Privacy
Policy

This Privacy Policy ("Policy") is issued by jillf ("jillf," "we," "us," "our") and applies to all personal information collected through the jillf online gaming platform at jillf.vip, including all associated services, features, and communications. This Policy is drafted in compliance with Republic Act No. 10173, known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an account on jillf, depositing funds, using our games, or otherwise interacting with the platform, you acknowledge that you have read and understood this Policy and that you consent to the processing of your personal data as described herein. If you do not agree to this Policy, you must not use the jillf platform.

01 Data Controller

jillf is the personal information controller ("PIC") for the purposes of the Data Privacy Act of 2012. As PIC, jillf determines the purposes and means of processing your personal data in connection with operating the jillf platform, complying with PAGCOR licensing requirements, fulfilling anti-money laundering obligations under Republic Act No. 9160 as amended, and delivering the services described in the jillf Terms and Conditions.

jillf has appointed a Data Privacy Officer (DPO) responsible for overseeing compliance with this Policy and with the Data Privacy Act. The DPO can be contacted at [email protected]. All data rights requests, privacy complaints, and inquiries about this Policy should be directed to the DPO in the first instance.

02 Personal Data We Collect

jillf collects the following categories of personal data in the course of operating the platform:

03 Purposes & Legal Basis for Processing

jillf processes your personal data on the following legal bases and for the following purposes:

• Contract performance: To register and maintain your account, process deposits and withdrawals, deliver gaming services, manage your VIP membership, and respond to support requests — all of which are necessary to fulfill the jillf Terms and Conditions.
• Legal obligation: To comply with PAGCOR licensing requirements including age verification (21+), KYC, and player activity reporting; to meet AML/AMLC obligations under RA 9160; and to respond to lawful requests from Philippine authorities.
• Legitimate interests: To detect, investigate, and prevent fraud, cheating, and platform abuse; to conduct security monitoring; to analyze platform usage and improve service quality; and to ensure the integrity of the gaming environment for all players.
• Consent: To send you promotional communications about jillf bonuses, new games, and offers where you have opted in. You may withdraw marketing consent at any time as described in Section 11.

jillf does not use your personal data for profiling purposes that produce legal or similarly significant effects, and does not engage in fully automated decision-making that would affect your account without human review.

04 Data Sharing & Third Parties

jillf does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. We share your personal data only in the following limited circumstances:

Payment Service Providers

GCash, PayMaya, BDO, BPI, Metrobank, and cryptocurrency processors receive the minimum personal data necessary to execute deposits and withdrawals — typically name, account reference, and transaction amount. These providers operate under their own privacy policies and applicable Philippine financial regulations.

KYC and Identity Verification Providers

jillf uses third-party KYC technology providers to verify identity documents and conduct liveness checks. These providers process document images and biometric data solely for verification purposes under data processing agreements with jillf. They are prohibited from using your data for any other purpose.

Game Technology and Content Providers

Live dealer studios and slot game providers receive anonymized session data necessary to deliver game content. Game providers do not receive personally identifiable information unless required for specific game functions and covered by appropriate agreements.

Regulatory and Law Enforcement Bodies

jillf will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government bodies when required by law, court order, or lawful authority. jillf will notify affected Members of such disclosures where legally permitted to do so.

05 International Data Transfers

Some of jillf's technology and service providers operate infrastructure outside the Philippines. Where personal data is transferred to servers or processors located in other countries, jillf ensures that such transfers are subject to appropriate safeguards — including contractual data processing agreements incorporating the NPC's standard contractual clauses or equivalent protections recognized under the Data Privacy Act.

jillf does not transfer personal data to jurisdictions that do not provide an adequate level of data protection unless contractual safeguards are in place that provide equivalent protection to those available under Philippine law. If you have questions about specific international transfer arrangements, contact jillf's DPO.

06 Data Retention

jillf retains personal data for as long as necessary to fulfill the purposes described in this Policy and to meet applicable legal, regulatory, and business requirements. The following retention guidelines apply:

• Active accounts: Personal data is retained for the duration of the account's active status plus a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under RA 9160.
• KYC documents: Retained for a minimum of five (5) years from the date of submission or the date of last transaction, whichever is later, as required by PAGCOR and AMLC regulations.
• Transaction records: Financial and gaming transaction logs are retained for a minimum of five (5) years to satisfy AML and PAGCOR regulatory obligations.
• Support communications: Live chat transcripts and email records are retained for three (3) years from the date of the interaction for dispute resolution purposes.
• Marketing data: Retained until marketing consent is withdrawn, or for two (2) years from the last engagement with marketing communications, whichever comes first.
• Technical/session data: Session logs and IP data are retained for twelve (12) months for security and fraud prevention purposes, then anonymized or deleted.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized in accordance with NPC guidelines.

07 Security Measures

jillf implements a range of technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS 1.3): All data transmitted between your device and jillf's servers is encrypted using current industry-standard TLS protocols — the same technology used by Philippine banks and financial institutions.
• Encrypted data storage: Sensitive personal data including KYC documents, identity records, and financial data are stored in encrypted form at rest using AES-256 encryption.
• Access controls: Access to personal data within jillf's systems is restricted to authorized personnel on a need-to-know basis. All internal access is logged and monitored. Privileged access requires multi-factor authentication.
• Password security: Member passwords are stored as salted cryptographic hashes and are never retrievable in plaintext form by any jillf personnel.
• Security monitoring: jillf operates continuous security monitoring, intrusion detection systems, and regular independent security audits of its platform infrastructure.
• Data breach response: In the event of a personal data breach affecting Member data, jillf will notify the National Privacy Commission and affected Members within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

08 Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by jillf:

To exercise any of these rights, submit a written request to jillf's Data Privacy Officer at [email protected]. Identity verification will be required before any request is processed. jillf will respond within fifteen (15) business days of verifying your identity.

If you are not satisfied with jillf's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

09 Cookies & Tracking Technologies

jillf uses cookies and similar tracking technologies (such as session tokens and local storage objects) on the jillf platform. The following types of cookies are in use:

• Strictly necessary cookies: Required for the platform to function. These include session authentication tokens, security tokens, load balancing cookies, and CSRF protection cookies. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Used to remember your preferences such as language settings, display preferences, and responsible gaming tool configurations. Disabling these may affect your experience.
• Analytics cookies: Used to understand how Members navigate the jillf platform — which pages are visited, where sessions end, and how features are used. Data is aggregated and anonymized. These can be disabled through your browser settings.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and multi-account attempts. These are required for platform security and cannot be disabled.

jillf does not use third-party advertising or retargeting cookies. You can manage or block non-essential cookies through your browser settings. Note that disabling cookies may prevent access to some features of the jillf platform, including the ability to maintain a logged-in session.

10 Minors & Under-21 Policy

jillf does not knowingly collect, process, or store personal data from individuals under the age of 21. Age verification is conducted during registration and the KYC process. Any account found to belong to a person under 21 years of age will be immediately suspended, any balance associated with that account will be handled in accordance with PAGCOR guidelines, and all personal data will be securely deleted following the completion of regulatory obligations.

If you believe that personal data of a person under 21 years of age has been submitted to jillf, please contact jillf's Data Privacy Officer immediately at [email protected] so that we can investigate and take appropriate action.

11 Marketing Communications

With your consent, jillf may send you promotional communications including information about new games, bonuses, seasonal promotions, VIP rewards, and platform updates. These communications may be sent via SMS to your registered Philippine mobile number, email, or in-platform notification.

Marketing communications are sent only where you have expressly opted in during registration or through your account settings. You may withdraw your marketing consent at any time by:

• Updating your communication preferences in your jillf account settings;
• Clicking "unsubscribe" or "opt out" in any marketing email; or
• Contacting jillf support at [email protected] and requesting removal from marketing lists.

Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to withdrawal, and does not affect jillf's ability to send you non-promotional service communications such as account security alerts, transaction confirmations, KYC requests, and regulatory notices — which are sent on the basis of contract performance or legal obligation, not consent.

12 Policy Amendments

jillf may update this Privacy Policy from time to time to reflect changes in applicable law, NPC guidance, PAGCOR requirements, or jillf's data processing practices. When material changes are made, jillf will update the "Last Updated" date at the top of this page and, where required, notify affected Members through the platform or via registered contact details.

Continued use of the jillf platform following the publication of an updated Privacy Policy constitutes acceptance of the updated terms. If you do not agree to the updated Policy, you must stop using the platform and may request account closure. The version of this Policy in force at the time of any data collection governs that collection.

13 Contact & Data Privacy Officer

For any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by jillf, please contact jillf's designated Data Privacy Officer:

If you are not satisfied with jillf's response to your privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines, which is the regulatory authority responsible for administering and enforcing the Data Privacy Act of 2012. The NPC's website provides guidance on the complaint submission process for Filipino data subjects.