Privacy Policy

Welcome to the 91jili Privacy Policy. 91jili is committed to protecting the personal data of all players and visitors who interact with our platform at https://91jili.app. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and the implementing rules and regulations issued by the National Privacy Commission (NPC).

This Privacy Policy applies to all personal data collected, processed, stored, and disclosed by 91jili in connection with your use of the 91jili website, mobile application, and all related services. It applies to registered players, prospective players who browse the platform without registering, and any individual who contacts 91jili through our support channels.

By accessing or using the 91jili 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 any part of this Privacy Policy, please discontinue use of the platform immediately.

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, 91jili acts as the personal information controller in respect of the personal data collected from players and users of the platform.

As the personal information controller, 91jili determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data protection law and the principles of transparency, legitimate purpose, and proportionality.

If you have any questions, concerns, or requests relating to the processing of your personal data by 91jili, you may contact our Data Protection Officer through the contact details provided in Section 14 of this Privacy Policy.

91jili collects the following categories of personal data from players and users of the platform. We only collect data that is necessary for the specific purposes described in this Privacy Policy.

3.1 Identity and Registration Data

• Full legal name as it appears on a government-issued identification document
• Date of birth (for age verification purposes — players must be 21 years of age or older)
• Gender
• Nationality and country of residence
• Government-issued identification number (e.g., Philippine National ID, passport, driver's license)
• Username and encrypted password

3.2 Contact Data

• Email address
• Mobile phone number
• Residential address, including barangay, city or municipality, province, and postal code

3.3 Financial and Transaction Data

• Payment method details (e.g., GCash account number, PayMaya account, BPI or BDO bank account details, Metrobank account details)
• Deposit and withdrawal transaction history
• Account balance information
• Bonus and promotional credit history

3.4 Gaming Activity Data

• Game session history, including games played, stakes placed, and outcomes
• Betting patterns and wagering history
• Bonus usage and wagering requirement progress
• Responsible gaming tool settings, including deposit limits and self-exclusion status

3.5 Technical and Device Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system, and browser type and version
• Unique device identifiers
• Session duration and login timestamps
• Referring URL and navigation data within the platform

3.6 Communications Data

• Records of communications between you and 91jili's customer support team, including chat transcripts and email correspondence
• Feedback, complaints, and dispute records

91jili collects personal data through the following means:

• Direct Collection: Data you provide directly when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and device data collected automatically when you access and use the 91jili platform, including through cookies, web beacons, and similar tracking technologies as described in Section 9.
• Third-Party Sources: Data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank) in connection with financial transactions, and from identity verification service providers used to conduct KYC checks.
• Regulatory Sources: Data received from PAGCOR or other regulatory authorities in connection with compliance obligations, including self-exclusion register information.

91jili processes your personal data only for specific, legitimate purposes and on a recognized legal basis under the Data Privacy Act of 2012. The table below sets out the primary purposes for which we process your data and the corresponding legal basis.

Where 91jili relies on legitimate interest as the legal basis for processing, we have assessed that our legitimate interests are not overridden by your interests, rights, or freedoms, taking into account the nature of the data processed and the reasonable expectations of players using an online gaming platform.

91jili does not sell, rent, or trade your personal data to any third party 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 Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely for the purpose of processing your financial transactions on the platform.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance obligations.
• IT and Platform Service Providers: Cloud hosting providers, cybersecurity firms, and software vendors who support the operation and maintenance of the 91jili platform, under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulation.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by 91jili, subject to professional confidentiality obligations.
• Business Successors: In the event of a merger, acquisition, or sale of all or part of 91jili's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

91jili retains your personal data only for as long as is 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 and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements under Philippine law.
• Transaction and Financial Data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AMLC regulations and applicable tax record-keeping requirements.
• Gaming Activity Data: Retained for a minimum of three (3) years from the date of the relevant gaming session, for dispute resolution and regulatory compliance purposes.
• Communications Data: Customer support records are retained for a minimum of two (2) years from the date of the last communication.
• Technical and Device Data: Log data is retained for a maximum of twelve (12) months, unless required to be retained longer for security investigation or legal proceedings.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 91jili's data disposal procedures. Anonymized data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical and analytical purposes.

91jili implements a comprehensive set of technical and organizational security measures designed 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 91jili platform is encrypted using Transport Layer Security (TLS). Sensitive data at rest, including identity documents and payment information, is encrypted using AES-256 or equivalent standards.
• Access Controls: Access to personal data is restricted to authorized 91jili personnel and service providers on a strict need-to-know basis. All access is logged and subject to regular review.
• Two-Factor Authentication: 91jili supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security.
• Regular Security Assessments: 91jili conducts regular vulnerability assessments and penetration testing of its platform and infrastructure to identify and remediate security weaknesses.
• Incident Response: 91jili maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, 91jili will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

While 91jili takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your own account credentials and for notifying 91jili immediately if you suspect any unauthorized access to your account.

91jili 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: These cookies are essential for the platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: These cookies remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience.
• Analytics Cookies: These cookies collect anonymized information about how players use the platform, including which pages are visited most frequently and how players navigate between sections. This data helps 91jili improve the platform experience.
• Security Cookies: These cookies support fraud detection and prevention functions, including identifying unusual login patterns and suspicious activity.

You may manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of the 91jili platform. Strictly necessary cookies cannot be disabled through browser settings without impacting your ability to use the platform.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by 91jili:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, stored, and disclosed, as set out in this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data 91jili holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have 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 91jili's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data where 91jili relies on legitimate interest as the legal basis, or where your data is being processed for direct marketing purposes.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another personal information controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that 91jili has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact 91jili's Data Protection Officer using the contact details in Section 14. We will respond to all verified requests within fifteen (15) business days. We may require you to verify your identity before processing your request.

The 91jili platform is strictly intended for adults aged 21 years and above, in compliance with Philippine gambling regulations. 91jili does not knowingly collect, process, or store personal data from individuals under the age of 21.

If 91jili becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. Any winnings generated by an underage player will be forfeited.

If you are a parent or guardian and believe that your child has registered on the 91jili platform or provided personal data to us, please contact our support team immediately so that we can take appropriate action.

In the course of operating the 91jili platform, your personal data may be transferred to, stored in, or processed in countries other than the Philippines, including countries where 91jili's technology infrastructure or service providers are located.

Where such cross-border transfers occur, 91jili ensures that appropriate safeguards are in place to protect your personal data in accordance with the requirements of the Data Privacy Act of 2012. These safeguards may include:

• Contractual clauses requiring the recipient to process your personal data to a standard equivalent to that required under Philippine law.
• Transfers to countries that have been assessed as providing an adequate level of data protection.
• Binding corporate rules or equivalent internal data transfer mechanisms where applicable.

By using the 91jili platform and providing your personal data, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Privacy Policy, subject to the safeguards described above.

91jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Privacy Policy, 91jili will notify registered players through one or more of the following methods:

• A prominent notice displayed on the 91jili platform upon your next login.
• An email notification sent to your registered email address.
• A notification through the platform's in-app messaging system.

The updated Privacy Policy will take effect on the date specified in the notice. Your continued use of the 91jili platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 91jili protects your personal data. The "Last Updated" date at the top of this page indicates when the most recent revision was made.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 91jili, please contact our Data Protection Officer through the following channel:

• Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week
• Response Time: We aim to respond to all privacy-related inquiries within 15 business days.

When contacting us, please clearly state that your inquiry relates to a data privacy matter and include your registered account username or email address so that we can locate your records and respond efficiently.

If you are not satisfied with 91jili's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.