Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by 93jili through our website at https://93jili.cam, mobile applications, customer support channels, and any other services we provide (collectively referred to as the "Platform" or "Services"). This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations issued by the National Privacy Commission (NPC).

93jili operates as a licensed online gaming platform under the regulatory authority of the Philippine Amusement and Gaming Corporation (PAGCOR). As such, we are required to collect, process, and retain certain personal information to comply with applicable gaming regulations, anti-money laundering laws, and know-your-customer (KYC) requirements. This Privacy Policy explains our data practices in detail and outlines your rights as a data subject under Philippine law.

§ 2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information is:

§ 3. Personal Information We Collect

93jili collects various categories of personal information necessary to provide our gaming services, ensure account security, comply with legal obligations, and enhance user experience. The types of personal information we collect include:

3.1 Account Registration Information

When you register for a 93jili account, we collect the following mandatory information:

• Full Legal Name: Your complete name as it appears on government-issued identification documents.
• Date of Birth: To verify that you meet the minimum age requirement of 21 years.
• Email Address: For account verification, communication, and password recovery.
• Mobile Phone Number: For SMS verification, two-factor authentication, and important account notifications.
• Residential Address: Your current physical address in the Philippines, including street address, city/municipality, province, and postal code.
• Username and Password: Your chosen login credentials (passwords are stored in encrypted form only).
• Preferred Currency: PHP (Philippine Peso) for all transactions.

3.2 Identity Verification Documents

To comply with PAGCOR regulations and anti-money laundering laws, we are required to verify your identity through the collection of the following documents:

• Government-Issued Photo ID: Philippine passport, driver's license, national ID, voter's ID, or other government-issued identification containing your photograph, full name, date of birth, and signature.
• Proof of Address: Utility bill (electricity, water, gas), bank statement, or government correspondence dated within the last three (3) months showing your name and residential address.
• Selfie with ID: A photograph of you holding your government-issued ID next to your face for biometric verification purposes.
• Proof of Payment Method: Screenshots or photographs of payment instruments (e-wallet accounts, bank cards) used for deposits and withdrawals, showing your name and account details.

3.3 Financial and Transaction Data

• Payment Method Information: E-wallet account numbers (GCash, PayMaya), bank account details, or credit/debit card information (last four digits only; full card numbers are processed by PCI-DSS compliant payment processors).
• Transaction History: Complete records of all deposits, withdrawals, wagers, winnings, bonuses claimed, and account balance changes.
• Deposit and Withdrawal Amounts: Monetary values of all financial transactions on the platform.
• Payment Processor Data: Transaction IDs, timestamps, payment status, and processor-specific identifiers.

3.4 Gaming and Activity Data

• Game Play History: Records of all games played, including game titles, bet amounts, outcomes, timestamps, and session durations.
• Betting Patterns: Statistical analysis of your gaming behavior, including favorite games, average bet sizes, win/loss ratios, and play frequency.
• Bonus and Promotion Usage: Records of bonuses claimed, wagering progress, bonus terms compliance, and promotional campaign participation.
• Chat Logs: Conversations with customer support representatives and, where applicable, chat messages sent through in-game chat features.
• Account Activity Logs: Login/logout timestamps, password changes, settings modifications, and other account management actions.

3.5 Technical and Device Information

• IP Address: Your Internet Protocol address, used for geolocation verification, fraud detection, and security monitoring.
• Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers (such as UDID or advertising ID).
• Connection Information: Internet service provider, connection type (WiFi, mobile data), and network quality metrics.
• Cookies and Similar Technologies: Session cookies, persistent cookies, local storage data, and tracking pixels (see Section 6 for detailed information).
• Geolocation Data: Approximate location data derived from IP address or, with your consent, precise GPS coordinates from mobile devices.

3.6 Marketing and Communication Preferences

• Communication Consent: Your preferences regarding promotional emails, SMS notifications, push notifications, and phone calls.
• Campaign Interaction Data: Email open rates, click-through rates, and responses to promotional offers.
• Survey and Feedback Responses: Voluntary feedback provided through customer satisfaction surveys, product reviews, or feedback forms.

§ 4. How We Use Your Personal Information

93jili processes your personal information for the following purposes, each of which is necessary for the provision of our services or required by applicable law:

PURPOSE	DATA CATEGORIES	LEGAL BASIS
Account Registration and Management	Registration information, login credentials, account preferences	Contract performance, consent
Identity Verification and KYC Compliance	Government ID, proof of address, selfie verification, biometric data	Legal obligation (PAGCOR regulations, AMLA compliance)
Payment Processing	Payment method details, transaction history, financial records	Contract performance, legal obligation
Game Provision and Management	Gaming history, betting patterns, game preferences, balance information	Contract performance, legitimate interest
Fraud Detection and Prevention	IP address, device information, betting patterns, transaction data	Legal obligation, legitimate interest
Customer Support	Contact information, chat logs, support tickets, account details	Contract performance, legitimate interest
Responsible Gaming Monitoring	Gaming behavior, session duration, deposit limits, self-exclusion requests	Legal obligation, legitimate interest
Marketing Communications	Email, phone number, marketing preferences, campaign interaction data	Consent (can be withdrawn at any time)
Platform Improvement and Analytics	Technical data, usage patterns, device information, aggregated statistics	Legitimate interest
Legal and Regulatory Compliance	All collected data as required by law	Legal obligation (PAGCOR, NPC, AMLC requirements)

4.1 Detailed Purpose Descriptions

• Account Creation and Authentication: We use your registration information to create and maintain your 93jili account, authenticate your identity during login, and enable access to our gaming services.
• Age Verification: We verify your age to ensure compliance with the minimum age requirement of 21 years as mandated by Philippine gaming regulations.
• Payment Processing: We process your financial information to facilitate deposits, execute withdrawal requests, maintain accurate account balances, and comply with financial reporting requirements.
• Fraud Prevention: We analyze transaction patterns, device information, and behavioral data to detect and prevent fraudulent activity, money laundering, bonus abuse, and unauthorized account access.
• Responsible Gaming: We monitor your gaming activity to identify potential problem gambling behaviors, enforce deposit and wagering limits, and implement self-exclusion measures when requested.
• Customer Service: We use your contact information and account details to respond to inquiries, resolve disputes, provide technical support, and maintain customer relationship management records.
• Marketing and Promotions: With your consent, we send promotional offers, bonus notifications, new game announcements, and other marketing communications via email, SMS, or push notifications.
• Platform Optimization: We analyze aggregated user data to improve game performance, enhance user interface design, fix technical issues, and develop new features.

§ 5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, we process your personal information based on the following legal grounds:

• Consent: You have provided explicit, informed consent for us to process your personal information for specific purposes (e.g., marketing communications, location services). You may withdraw your consent at any time by contacting our Data Protection Officer.
• Contract Performance: Processing is necessary to perform our contractual obligations under the Terms and Conditions you agreed to when registering your account (e.g., providing gaming services, processing payments, managing your account).
• Legal Obligation: Processing is required to comply with Philippine laws and regulations, including PAGCOR licensing requirements, anti-money laundering laws (AMLA), tax reporting obligations, and data protection laws.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, network security, business analytics, and service improvement, provided such interests are not overridden by your fundamental rights and freedoms.

§ 6. Cookies and Tracking Technologies

93jili uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance user experience, analyze platform usage, and deliver personalized content. This section explains what these technologies are and how we use them:

6.1 Types of Cookies We Use

• Essential Cookies: These cookies are strictly necessary for the operation of our platform. They enable core functionalities such as account authentication, session management, security features, and payment processing. You cannot opt out of essential cookies as they are required for the platform to function properly.
• Performance Cookies: These cookies collect aggregated information about how visitors use our platform, such as which pages are visited most frequently, average session duration, and error messages encountered. This data helps us improve platform performance and user experience.
• Functionality Cookies: These cookies remember your preferences and settings (such as language preference, currency display, and favorite games) to provide a more personalized experience during return visits.
• Advertising Cookies: With your consent, we use advertising cookies to deliver relevant promotional content based on your interests and gaming behavior. These cookies may track your activity across different websites (third-party cookies) to provide targeted advertising.
• Analytics Cookies: We use third-party analytics services (such as Google Analytics) to collect statistical data about platform usage, user demographics, and traffic sources. This information is used to optimize our marketing strategies and improve service delivery.

6.2 Managing Cookie Preferences

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies, receive notifications when cookies are set, or browse in private/incognito mode. However, please note that disabling certain cookies may limit your ability to use some features of the 93jili platform. To manage your cookie preferences, please refer to your browser's help documentation or visit the cookie settings panel on our website.

§ 7. Data Sharing and Disclosure

93jili does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your personal information with the following categories of recipients when necessary to provide our services or comply with legal obligations:

7.1 Service Providers and Business Partners

• Payment Processors: We share necessary financial information with third-party payment service providers (GCash, PayMaya, bank partners) to process deposits and withdrawals. These processors are PCI-DSS compliant and bound by strict confidentiality agreements.
• Game Providers: We share limited account information with third-party game developers and software providers to enable game functionality and track gaming activity.
• Identity Verification Services: We use third-party KYC verification services to authenticate government-issued IDs and verify your identity in compliance with regulatory requirements.
• Customer Support Platforms: We use third-party customer relationship management (CRM) systems and live chat services to provide customer support.
• Cloud Hosting Providers: We store data on secure cloud servers operated by reputable hosting providers with robust data security measures.
• Analytics and Marketing Platforms: We share aggregated, anonymized data with analytics providers to measure platform performance and marketing campaign effectiveness.

7.2 Legal and Regulatory Authorities

We may disclose your personal information to government authorities, regulatory bodies, and law enforcement agencies when:

• Required by Philippine law, court order, subpoena, or other legal process.
• Requested by PAGCOR, the National Privacy Commission, or other regulatory authorities conducting audits or investigations.
• Necessary to comply with anti-money laundering reporting obligations under the Anti-Money Laundering Act (AMLA).
• Required to protect the rights, property, or safety of 93jili, our users, or the public.
• Necessary to detect, prevent, or investigate fraud, security breaches, or illegal activities.

7.3 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, subject to the same privacy protections outlined in this Privacy Policy. We will notify you of any such change in ownership or control of your personal information.

§ 8. International Data Transfers

Your personal information is primarily stored and processed within the Republic of the Philippines. However, some of our service providers and business partners may be located outside the Philippines, which may involve the transfer of your personal data to countries with different data protection standards.

When we transfer personal information internationally, we ensure adequate protection through:

• Standard contractual clauses approved by the National Privacy Commission.
• Binding corporate rules that ensure consistent data protection across jurisdictions.
• Adequacy decisions recognizing that the recipient country provides an adequate level of data protection.
• Your explicit consent for specific international transfers.

§ 9. Data Security and Protection Measures

93jili implements industry-leading technical, organizational, and administrative security measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

§ 10. Data Retention and Deletion

93jili retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by Philippine law. Our specific retention periods are as follows:

DATA CATEGORY	RETENTION PERIOD	LEGAL BASIS
Account Registration Information	Duration of account activity + 5 years after closure	PAGCOR regulatory requirements
Identity Verification Documents	5 years after account closure	AMLA compliance, KYC regulations
Financial Transaction Records	5 years from transaction date	AMLA, BIR tax requirements
Gaming Activity Logs	3 years from activity date	PAGCOR audit requirements
Customer Support Communications	2 years from last communication	Customer service quality, dispute resolution
Marketing Consent Records	Until consent is withdrawn + 1 year	Proof of consent, regulatory compliance
Technical Logs (IP addresses, cookies)	12 months from collection	Security monitoring, fraud prevention

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with industry best practices and data protection standards. Anonymized data that cannot be used to identify you may be retained indefinitely for statistical and analytical purposes.

§ 11. Your Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal information:

11.1 Right to be Informed

You have the right to be informed about the collection, use, and processing of your personal information. This Privacy Policy serves as our primary means of providing such information. We will notify you of any material changes to our data processing practices.

11.2 Right to Access

You have the right to request access to your personal information held by 93jili. Upon verification of your identity, we will provide you with a copy of your personal data in a structured, commonly used, and machine-readable format. You may submit an access request by contacting our Data Protection Officer at [email protected].

11.3 Right to Rectification

You have the right to request correction of inaccurate, incomplete, or outdated personal information. You can update most of your account information directly through your account settings. For information that cannot be self-updated (such as verified identity documents), please contact customer support with supporting documentation.

11.4 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal information when:

• The personal information is no longer necessary for the purposes for which it was collected.
• You withdraw your consent and there is no other legal basis for processing.
• The personal information was unlawfully processed.
• Deletion is required to comply with a legal obligation.

However, this right is not absolute. We may refuse deletion requests when retention is necessary for legal compliance, regulatory obligations, or the establishment, exercise, or defense of legal claims.

11.5 Right to Object

You have the right to object to the processing of your personal information when such processing is based on legitimate interests or for direct marketing purposes. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

11.6 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and transmit it to another data controller without hindrance, where technically feasible.

11.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw marketing consent by clicking "unsubscribe" in promotional emails or adjusting your communication preferences in your account settings.

11.8 How to Exercise Your Rights

To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected]. Include your full name, registered email address, account username, and a detailed description of your request. We may require additional information to verify your identity before processing your request. We will respond to all valid requests within fifteen (15) business days, as required by the Philippine Data Privacy Act.

§ 12. Children's Privacy

93jili's services are intended exclusively for individuals who are at least twenty-one (21) years of age. We do not knowingly collect, process, or retain personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal information from a person under the minimum age requirement, we will take immediate steps to delete such information from our systems.

If you are a parent or legal guardian and believe that your minor child has provided personal information to 93jili, please contact us immediately at [email protected] so that we can take appropriate action to remove the information and terminate the account.

§ 13. Changes to This Privacy Policy

93jili reserves the right to update, modify, or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this Privacy Policy, we will:

• Update the "Last Updated" date at the top of this document.
• Notify registered users via email to their registered email address.
• Display a prominent notice on the 93jili platform homepage.
• Where required by law, obtain your renewed consent to the updated Privacy Policy.

Your continued use of the 93jili platform following notification of changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

§ 14. Contact Information and Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer: