33jili Privacy Policy

1. Overview & Scope

This Privacy Policy ("Policy") applies to all personal data collected, processed, and stored by 33jili ("we," "us," or "our") in connection with your use of the 33jili online gaming platform, including the website at https://33jili.app, any associated mobile applications, and all related services (collectively, the "Platform").

By registering an account or otherwise using the 33jili Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform.

This Policy should be read together with the 33jili Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

33jili acts as the Personal Information Controller (PIC) with respect to the personal data you provide. Where third-party service providers process data on our behalf, they act as Personal Information Processors (PIPs) and are bound by data processing agreements consistent with this Policy and applicable law.

2. Personal Data We Collect

33jili collects the following categories of personal data, depending on how you interact with the Platform:

3. How We Collect Your Data

33jili collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access or use the Platform.
• Third-Party Sources: Identity verification data from KYC service providers; fraud detection signals from anti-fraud partners; payment confirmation data from payment processors such as GCash, Maya, and Philippine banking partners.
• Publicly Available Sources: In limited circumstances, we may supplement your profile with information from publicly available sources for fraud prevention or regulatory compliance purposes.

4. Purpose of Data Processing

33jili processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and managing your 33jili player account, including authentication and access control.
• Identity Verification (KYC): Verifying your identity and age (21+) in compliance with PAGCOR regulations and anti-money laundering (AML) requirements.
• Transaction Processing: Processing deposits, withdrawals, and bonus transactions accurately and securely.
• Service Delivery: Providing access to games, promotions, customer support, and all other Platform features.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other illegal or prohibited conduct.
• Regulatory Compliance: Meeting our obligations under PAGCOR licensing conditions, the Data Privacy Act of 2012, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Responsible Gaming: Monitoring gaming behavior to identify potential problem gambling indicators and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform Improvement: Analyzing usage patterns to improve Platform performance, user experience, and game offerings.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time.
• Dispute Resolution: Maintaining records necessary to investigate and resolve disputes, complaints, and legal claims.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 33jili processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you — i.e., to provide the gaming services you have registered for, including account management, transaction processing, and game access.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations under PAGCOR licensing conditions and the Anti-Money Laundering Act.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where we have obtained your explicit prior consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Data Sharing & Disclosure

33jili does not sell your personal data to third parties. We may share your data only in the following circumstances:

• Payment Processors: GCash, Maya, and Philippine banking partners receive the minimum financial data necessary to process your transactions.
• KYC & Identity Verification Providers: Third-party identity verification services that assist us in confirming your identity and age in compliance with regulatory requirements.
• Fraud Prevention & Security Partners: Anti-fraud and cybersecurity service providers who help us detect and prevent unauthorized access, money laundering, and other prohibited activities.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory mandate.
• Legal Proceedings: Courts, law enforcement agencies, or other parties where disclosure is required by a valid court order, subpoena, or applicable law.
• Service Providers: Cloud hosting, IT infrastructure, customer support platform, and analytics providers who process data on our behalf under binding data processing agreements that require them to maintain confidentiality and security standards consistent with this Policy.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of 33jili's assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections.

7. Data Retention

33jili retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account & Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing conditions and AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Gaming History: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes.
• Support Communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing Preferences: Retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations.
• Technical & Log Data: Retained for up to twelve (12) months for security monitoring and fraud prevention purposes.

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

8. Data Security

33jili 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:

• Encryption: All data transmitted between your device and the 33jili Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All staff with access to personal data undergo background checks and regular data privacy training.
• Firewalls & Intrusion Detection: The Platform is protected by enterprise-grade firewalls, intrusion detection systems, and continuous security monitoring.
• Secure Payment Processing: Financial transactions are processed through PCI-DSS compliant payment gateways. 33jili does not store full payment card numbers on its servers.
• Regular Security Audits: The Platform undergoes regular penetration testing and security audits by independent cybersecurity professionals.
• Incident Response: In the event of a personal data breach, 33jili will notify affected individuals and the National Privacy Commission within the timeframes prescribed by the Data Privacy Act of 2012 and NPC regulations.

9. Cookies & Tracking Technologies

33jili uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, authentication, and security features. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations to provide a personalized experience.
• Analytics Cookies: Collect anonymized data about how users interact with the Platform to help us improve performance and user experience. Used only with your consent.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of marketing campaigns. Used only with your explicit consent.

You may manage your cookie preferences through your browser settings or through the cookie consent tool on the Platform. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 33jili:

• Right to Be Informed: The right to be informed of how your personal data is collected, used, and processed — as set out in this Policy.
• Right of Access: The right to request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update certain information directly through your account settings.
• 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 overriding 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 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 controller, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details in Section 14. We will respond to all verified requests within thirty (30) days, or within such extended period as permitted by applicable law.

11. Minors & Age Restriction

The 33jili Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data, and return any deposits in accordance with applicable regulations.

If you are a parent or guardian and believe that your child under 21 has provided personal data to 33jili, please contact us immediately at the details provided in Section 14 so that we can take appropriate action.

12. Cross-Border Data Transfers

In the course of providing the Platform and its services, your personal data may be transferred to, stored in, or processed in countries outside the Philippines where our service providers or infrastructure partners operate.

Where such cross-border transfers occur, 33jili ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission.
• Implementing standard contractual clauses or binding corporate rules with recipient entities.
• Ensuring that all cross-border transfers comply with the requirements of the Data Privacy Act of 2012 and NPC regulations on cross-border data flows.

13. Changes to This Policy

33jili reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. Any material changes will be communicated to registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the Platform following the posting of an updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your data.

14. Contact & Data Protection Officer

33jili has appointed a Data Protection Officer (DPO) in accordance with the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us through the following channels: