128jili Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") describes how 128jili ("the Company," "we," "us," or "our") collects, uses, stores, shares, and protects the personal data of individuals ("you," "the Player," or "the User") who access or use the 128jili platform, website, mobile application, and related services (collectively, "the Platform").

1.2 128jili is committed to protecting the privacy and personal data of all players, particularly those based in the Republic of the Philippines. This Policy is designed to comply with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission ("NPC").

1.3 By registering an account, making a deposit, or otherwise using the 128jili Platform, you acknowledge that you have read and understood this Privacy 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 not use the Platform.

1.4 This Policy should be read together with the 128jili Terms & Conditions and the Responsible Gaming Policy, both of which are available on the 128jili Platform.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012 and this Policy, 128jili acts as the personal information controller in respect of the personal data collected through the Platform.

2.2 128jili has appointed a Data Privacy Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

3.1 128jili collects the following categories of personal data:

3.2 Sensitive Personal Information. In certain circumstances, 128jili may collect sensitive personal information as defined under the DPA, including government-issued identification numbers (e.g., Philippine National ID, SSS/GSIS number, TIN) for KYC and AML compliance purposes. Such data is processed with heightened security measures and is accessed only by authorized personnel on a strict need-to-know basis.

3.3 Voluntary Provision. You are not legally required to provide your personal data to 128jili. However, failure to provide certain mandatory information (such as identity and contact data) will prevent us from creating and maintaining your account or processing your transactions.

4. How We Collect Your Data

4.1 128jili collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you use the Platform, including cookies, web beacons, pixel tags, server logs, and similar tracking technologies (see Section 8).
• Third-party sources: Data received from payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank), identity verification service providers, fraud prevention agencies, and analytics partners, where permitted by applicable law.
• Publicly available sources: In limited circumstances, data from publicly available sources such as government registries, where relevant to KYC or AML compliance.

5. How We Use Your Personal Data

5.1 128jili uses your personal data for the following purposes:

• To create, verify, and manage your 128jili account;
• To process deposits, withdrawals, and other financial transactions;
• To verify your identity and age (21+) in compliance with applicable regulations;
• To comply with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) obligations;
• To detect, investigate, and prevent fraud, cheating, and other prohibited conduct;
• To provide customer support and resolve disputes;
• To monitor your gaming activity for responsible gaming purposes and to enforce self-exclusion requests;
• To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts);
• To send you promotional communications and personalized offers, where you have provided consent;
• To improve the Platform, develop new features, and conduct internal analytics;
• To comply with legal obligations imposed by Philippine law and applicable gaming regulations.

6. Legal Basis for Processing

6.1 128jili processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary to perform the contract between you and 128jili (i.e., the Terms & Conditions), including account management and payment processing.
• Legal obligation: Where processing is required to comply with a legal obligation applicable to 128jili, including KYC, AML, and CTF requirements under Philippine law.
• Legitimate interests: Where processing is necessary for the legitimate interests of 128jili or a third party, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.

6.2 Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, please contact the 128jili DPO using the details in Section 15.

7. Sharing Your Personal Data

7.1 128jili does not sell, rent, or otherwise disclose your personal data to unaffiliated third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors and financial institutions: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment partners, for the purpose of processing your transactions;
• Identity verification and KYC providers: Third-party service providers engaged to verify your identity and age in compliance with applicable regulations;
• Fraud prevention and security providers: Service providers that assist 128jili in detecting and preventing fraud, money laundering, and other prohibited conduct;
• IT and platform service providers: Cloud hosting, data storage, and software service providers engaged to operate and maintain the 128jili Platform;
• Analytics providers: Service providers that assist 128jili in understanding how the Platform is used and improving the player experience;
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies in the Philippines and internationally, where disclosure is required by law or necessary to protect the rights and safety of 128jili or others;
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by 128jili in connection with its business operations.

7.2 All third-party service providers engaged by 128jili are required to process personal data only in accordance with 128jili's instructions and applicable data protection law, and to implement appropriate technical and organizational security measures.

8. Cookies & Tracking Technologies

8.1 128jili uses cookies and similar tracking technologies to operate and improve the Platform, to remember your preferences, and to analyze how the Platform is used. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and security features.
• Performance and analytics cookies: Used to collect anonymized information about how players use the Platform, such as which pages are visited most frequently. This helps 128jili improve the Platform experience.
• Functionality cookies: Used to remember your preferences and settings, such as your preferred language and display options.
• Marketing cookies: Used to deliver relevant promotional content and to measure the effectiveness of marketing campaigns. These are only set where you have provided consent.

8.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 128jili Platform. For strictly necessary cookies, no opt-out is available as they are essential to the operation of the Platform.

9. Data Retention

9.1 128jili retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulation. 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 accordance with AML and gaming regulatory requirements under Philippine law.
• Financial transaction data: Retained for a minimum of five (5) years following the date of the transaction, as required by applicable AML regulations.
• Communications data: Retained for up to three (3) years following the date of the communication, or longer if relevant to an ongoing dispute or legal proceeding.
• Technical and usage data: Retained for up to two (2) years, after which it is anonymized or deleted.
• Marketing preference data: Retained until you withdraw your consent or request deletion.

9.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 128jili's data retention and disposal procedures.

10. Data Security

10.1 128jili 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:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest using industry-standard algorithms;
• Role-based access controls limiting access to personal data to authorized personnel only;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Comprehensive incident response and data breach notification procedures.

10.2 While 128jili takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, 128jili will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by the DPA.

11. Your Rights as a Data Subject

11.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 128jili:

11.2 To exercise any of the above rights, please submit a written request to the 128jili Data Privacy Officer using the contact details provided in Section 15. 128jili will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with the DPA and its IRR.

11.3 128jili may need to verify your identity before processing a data subject request. This is to ensure that personal data is not disclosed to unauthorized persons.

12. Children's Privacy

12.1 The 128jili Platform is strictly intended for individuals who are 21 years of age or older. 128jili does not knowingly collect personal data from individuals under the age of 21. If 128jili becomes aware that personal data has been collected from a person under 21, that account will be immediately closed, all deposits refunded, and the associated personal data deleted.

12.2 If you are a parent or guardian and believe that your child has registered on the 128jili Platform, please contact us immediately using the details in Section 15 so that we can take appropriate action.

13. International Data Transfers

13.1 128jili primarily processes personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines, for example where 128jili engages third-party service providers located abroad.

13.2 Where personal data is transferred outside the Philippines, 128jili ensures that appropriate safeguards are in place to protect your data, including contractual clauses that impose data protection obligations on the recipient equivalent to those required under the DPA, or by transferring data only to countries that have been assessed as providing an adequate level of data protection.

14. Updates to This Privacy Policy

14.1 128jili reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. When material changes are made, 128jili will notify registered players by email or by posting a prominent notice on the Platform.

14.2 The date of the most recent revision is indicated at the top of this page. Your continued use of the 128jili Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy.

15. Contact Us & Data Privacy Officer

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 128jili, please contact our Data Privacy Officer:

15.2 If you are not satisfied with 128jili's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the NPC's official website.

15.3 For matters relating to responsible gaming, account self-exclusion, or problem gambling, please contact our dedicated responsible gaming team through the same email address. Responsible gaming inquiries are treated as a priority.