3jili Privacy Policy

This Privacy Policy is issued by 3jili ("3jili," "we," "us," or "our"), the operator of the online gaming platform accessible at 3jili.org and any associated mobile or web applications (collectively, the "Platform"). 3jili operates under the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the data protection requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

For the purposes of the DPA, 3jili acts as the Personal Information Controller in respect of the personal data of players and visitors to the Platform. This means that 3jili determines the purposes and means by which your personal data is processed.

By using the 3jili 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, please discontinue use of the Platform.

3jili collects the following categories of personal data, depending on how you interact with the Platform:

We do not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive data is collected — such as a copy of your government-issued ID — it is handled with additional safeguards as described in Section 9 of this policy.

3jili collects personal data through the following means:

• Direct Collection: Information you provide when you register for an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey or promotion.
• Automated Collection: Technical data collected automatically when you access the Platform, including your IP address, device identifiers, browser type, pages visited, and session duration. This data is collected via cookies, web beacons, and similar tracking technologies as described in Section 8.
• Third-Party Sources: Information received from payment processors (such as GCash and Maya) to verify transactions; identity verification service providers used for KYC compliance; and fraud prevention partners who help us detect suspicious activity on the Platform.
• Regulatory Sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with our licensing obligations, including self-exclusion lists and player protection registers.

3jili does not purchase personal data from data brokers or any other commercial data sources. All data we hold about you originates from your direct interactions with the Platform or from the regulated third-party sources described above.

3jili uses your personal data for the following specific purposes:

• Account Management: To create, maintain, and administer your 3jili player account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Service Delivery: To provide you with access to the games, features, and services available on the 3jili Platform, including processing deposits, settling wagers, and processing withdrawal requests.
• Regulatory Compliance: To fulfill our obligations under PAGCOR regulations, the Philippine Anti-Money Laundering Act (Republic Act No. 9160, as amended), and other applicable Philippine laws — including conducting KYC checks, monitoring transactions for suspicious activity, and maintaining records as required by law.
• Responsible Gaming: To monitor player activity for signs of problem gambling, enforce deposit limits and self-exclusion requests, and comply with PAGCOR's responsible gaming framework.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance when you contact our support team.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, cheating, and other prohibited conduct on the Platform.
• Platform Improvement: To analyze aggregated usage data and player behavior patterns in order to improve the performance, features, and user experience of the 3jili Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and news about 3jili — but only where you have given your explicit consent to receive such communications. You may withdraw this consent at any time.

Under the Philippine Data Privacy Act of 2012, 3jili is required to have a lawful basis for each purpose for which it processes your personal data. The following table sets out the legal bases we rely on:

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal. To withdraw consent for marketing communications, you may use the unsubscribe link in any marketing email or contact our support team directly.

3jili does not sell, rent, or trade your personal data. 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: GCash, Maya/PayMaya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive the minimum data necessary to process your deposit and withdrawal transactions.
• Identity Verification Providers: Third-party KYC service providers who assist us in verifying your identity and screening against sanctions lists and politically exposed persons (PEP) databases, as required by Philippine AML regulations.
• Game Software Providers: Licensed game developers and providers whose games are hosted on the 3jili Platform may receive anonymized or pseudonymized technical data necessary to deliver and maintain their games.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where we are legally required to disclose information or respond to lawful requests.
• Professional Advisors: Legal counsel, auditors, and other professional advisors who are bound by confidentiality obligations and who assist 3jili in operating its business lawfully.
• IT and Infrastructure Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf as Personal Information Processors under data processing agreements that require them to protect your data to the same standard as 3jili.

3jili 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 Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 3jili's data disposal procedures. Anonymized data — which can no longer be linked to any individual — may be retained indefinitely for statistical and analytical purposes.

3jili uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit a website. We use the following types of cookies:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting your ability to use the Platform.
• Performance Cookies: These cookies collect anonymized information about how visitors use the Platform — such as which pages are visited most frequently and whether error messages are received. This data helps us improve the Platform's performance and reliability.
• Functionality Cookies: These cookies remember your preferences and settings (such as your preferred language or display settings) to provide a more personalized experience on return visits.
• Analytics Cookies: We use analytics tools to understand aggregate user behavior on the Platform. The data collected is anonymized and used solely for internal reporting and platform improvement purposes.

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the 3jili Platform. For detailed instructions on managing cookies, refer to your browser's help documentation.

3jili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and 3jili's servers is encrypted using TLS 1.2 or higher. We enforce HTTPS across the entire Platform.
• Encryption at Rest: Sensitive personal data stored on 3jili's servers — including KYC documents and financial data — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to 3jili staff and contractors who have a legitimate need to access it for their job functions. All access is logged and subject to regular review.
• Two-Factor Authentication: 3jili's internal systems require multi-factor authentication for all staff accessing personal data. We also offer 2FA to players for their own account security.
• Regular Security Audits: 3jili conducts regular penetration testing and security audits of its Platform and infrastructure to identify and remediate vulnerabilities.
• Incident Response: In the event of a personal data breach that poses a risk to your rights and freedoms, 3jili will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA's breach notification requirements.

While 3jili takes all reasonable steps to protect your personal data, no system is completely immune to security risks. You also play an important role in keeping your data safe — please refer to the account security guidance in our Terms & Conditions.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 3jili. You may exercise any of these rights by contacting our Data Protection Officer as described in Section 13.

3jili will respond to all data subject rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case we will notify you of the extension and the reason for it. There is no fee for exercising your rights, unless a request is manifestly unfounded or excessive.

The 3jili Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gambling in the Philippines. 3jili does not knowingly collect personal data from any person under the age of 21.

If you are a parent or guardian and you believe that a minor has provided personal data to 3jili or has accessed the Platform without authorization, please contact us immediately at the details provided in Section 13. Upon verification, we will take prompt steps to delete the minor's personal data and close any associated account.

3jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When we make material changes to this policy, we will:

• Update the "Last Updated" date at the top of this page;
• Post a prominent notice on the 3jili Platform homepage or login screen; and
• Where required by law or where the changes materially affect your rights, notify you directly via your registered email address or mobile number.

Your continued use of the 3jili Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically to stay informed about how 3jili protects your personal data. The most current version of this Privacy Policy will always be available at 3jili.org/privacy-policy.

If you have any concerns about a proposed change to this Privacy Policy, please contact our Data Protection Officer before the effective date of the change. If you do not agree with the revised policy, you should stop using the Platform and close your account.

3jili has appointed a Data Protection Officer (DPO) as required by the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO using the details below:

• Data Protection Officer: 3jili Privacy & Compliance Team
• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on the 3jili Platform
• Response Time: We aim to acknowledge all privacy-related inquiries within two (2) business days and provide a full response within thirty (30) calendar days.

When submitting a data subject rights request, please include your full name, registered email address, and a clear description of your request. We may need to verify your identity before processing your request to ensure we do not disclose your personal data to an unauthorized party.