Privacy Policy – 39 Jili Casino

1. Overview

This Privacy Policy ("Policy") describes how 39 Jili Casino ("39 Jili," "we," "us," or "our"), operating through the website 39jili.vip, collects, processes, stores, and protects the personal information of its users ("Player," "you," or "your") in connection with the provision of online gaming and related services.

39 Jili Casino is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

By registering an account, accessing the 39 Jili platform, or otherwise using our services, 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 Policy, please discontinue use of the platform immediately.

2. Personal Data We Collect

39 Jili collects the following categories of personal data from players and platform visitors:

2.1 Identity & Contact Information

• Full legal name
• Date of birth (for age verification – players must be 21 years or older)
• Philippine mobile number
• Email address
• Residential address (province, city, barangay)
• Government-issued ID details (for KYC verification)

2.2 Financial Information

• GCash or PayMaya/Maya account number (for deposit and withdrawal processing)
• Bank account details (BPI, BDO, Metrobank, UnionBank, or other participating Philippine banks) where applicable
• Transaction history, deposit amounts, and withdrawal records

2.3 Gaming Activity Data

• Game session logs, bet history, and win/loss records
• Bonus and promotion usage history
• Responsible gaming tool usage (deposit limits, self-exclusion requests)

2.4 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and platform interaction logs
• Cookie identifiers and similar tracking technologies

2.5 Communications Data

• Records of live chat, email, or support ticket interactions with 39 Jili staff
• Feedback, survey responses, and promotional opt-in preferences

3. How We Collect Your Data

39 Jili collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, or contacting our support team.
• Automated collection: Technical data collected automatically when you access the 39 Jili platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers, fraud detection data from security partners, and payment confirmation data from GCash, PayMaya, or banking partners.
• Regulatory sources: Information shared with us by PAGCOR or other regulatory bodies in connection with compliance obligations.

4. Purpose of Data Processing

39 Jili processes your personal data for the following specific purposes:

Purpose	Description
Account Management	Creating, maintaining, and securing your 39 Jili player account.
Age & Identity Verification	Confirming that you meet the 21+ age requirement and verifying your identity as required by PAGCOR and AML regulations.
Payment Processing	Facilitating deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card.
Regulatory Compliance	Meeting obligations under PAGCOR licensing, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act.
Fraud Prevention	Detecting and preventing fraudulent activity, multi-accounting, and unauthorized access.
Customer Support	Responding to your inquiries, resolving disputes, and improving support quality.
Platform Improvement	Analyzing usage patterns to improve game performance, platform stability, and user experience.
Responsible Gaming	Monitoring gaming behavior to support responsible gaming tools and self-exclusion requests.
Marketing (with consent)	Sending promotional offers, bonus notifications, and platform updates where you have opted in.

5. Legal Basis for Processing

39 Jili processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration, including account management and payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw this consent at any time.

6. Data Sharing & Disclosure

39 Jili does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data only in the following limited circumstances:

• Payment processors: GCash, PayMaya/Maya, and participating Philippine banks receive the minimum data necessary to process your transactions.
• KYC and identity verification providers: Third-party services engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention and security partners: Service providers that assist in detecting and preventing fraudulent activity on the platform.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or court order.
• IT and platform service providers: Cloud hosting, data storage, and technical support providers operating under strict data processing agreements that prohibit unauthorized use of your data.
• Business transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

All third parties with whom 39 Jili shares personal data are required to implement appropriate technical and organizational security measures and to process your data only for the purposes specified by 39 Jili.

7. Data Retention

39 Jili retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations.

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, as required under PAGCOR and AMLA regulations.
• Transaction records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act.
• KYC documents: Retained for the period required by PAGCOR and NPC guidelines, typically five (5) years from the date of verification.
• Support communications: Retained for up to two (2) years from the date of the last interaction.
• Marketing data: Retained until you withdraw your consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with NPC-approved data disposal procedures.

8. Data Security

39 Jili 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:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 39 Jili platform.
• Encrypted storage of sensitive personal and financial data at rest on secured servers with restricted access controls.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits and penetration testing conducted by independent security professionals.
• Two-factor authentication (2FA) available for player accounts to add an additional layer of login security.
• Data breach response protocols in place, including mandatory notification to the NPC and affected players within 72 hours of discovering a breach, as required by the Data Privacy Act.

While 39 Jili takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your 39 Jili login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

9. Cookies & Tracking Technologies

39 Jili uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file stored on your device when you visit a website. We use the following types of cookies:

Cookie Type	Purpose	Can Be Disabled?
Essential	Required for the platform to function, including session management and login authentication.	No – platform will not function without these.
Performance	Collect anonymized data on how players use the platform to help us improve performance and stability.	Yes – via browser settings.
Functional	Remember your preferences such as language settings and game display options.	Yes – via browser settings.
Analytics	Help us understand traffic patterns and player behavior in aggregate, anonymized form.	Yes – via browser settings or cookie consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 39 Jili platform. 39 Jili does not use cookies to serve third-party advertising or to track your activity on other websites.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 39 Jili Casino:

• Right to be Informed: You have the right to know what personal data 39 Jili collects about you and how it is processed.
• Right to Access: You may request a copy of the personal data we hold about you at any time.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data in your account.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer (DPO) using the details provided in Section 13 of this Policy. We will respond to all verified requests within fifteen (15) business days, as required by the Data Privacy Act.

11. Minors & Age Restriction

39 Jili Casino strictly prohibits access by persons under the age of 21 years, in accordance with Philippine gaming law and PAGCOR regulations. We do not knowingly collect personal data from individuals under 21 years of age.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any winnings or balances associated with an underage account will be forfeited.

If you are a parent or guardian and believe that your child has registered on the 39 Jili platform, please contact our support team immediately via live chat or at [email protected] so that we can investigate and take appropriate action.

12. Changes to This Privacy Policy

39 Jili 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. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Policy, we will notify registered players via the mobile number or email address on file, or by posting a prominent notice on the 39 Jili platform. Your continued use of the platform following notification of any changes constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Policy periodically to stay informed about how 39 Jili protects your personal data.

13. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 39 Jili Casino, please contact our designated Data Protection Officer (DPO):

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the chat widget on the 39 Jili platform.

For complaints that cannot be resolved directly with 39 Jili, you may contact the National Privacy Commission (NPC) of the Philippines through their official channels.