291jili Privacy Policy

Your Privacy at a Glance

At 291jili, we take the privacy and security of your personal information seriously. We are committed to handling your data responsibly, transparently, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations. This Privacy Policy applies to all users of the 291jili website, mobile platform, and related services.

1. Overview

291jili ("we," "us," or "our") operates the online gaming platform accessible at https://291jili.app and any associated mobile applications or services (collectively, the "Platform"). As the data controller, 291jili is responsible for determining the purposes and means of processing your personal data.

This Privacy Policy describes the types of personal information we collect from you, how we use and protect that information, with whom we share it, and the rights you have with respect to your personal data. We encourage you to read this policy carefully and contact us if you have any questions or concerns.

This policy applies to all personal data collected through your use of the 291jili Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and your browsing of our website. It does not apply to third-party websites or services that may be linked from our Platform, as those are governed by their own privacy policies.

2. Data We Collect

291jili collects the following categories of personal data from users of the Platform:

2.1 Identity and Contact Information

• Full legal name as it appears on government-issued identification
• Date of birth and age verification data
• Residential address (including barangay, city, province, and postal code)
• Email address and mobile phone number
• Government-issued identification numbers (e.g., passport, driver's license, SSS/UMID)

2.2 Financial Information

• Payment method details (e.g., GCash account number, PayMaya account, bank account details for BPI, BDO, Metrobank)
• Transaction history, including deposits, withdrawals, and wager amounts
• Source of funds documentation where required for AML compliance

2.3 Account and Gaming Data

• Username, password (stored in hashed form), and account preferences
• Gaming history, including games played, bets placed, wins, and losses
• Bonus and promotion usage history
• Responsible gaming settings, including deposit limits and self-exclusion records

2.4 Technical and Usage Data

• IP address, device type, operating system, and browser information
• Session duration, pages visited, and features used on the Platform
• Geolocation data (country and region level) for compliance purposes
• Cookies and similar tracking technologies (see Section 9)

2.5 Communications Data

• Records of customer support interactions, including live chat transcripts and email correspondence
• Feedback, complaints, and dispute records
• Marketing communication preferences and opt-out records

3. How We Collect Your Data

291jili collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access and use the Platform, including through cookies, log files, and analytics tools.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from risk management partners; payment data from payment processors such as GCash and PayMaya.
• Regulatory sources: Self-exclusion lists and player protection data from PAGCOR and other regulatory bodies where applicable.

4. How We Use Your Data

291jili processes your personal data for the following purposes:

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

5. Legal Basis for Processing

291jili processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012 and its implementing rules:

• Contractual necessity: Processing required to fulfill our obligations under the Terms and Conditions you agreed to upon registration, including account management, payment processing, and gameplay services.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering obligations, tax reporting requirements, and PAGCOR regulatory directives.
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing and Disclosure

291jili does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification providers, fraud detection and risk management partners, cloud hosting and infrastructure providers, and customer support platform operators. All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection laws.

6.2 Regulatory and Law Enforcement Authorities

We may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive. Such disclosures will be made only to the extent required and in accordance with applicable legal procedures.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 291jili's business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that may result from it.

6.4 With Your Consent

We may share your personal data with other third parties where you have provided your explicit consent to such sharing.

7. Data Retention

291jili retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and regulatory requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC documentation: Retained for a minimum of five (5) years following the end of the business relationship.
• Customer support records: Retained for three (3) years from the date of the interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications, after which it will be deleted or anonymized within thirty (30) days.
• Technical and usage data: Retained for up to twelve (12) months in identifiable form, after which it may be anonymized for analytical purposes.

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

8. Data Security

291jili implements a comprehensive set of technical and organizational security measures 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 291jili Platform is protected using 256-bit SSL/TLS encryption. Sensitive data, including passwords and payment information, is encrypted at rest using industry-standard algorithms.
• Access controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular security training.
• Infrastructure security: Our servers are hosted in secure, access-controlled data centers with physical security measures, redundant systems, and regular security audits.
• Monitoring and testing: We conduct regular vulnerability assessments, penetration testing, and security audits to identify and address potential weaknesses in our systems.
• Incident response: We maintain a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act.

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorized access to your account.

9. Cookies and Tracking Technologies

291jili 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:

Essential and security cookies are strictly necessary for the operation of the Platform and cannot be disabled. For all other cookie types, you may manage your preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

10. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 291jili:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data we hold 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 our legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer through the customer support channels listed in Section 14. We will respond to all verified requests within thirty (30) days of receipt, or within such extended period as permitted by applicable law.

11. Minors and Age Restriction

The 291jili Platform is strictly intended for persons who are at least 21 years of age, as required under Philippine law for casino-style gambling activities. We do not knowingly collect personal data from individuals under the age of 21.

During the registration process, all users are required to confirm that they meet the minimum age requirement. Where we have reason to believe that a user is under 21 years of age, we will suspend the account, refuse to process any transactions, and delete any personal data collected from that individual as soon as practicable.

If you are a parent or guardian and believe that your child has provided personal data to 291jili, please contact us immediately using the details in Section 14 so that we can take appropriate action.

12. International Data Transfers

291jili primarily processes and stores personal data within the Philippines. In certain circumstances, your personal data may be transferred to, stored in, or processed by service providers located in other countries, including for cloud hosting, payment processing, or KYC verification purposes.

Where personal data is transferred outside the Philippines, 291jili ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of the Data Privacy Act. These safeguards may include contractual clauses approved by the National Privacy Commission, adequacy decisions, or other legally recognized transfer mechanisms.

By using the 291jili Platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

13. Changes to This Privacy Policy

291jili reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. When we make material changes to this policy, we will notify registered users by email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data. Your continued use of the Platform following the effective date of any changes constitutes your acceptance of the revised Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 291jili handles your personal data, please contact our Data Protection Officer (DPO) or customer support team using the details below. We are committed to addressing all privacy-related inquiries promptly and in good faith.

• Data Protection Officer: Available via the 291jili customer support portal
• Live Chat: Available 24/7 directly on the 291jili Platform
• Email: [email protected]
• Response Time: Within 30 days for formal data rights requests; within 24 hours for general privacy inquiries

If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.