliwim's support services.
• Platform improvement: Analyzing usage data in aggregated, anonymized form to improve game offerings, platform performance, and user experience.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates where you have provided consent or where jiliwim has a legitimate interest, subject to your right to opt out at any time.

jiliwim processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and jiliwim — including account registration, payment processing, and game provision — is necessary for the execution of that contract.
• Legal obligation: Processing required to comply with jiliwim's obligations under Philippine law, including PAGCOR regulations, AMLA reporting requirements, and NPC directives.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where jiliwim's legitimate interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where jiliwim relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

jiliwim does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment service providers: GCash, Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with PAGCOR and AMLA requirements.
• IT and platform service providers: Cloud hosting, data storage, and cybersecurity service providers who process data on jiliwim's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and accountants engaged by jiliwim, subject to professional confidentiality obligations.

All third-party service providers engaged by jiliwim are required to implement appropriate technical and organizational security measures and are prohibited from using your personal data for their own purposes.

jiliwim uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help jiliwim recognize you, remember your preferences, and analyze how the Platform is used.

jiliwim uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how users interact with the Platform — such as pages visited, time spent, and error messages — to help jiliwim improve performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jiliwim Platform. jiliwim does not use third-party advertising or behavioral tracking cookies.

jiliwim retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by AMLA and PAGCOR regulations.
• Support and communications data: Retained for three (3) years from the date of the last interaction, or longer if required for ongoing dispute resolution.
• Technical and usage data: Retained for up to twelve (12) months in identifiable form, after which it is anonymized or deleted.
• Marketing consent records: Retained for the duration of your consent and for three (3) years following withdrawal of consent as evidence of compliance.

When personal data is no longer required, jiliwim will securely delete or anonymize it in accordance with industry-standard data destruction procedures.

jiliwim implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• TLS 1.3 encryption for all data in transit between your device and jiliwim's servers.
• AES-256 encryption for sensitive personal data stored at rest, including identity documents and financial account details.
• Multi-factor authentication requirements for jiliwim staff accessing personal data systems.
• Role-based access controls ensuring that only authorized personnel with a legitimate need can access personal data.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• 24/7 security monitoring and intrusion detection systems.
• Regular staff training on data protection obligations and security best practices.

In the event of a personal data breach that poses a risk to your rights and freedoms, jiliwim will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jiliwim:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data jiliwim holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data jiliwim holds about you.
• Right to erasure: 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 jiliwim's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on jiliwim's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jiliwim has violated your data privacy rights.

To exercise any of these rights, please contact jiliwim's Data Protection Officer using the contact details in Section 15. jiliwim will respond to all verified data rights requests within thirty (30) days of receipt.

The jiliwim Platform is strictly intended for users who are 21 years of age or older, in compliance with Philippine law and PAGCOR regulations governing online gambling. jiliwim does not knowingly collect personal data from individuals under the age of 21.

If jiliwim discovers or has reason to believe that personal data has been collected from a person under 21 years of age, jiliwim will immediately suspend the associated account, delete the personal data in question, and report the matter to the relevant regulatory authorities where required.

If you are a parent or guardian and believe that your child under 21 has provided personal data to jiliwim, please contact jiliwim's Data Protection Officer immediately using the contact details in Section 15 so that appropriate action can be taken without delay.

Some of jiliwim's third-party service providers — including cloud infrastructure and cybersecurity providers — may process personal data outside of the Philippines. Where such cross-border transfers occur, jiliwim ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012.

These safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission.
• Binding corporate rules where the recipient is part of a corporate group with an approved privacy framework.
• Transfers to countries recognized by the NPC as providing an adequate level of data protection.

jiliwim will not transfer your personal data to a foreign jurisdiction unless the transfer is covered by one of the safeguards described above or is otherwise permitted under the DPA and its Implementing Rules and Regulations.

With your consent, jiliwim may send you promotional communications about new games, bonuses, special offers, and platform updates via email or SMS. You may withdraw your consent to receive marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email sent by jiliwim.
• Updating your communication preferences in your jiliwim account settings.
• Contacting jiliwim support and requesting removal from marketing lists.

Withdrawal of marketing consent will not affect your ability to use the jiliwim Platform or receive transactional communications related to your account, such as deposit confirmations, withdrawal notifications, and security alerts. These transactional communications are necessary for the operation of your account and cannot be opted out of while your account remains active.

jiliwim does not engage in automated decision-making or profiling for marketing purposes that produces legal or similarly significant effects on you without your explicit consent.

jiliwim reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, jiliwim will notify registered users via email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised. The current version of this Privacy Policy is always available on the jiliwim Platform. Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy.

If you do not agree with any changes to this Privacy Policy, you should cease using the jiliwim Platform and may request account closure by contacting jiliwim support.

If you have any questions, concerns, or requests regarding this Privacy Policy or jiliwim's data processing practices, or if you wish to exercise any of your data rights under the Data Privacy Act of 2012, please contact jiliwim's Data Protection Officer:

Data Protection Officer — jiliwim

Email: [email protected]

General Support: [email protected]

jiliwim's Data Protection Officer is available Monday to Friday, 9:00 AM to 6:00 PM Philippine Standard Time (PST). General support is available 24/7 in English and Filipino.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.

This Privacy Policy was last updated on January 1, 2026 and supersedes all previous versions.