22jili Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") governs the collection, processing, storage, use, disclosure, and protection of personal information by 22jili ("we," "us," "our," "Company"), a Philippine online gaming operator licensed by the Philippine Amusement and Gaming Corporation (PAGCOR), in connection with the 22jili website, mobile applications, and related gaming services (collectively, "Services").

By accessing or using 22jili Services, registering for an account, or providing personal information to us, you ("User," "you," "your") acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal information as described herein.

If you do not agree with the terms of this Privacy Policy, you must immediately discontinue use of 22jili Services and refrain from providing any personal information. 22jili reserves the right to modify this Policy at any time. Material changes will be communicated via email or prominent notice on our website. Your continued use of the Services following such notification constitutes acceptance of the modified Policy.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a 22jili account or use our Services, you voluntarily provide us with personal information including:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers;
• Contact Information: Email address, mobile phone number, residential address, and postal code;
• Account Credentials: Username, password, security questions, and answers;
• Financial Information: Payment method details including GCash account information, PayMaya account details, bank account numbers, and transaction history;
• Verification Documents: Copies of government-issued identification (passport, driver's license, national ID), proof of address (utility bills, bank statements), and source of funds documentation;
• Communication Data: Content of messages exchanged with customer support, feedback submissions, and correspondence with 22jili.

2.2 Information Collected Automatically

When you access 22jili Services, we automatically collect technical and usage information through cookies, web beacons, and similar technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information;
• Connection Information: IP address, internet service provider, geographic location (country, region, city), time zone settings;
• Usage Data: Pages visited, games played, betting patterns, session duration, click-stream data, referral source, and interaction with promotional offers;
• Performance Data: Application crashes, loading times, error reports, and diagnostic information;
• Cookie Data: Preferences, authentication tokens, session identifiers, and marketing attribution data.

2.3 Information from Third Parties

22jili may receive personal information about you from third-party sources including:

• Payment processors (GCash, PayMaya, banking partners) providing transaction verification and fraud prevention data;
• Identity verification services conducting KYC (Know Your Customer) checks;
• Affiliate partners and marketing platforms tracking referral sources;
• Social media platforms if you choose to connect your account (limited to public profile information);
• Credit reference agencies and fraud prevention databases as required by anti-money laundering regulations.

3. How We Use Your Information

3.1 Primary Processing Purposes

22jili processes your personal information for the following lawful purposes:

• Account Management: Creating and maintaining your user account, authenticating your identity, and providing access to gaming services;
• Transaction Processing: Processing deposits and withdrawals, reconciling payments, maintaining transaction records, and generating account statements;
• Gaming Services: Enabling gameplay, recording betting history, calculating winnings, distributing prizes, and maintaining fair gaming integrity;
• Regulatory Compliance: Verifying age (21+ requirement), conducting KYC/AML checks, fulfilling PAGCOR licensing obligations, and complying with Philippine gaming regulations;
• Security and Fraud Prevention: Detecting and preventing fraudulent activity, monitoring for suspicious transactions, identifying duplicate accounts, and protecting against unauthorized access;
• Customer Support: Responding to inquiries, resolving technical issues, handling complaints, and providing personalized assistance;
• Marketing Communications: Sending promotional offers, bonus notifications, newsletters, and product updates (only with your consent);
• Platform Improvement: Analyzing usage patterns, conducting A/B testing, optimizing user experience, developing new features, and enhancing service quality;
• Legal Obligations: Responding to legal process, cooperating with law enforcement, defending legal claims, and enforcing our Terms and Conditions.

3.2 Legal Basis for Processing

Under the Philippine Data Privacy Act, 22jili processes personal information based on the following legal grounds:

• Consent: You provide explicit consent during account registration and through opt-in mechanisms for marketing communications;
• Contractual Necessity: Processing is necessary to perform our contract with you (providing gaming services);
• Legal Obligation: We are required by law to process certain data for regulatory compliance, anti-money laundering, and age verification;
• Legitimate Interests: We process data to prevent fraud, improve services, and maintain platform security, balancing these interests against your privacy rights.

4. Information Sharing and Disclosure

4.1 Third-Party Service Providers

22jili shares your personal information with trusted third-party service providers who assist us in operating our business. These providers are contractually obligated to protect your data and use it only for specified purposes:

• Payment Processors: GCash, PayMaya, and banking partners process financial transactions and verify payment methods;
• Identity Verification Services: Third-party KYC providers verify your identity documents and conduct background checks;
• Cloud Hosting Providers: Secure data centers store and process your information with enterprise-grade security;
• Customer Support Platforms: CRM systems and live chat providers facilitate customer service interactions;
• Marketing and Analytics Services: Email marketing platforms and analytics tools help us understand user behavior and improve services;
• Game Providers: Licensed software providers power our casino games and sports betting platforms.

4.2 Legal and Regulatory Disclosure

22jili may disclose your personal information when required or permitted by law:

• To PAGCOR and other regulatory authorities for licensing compliance and gaming oversight;
• To law enforcement agencies investigating criminal activity or responding to valid legal process;
• To the Anti-Money Laundering Council (AMLC) when suspicious transactions are identified;
• To courts, tribunals, or dispute resolution bodies in connection with legal proceedings;
• To government agencies enforcing tax obligations or other regulatory requirements;
• To protect 22jili's legal rights, prevent fraud, or respond to security threats.

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity. You will be notified via email and prominent website notice before any such transfer occurs, and you will have the opportunity to close your account if you do not consent to the transfer.

4.4 No Sale of Personal Information

22jili does not sell, rent, or trade your personal information to third parties for their independent marketing purposes. Any data sharing is strictly for the purposes described in this Policy and subject to contractual protections.

5. Data Security and Protection

5.1 Security Measures

22jili implements industry-standard technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data transmitted between your device and 22jili servers is encrypted using TLS/SSL protocols. Sensitive data at rest is encrypted using AES-256 encryption;
• Access Controls: Personal information is accessible only to authorized employees and contractors who require it to perform their duties. Access is granted on a need-to-know basis;
• Authentication: Multi-factor authentication protects administrative access. User accounts are secured with password requirements and optional two-factor authentication;
• Network Security: Firewalls, intrusion detection systems, and DDoS protection safeguard our infrastructure;
• Regular Audits: Third-party security firms conduct periodic penetration testing and vulnerability assessments;
• Data Minimization: We collect only the personal information necessary for specified purposes and retain it no longer than required;
• Employee Training: All staff receive data privacy and security training to ensure proper handling of personal information.

5.2 Data Breach Notification

In the event of a data breach that affects your personal information, 22jili will notify you within seventy-two (72) hours of becoming aware of the breach, as required by the Philippine Data Privacy Act. We will also notify the National Privacy Commission and take immediate steps to contain the breach and prevent further unauthorized access.

6. Data Retention and Deletion

6.1 Retention Periods

22jili retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, subject to legal and regulatory requirements:

• Active Accounts: Information is retained for the duration of your account activity;
• Closed Accounts: Following account closure, personal information is retained for five (5) years to comply with PAGCOR record-keeping requirements and Philippine tax laws;
• Financial Records: Transaction data is retained for seven (7) years as required by anti-money laundering regulations;
• Marketing Consent: Marketing communication data is retained until you withdraw consent or for two (2) years of inactivity;
• Legal Proceedings: Information relevant to ongoing litigation or regulatory investigations is retained until resolution;
• Technical Logs: Server logs and diagnostic data are retained for ninety (90) days unless required for security investigations.

6.2 Deletion Procedures

Upon expiration of retention periods, personal information is securely deleted or anonymized using industry-standard data destruction methods. You may request early deletion of your personal information by contacting our Data Protection Officer, subject to legal obligations that may require continued retention.

7. Your Privacy Rights

7.1 Rights Under Philippine Law

As a data subject under the Philippine Data Privacy Act, you have the following rights:

• Right to Be Informed: You have the right to know how your personal information is collected, processed, and shared;
• Right to Access: You may request copies of your personal information held by 22jili;
• Right to Rectification: You may request correction of inaccurate or incomplete personal information;
• Right to Erasure or Blocking: You may request deletion or blocking of personal information that is unlawfully processed, excessive, or no longer necessary;
• Right to Object: You may object to processing of personal information for direct marketing, automated decision-making, or profiling;
• Right to Data Portability: You may request your personal information in a structured, commonly used, machine-readable format;
• Right to Damages: You may claim compensation for damages suffered due to privacy violations;
• Right to File a Complaint: You may file a complaint with the National Privacy Commission if you believe your privacy rights have been violated.

7.2 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond to your request within fifteen (15) business days. You may be required to verify your identity before we process your request. There is no fee for exercising your rights unless your request is manifestly unfounded or excessive, in which case a reasonable administrative fee may be charged.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

22jili uses cookies and similar tracking technologies to enhance user experience and analyze platform performance:

• Essential Cookies: Required for basic platform functionality including authentication, session management, and security features. These cannot be disabled;
• Performance Cookies: Collect anonymous information about how users interact with our Services to improve functionality;
• Functional Cookies: Remember your preferences such as language settings, game favorites, and display options;
• Marketing Cookies: Track your activity across websites to deliver personalized advertising and measure campaign effectiveness (optional).

8.2 Managing Cookie Preferences

You can manage cookie preferences through your browser settings. However, disabling essential cookies may prevent you from accessing certain features. Most browsers allow you to block third-party cookies while accepting first-party cookies. For detailed instructions, visit your browser's help documentation.

9. Contact Information

9.1 Data Protection Officer

For questions, concerns, or requests regarding this Privacy Policy or your personal information, contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Subject Request"
• Response Time: Within fifteen (15) business days

9.2 National Privacy Commission

If you are not satisfied with our response or believe your privacy rights have been violated, you may file a complaint with the National Privacy Commission of the Philippines:

• Website: www.privacy.gov.ph
• Email: [email protected]
• Address: 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City, Metro Manila