39 Jili Privacy Policy

1 Introduction

39 Jili ("we," "us," "our") is committed to protecting the privacy and personal data of all individuals who use our online gaming platform. This Privacy Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

This Policy describes the types of personal data we collect from players and visitors to the 39 Jili platform, the purposes for which that data is processed, the legal bases on which we rely, the parties with whom we may share data, the security measures we employ to protect it, and the rights available to you as a data subject under Philippine law.

We encourage you to read this Policy in full. If you have questions about any aspect of our data practices, please contact us using the details provided in Section 15 of this Policy. Our Data Protection Officer is available to assist with any privacy-related inquiries.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, the data controller responsible for your personal data is the operator of the 39 Jili platform, accessible at https://39-jili.com. The data controller determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

39 Jili has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection legislation. You may contact the DPO using the contact details provided in Section 15 of this Policy.

3 Data We Collect

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

We do not collect sensitive personal information as defined under the Data Privacy Act of 2012 (such as health data, political opinions, or religious beliefs) unless specifically required by law or with your explicit consent.

4 How We Collect Your Data

39 Jili collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the platform, including IP address, device identifiers, browser information, and session activity logs collected via cookies and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment verification data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank.
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations, including self-exclusion registers.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 39 Jili processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including operating your account, processing deposits and withdrawals, and providing access to games.
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulatory requirements, the Anti-Money Laundering Act (Republic Act No. 9160 as amended), and the Data Privacy Act of 2012.
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improving our services, where such interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent as the legal basis for processing (for example, for certain marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 How We Use Your Data

39 Jili uses your personal data for the following purposes:

• Account management: Creating and maintaining your player account, verifying your identity and age, and managing your account settings and preferences.
• Platform operation: Processing deposits and withdrawals, recording game activity, applying bonuses and promotions, and providing customer support.
• Regulatory compliance: Meeting our obligations under PAGCOR regulations, the Anti-Money Laundering Act, and other applicable Philippine laws, including filing required reports with regulatory authorities.
• Fraud and security: Detecting, investigating, and preventing fraudulent activity, money laundering, account takeover, and other security threats to the platform and its players.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior, applying player-requested limits and self-exclusion measures, and complying with responsible gaming obligations.
• Communications: Sending transactional communications related to your account, including deposit confirmations, withdrawal notifications, and security alerts. Where you have consented, sending promotional communications about 39 Jili offers and new games.
• Platform improvement: Analyzing aggregated and anonymized usage data to improve the performance, features, and user experience of the 39 Jili platform.
• Dispute resolution: Maintaining records necessary to investigate and resolve disputes, including game outcome disputes and payment disputes.

7 Sharing Your Personal Data

39 Jili does not sell your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist in verifying your identity and age in compliance with PAGCOR and AML requirements.
• Fraud prevention and security providers: Services that assist in detecting and preventing fraudulent activity on the platform.
• Game providers: Software providers whose games are available on the 39 Jili platform, to the extent necessary for game operation and dispute resolution.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by 39 Jili, subject to professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 39 Jili's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

8 Cookies and Tracking Technologies

The 39 Jili platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and collect analytical data about platform usage. The following types of cookies are used:

• Essential cookies: Required for the platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without affecting platform functionality.
• Analytical cookies: Used to collect aggregated, anonymized data about how players use the platform, including pages visited, session duration, and navigation patterns. This data helps us improve the platform experience.
• Functional cookies: Used to remember your preferences, such as language settings and display preferences, to provide a more personalized experience.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and account takeover prevention.

You may manage cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the 39 Jili platform. For more information about managing cookies, refer to your browser's help documentation.

9 Data Retention

39 Jili retains personal data for the periods set out below, after which data is securely deleted or anonymized:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AML record-keeping requirements.
• Gaming activity data: Retained for a minimum of three (3) years from the date of the activity, for dispute resolution and regulatory compliance purposes.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support communications: Retained for two (2) years from the date of the communication, unless the communication relates to an ongoing dispute or regulatory matter.
• Technical and log data: Retained for twelve (12) months from the date of collection, unless required for longer retention for security or legal purposes.

Where retention beyond these periods is required by Philippine law or regulatory obligation, data will be retained for the period required by law. At the end of the applicable retention period, data is securely deleted using industry-standard data destruction methods.

10 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:

• TLS encryption for all data transmitted between your device and the 39 Jili platform;
• AES-256 encryption for sensitive data stored at rest, including financial information and identity documents;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing by independent security professionals;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Staff training on data protection obligations and security best practices;
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 39 Jili will notify the National Privacy Commission and, where required, affected data subjects, within the timeframes prescribed by the Data Privacy Act of 2012 and NPC guidelines.

While 39 Jili takes all reasonable steps to protect your personal data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the security of your account credentials and for notifying 39 Jili immediately if you suspect unauthorized access to your account.

11 Your Data Subject Rights

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

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified data subject requests within thirty (30) days of receipt, as required by NPC guidelines. We may need to verify your identity before processing your request.

12 Children's Privacy

The 39 Jili platform is strictly intended for individuals who are at least twenty-one (21) years of age, consistent with Philippine gaming regulations applicable to casino-style gaming. 39 Jili does not knowingly collect personal data from individuals under the age of 21.

If 39 Jili 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. If you believe that a minor has registered an account on the 39 Jili platform, please contact us immediately using the details in Section 15.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gaming platforms. 39 Jili supports responsible gaming and takes its obligations to prevent underage gambling seriously.

13 International Data Transfers

39 Jili primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, for example where a game provider or technical service provider operates servers in another jurisdiction.

Where personal data is transferred outside the Philippines, 39 Jili ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to process the data in accordance with standards equivalent to those required by the Data Privacy Act of 2012. Such transfers are carried out only where necessary and only with service providers who have demonstrated adequate data protection practices.

By using the 39 Jili platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines in the circumstances described above, subject to the safeguards described in this section.

14 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 practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where amendments are material — meaning they significantly affect how we process your personal data or the rights available to you — we will provide reasonable advance notice via the platform and, where practicable, via email to your registered address. For non-material amendments, the updated Policy will be posted on this page with a revised effective date.

Your continued use of the 39 Jili platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not agree with the revised Policy, you should cease using the platform and may request closure of your account in accordance with our Terms and Conditions.

15 Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 39 Jili, please contact our Data Protection Officer:

Please include your registered account username, a clear description of your request or concern, and any relevant supporting information in all correspondence. We may need to verify your identity before processing data subject requests.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012 and can be reached through its official government channels.