jilispins Privacy Policy

1. Introduction

jilispins operates the online casino platform accessible at jilispins.app, offering a wide range of games including slots, bingo, live casino, and specialty games to players across the Philippines — from Manila and Makati to Cebu, Davao, and Quezon City. As part of delivering these services, we necessarily collect and process certain personal information about our users.

This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (PDPA), and its Implementing Rules and Regulations. It governs all personal data collected through the jilispins website, mobile platform, customer support channels, and any other touchpoints associated with our services.

We act as the Personal Information Controller with respect to the personal data you provide to us. This means we determine the purposes and means by which your personal data is processed. Where we engage third-party service providers to process data on our behalf, they act as Personal Information Processors and are bound by strict data processing agreements.

2. Data We Collect

jilispins collects personal information that is necessary to provide our services, comply with legal obligations, and improve your experience on the platform. The categories of data we collect include:

2.1 Information You Provide Directly

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., SSS, PhilHealth, Passport, Driver's License).
• Contact Data: Email address, mobile number, and residential address (including city, province, and postal code).
• Account Data: Username, password (stored in encrypted form), security questions, and account preferences.
• Financial Data: Payment method details (GCash number, PayMaya account, bank account details for BPI, BDO, Metrobank, and other Philippine banks), transaction history, deposit and withdrawal records.
• Verification Documents: Copies of government-issued IDs, proof of address, and proof of payment method ownership submitted during KYC (Know Your Customer) verification.
• Communications: Records of your interactions with our customer support team, including live chat transcripts, emails, and feedback submissions.

2.2 Information Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, session duration, click patterns, search queries within the platform, and features used.
• Location Data: General geographic location derived from your IP address, used to verify that you are accessing the platform from the Philippines.
• Cookie Data: Information collected through cookies and similar tracking technologies as described in Section 6 of this policy.

2.3 Information from Third Parties

• Identity and fraud verification data from third-party KYC and AML (Anti-Money Laundering) service providers.
• Payment verification data from payment processors and financial institutions.
• Publicly available information used to verify your identity or detect fraudulent activity.

Data Category	Examples	Purpose
Identity	Name, DOB, Government ID	Account registration, age verification, KYC
Contact	Email, mobile, address	Account management, notifications, support
Financial	GCash, bank details, transactions	Deposits, withdrawals, fraud prevention
Technical	IP address, device info	Security, geolocation compliance
Usage	Games played, session data	Platform improvement, responsible gaming
Communications	Support chats, emails	Customer service, dispute resolution

3. How We Use Your Data

jilispins uses your personal data only for legitimate purposes directly related to the provision of our services. Specifically, we use your data to:

• Create and manage your jilispins account, including verifying your identity and age (21+ requirement under Philippine law).
• Process deposits and withdrawals through GCash, PayMaya, and Philippine bank transfers.
• Provide access to our games, promotions, bonuses, and other platform features.
• Comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements, PAGCOR compliance, and the Data Privacy Act of 2012.
• Detect, investigate, and prevent fraudulent activity, cheating, bonus abuse, and other prohibited conduct.
• Monitor and enforce responsible gaming measures, including deposit limits, session limits, and self-exclusion requests.
• Send you transactional communications such as deposit confirmations, withdrawal notifications, and security alerts.
• Send you promotional communications about bonuses, new games, and special offers — only where you have consented to receive such communications.
• Analyze platform usage to improve our services, fix bugs, and develop new features.
• Respond to your customer support inquiries and resolve disputes.
• Conduct internal audits, risk assessments, and business analytics.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, jilispins processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and jilispins — specifically, to provide you with access to our platform and services.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including AML obligations, PAGCOR requirements, and tax reporting duties.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as sending marketing communications or using non-essential cookies, we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

jilispins does not sell, rent, or trade your personal information to third parties. We may share your data only in the following limited circumstances:

5.1 Service Providers

We share data with trusted third-party service providers who assist us in operating the platform, including payment processors (GCash, PayMaya, Philippine banks), KYC and identity verification providers, game software providers, cloud hosting and infrastructure providers, customer support tools, and analytics platforms. All service providers are bound by data processing agreements and are prohibited from using your data for any purpose other than providing services to jilispins.

5.2 Legal and Regulatory Authorities

We may disclose your personal data to government agencies, law enforcement authorities, courts, or regulators where required by law, court order, or regulatory requirement. This includes disclosures to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other relevant Philippine authorities.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and ensure that your data continues to be protected in accordance with this Privacy Policy.

5.4 With Your Consent

We may share your data with other third parties where you have given us explicit consent to do so.

6. Cookies & Tracking Technologies

jilispins uses cookies and similar tracking technologies to enhance your experience on our platform, analyze usage patterns, and deliver relevant content. Cookies are small text files stored on your device when you visit our website.

6.1 Types of Cookies We Use

• Essential Cookies: Required for the platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game preferences, and display options to personalize your experience.
• Analytics Cookies: Help us understand how players use the platform, which pages are most visited, and where improvements can be made. Data collected is aggregated and anonymized.
• Marketing Cookies: Used to deliver relevant promotional content and track the effectiveness of our marketing campaigns. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the jilispins platform. For more information on managing cookies, refer to your browser's help documentation.

7. Data Retention

jilispins retains your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML and PAGCOR record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• KYC Documents: Retained for a minimum of five (5) years after the end of the business relationship.
• Customer Support Records: Retained for three (3) years from the date of the interaction.
• Marketing Consent Records: Retained until you withdraw consent, plus an additional period as required for legal compliance.

When your data is no longer required, we will securely delete or anonymize it in accordance with our data disposal procedures.

8. Your Rights Under the Data Privacy Act

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

• Right to Be Informed: You have the right to know what personal data we collect, how we use it, and with whom we share it.
• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 14. We will respond to all verified requests within thirty (30) days.

9. Data Security

jilispins implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is protected using 256-bit SSL/TLS encryption. Sensitive data such as passwords and financial information is encrypted at rest using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data undergo regular security training.
• Firewalls and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and continuous security monitoring.
• Regular Security Audits: We conduct regular penetration testing, vulnerability assessments, and security audits to identify and address potential weaknesses.
• Incident Response: We maintain a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected individuals within 72 hours of becoming aware of the breach, as required by law.

10. Children's Privacy

The jilispins platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming laws. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has provided personal information to jilispins, please contact us immediately at the details provided in Section 14 so that we can take appropriate action.

11. Third-Party Services

The jilispins platform integrates with third-party services to deliver certain features, including game content from licensed game providers, payment processing through GCash, PayMaya, and Philippine banking partners, and identity verification services. These third parties operate under their own privacy policies and data protection practices.

jilispins is not responsible for the privacy practices of third-party service providers. However, we carefully vet all partners and require them to maintain data protection standards consistent with applicable Philippine law and our own privacy commitments. All third-party processors are bound by data processing agreements that restrict their use of your data to the specific services they provide to jilispins.

12. International Data Transfers

Some of our third-party service providers, including cloud infrastructure and game software providers, may be located outside the Philippines. Where your personal data is transferred to countries that may not provide the same level of data protection as the Philippines, jilispins ensures that appropriate safeguards are in place, including contractual clauses that require the recipient to protect your data to the same standard required under the Data Privacy Act of 2012.

By using the jilispins platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

13. Updates to This Privacy Policy

jilispins reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify registered users via email and post a prominent notice on the platform. The "Effective Date" at the top of this policy will be updated to reflect the date of the most recent revision.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Your continued use of the jilispins platform following the posting of changes constitutes your acceptance of the updated policy.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 on the jilispins platform
• Address: jilispins Data Protection Officer, Metro Manila, Philippines

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