Privacy Policy

1. Who We Are (Data Controller)

jilljuck is the data controller responsible for the personal information you provide and that we collect through your use of the Platform. jilljuck operates in alignment with the Philippine Amusement and Gaming Corporation (PAGCOR) regulatory framework and processes personal data in accordance with Philippine law.

For privacy-related inquiries, you may contact our Data Protection Officer (DPO) at the contact details provided in Section 13 of this Policy.

2. Personal Data We Collect

jilljuck collects personal data in the following categories depending on how you interact with the Platform:

2.1 Registration and Identity Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify you are 21 years of age or older);
• Philippine mobile number and email address;
• Username and encrypted password;
• Residential address in the Philippines (city, province).

2.2 KYC Verification Data

• Copies of government-issued identification documents (e.g., PhilSys National ID, passport, UMID, SSS ID, driver's license, voter's ID);
• Selfie photograph or liveness check image for identity matching;
• Source of funds documentation where required for enhanced due diligence;
• Proof of address documentation where requested.

2.3 Financial and Transaction Data

• GCash or Maya mobile wallet identifiers (account number or registered mobile number);
• Bank account details for BPI, BDO, Metrobank, and other bank transfer methods;
• Deposit and withdrawal transaction history;
• Cryptocurrency wallet addresses for USDT TRC20 transactions where applicable.

2.4 Gaming and Behavioral Data

• Game session records including game type, bet amounts, game outcomes, and session duration;
• Sports betting selections, odds accepted, and settlement outcomes;
• Bonus and promotion usage history;
• Responsible gaming tool usage (limit settings, self-exclusion events).

2.5 Technical and Device Data

• IP address and approximate geolocation (country/region);
• Device type, operating system, and browser version;
• Session timestamps, login history, and access logs;
• Cookie identifiers and similar tracking technologies as described in Section 6.

2.6 Communications Data

• Customer support chat transcripts and email correspondence;
• Complaints, dispute submissions, and feedback you provide to jilljuck;
• Marketing communication preferences and consent records.

3. How jilljuck Uses Your Personal Data

Purpose	Data Categories Used
Account creation and authentication	Registration data, device data
Age and identity verification (KYC)	Identity data, KYC documents
Processing deposits and withdrawals	Financial data, identity data
Anti-money laundering (AML) compliance	Identity data, financial data, transaction history
Delivering and improving gaming services	Gaming data, technical data
Bonus and promotion administration	Registration data, gaming data
Responsible gaming monitoring and enforcement	Gaming data, behavioral data
Customer support and dispute resolution	Communications data, gaming data, transaction data
Fraud detection and security	Technical data, financial data, identity data
Marketing communications (with consent)	Registration data, communication preferences
Regulatory reporting to PAGCOR and NPC	Identity data, transaction data

4. Legal Bases for Processing

jilljuck processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity — processing required to fulfill the jilljuck Terms & Conditions you agreed to when creating your account, including account management, payments, and game delivery;
• Legal obligation — processing required to comply with applicable Philippine laws including AMLA reporting, PAGCOR regulatory requirements, and NPC data breach notification obligations;
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and improving our services, where those interests are not overridden by your data protection rights;
• Consent — processing for marketing communications, where you have expressly opted in. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

jilljuck does not sell your personal data to third parties. We may share your data with the following categories of recipients only as necessary for the purposes described in this Policy:

• KYC and identity verification providers — third-party services used to verify government-issued IDs and perform liveness checks;
• Payment processors and e-wallet operators — GCash, Maya, BPI, BDO, Metrobank, and other payment partners to process deposits and withdrawals;
• Game software providers — game studios that supply the slot, live dealer, and specialty game titles accessible through jilljuck, who may receive game session data for technical operation and RNG certification purposes;
• 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;
• Fraud and security services — third-party providers used to detect and prevent fraudulent activity, account abuse, and money laundering;
• Professional advisors — legal, accounting, and compliance advisors under confidentiality obligations where necessary.

All third-party service providers engaged by jilljuck are contractually required to process personal data only for the specified purpose, to implement appropriate security measures, and to comply with Philippine data privacy law.

6. Cookies and Tracking Technologies

jilljuck uses cookies and similar technologies (local storage, session tokens) on the Platform for the following purposes:

• Essential cookies — required for Platform operation including login session management, security tokens, and load balancing. These cannot be disabled without affecting core Platform functionality.
• Functional cookies — store your preferences such as language settings, game lobby layout preferences, and responsible gaming tool configurations.
• Analytics cookies — aggregate, anonymized data on Platform usage patterns to help jilljuck improve the user experience for Filipino players. No individual player is identified in analytics reports.
• Security cookies — used to detect suspicious login patterns, enforce session limits, and prevent account takeover attacks.

jilljuck does not use third-party advertising or behavioral tracking cookies. Your browsing activity on jilljuck is not shared with advertising networks or data brokers.

7. Data Retention

jilljuck retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC data — retained for a minimum of five (5) years from account closure, as required by AMLA and PAGCOR regulatory record-keeping obligations;
• Transaction and gaming records — retained for five (5) years in accordance with AMLA transaction monitoring requirements;
• Customer support communications — retained for three (3) years from the date of the last interaction;
• Marketing consent records — retained for the duration of your marketing consent plus three (3) years for audit purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be linked to an identifiable individual.

8. Data Security

jilljuck implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption on all data transmitted between your device and the jilljuck Platform;
• Encryption at rest for sensitive personal data including KYC documents and financial account identifiers;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Multi-factor authentication requirements for internal administrative systems;
• Regular security assessments and penetration testing of Platform infrastructure;
• Incident response procedures aligned with NPC breach notification requirements (72-hour notification for qualifying breaches).

While jilljuck implements robust security measures, no online platform can guarantee absolute security. We encourage all jilljuck account holders to use strong, unique passwords and to enable two-factor authentication on their accounts.

9. Your Data Subject Rights

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

• Right to be informed — the right to know what personal data jilljuck collects about you and how it is used, as described in this Policy;
• Right of access — the right to request a copy of the personal data jilljuck holds about your account;
• Right to rectification — the right to correct inaccurate or incomplete personal data, which you may do partially through Account Settings or by contacting our DPO;
• Right to erasure or blocking — the right to request deletion or blocking of your personal data in certain circumstances, subject to our legal retention obligations;
• Right to object — the right to object to processing based on legitimate interests, including direct marketing, at any time;
• Right to data portability — the right to receive a structured, machine-readable copy of personal data you provided to jilljuck under consent or contract;
• Right to lodge a complaint — the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jilljuck has processed your personal data unlawfully.

To exercise any of these rights, please contact our DPO using the details in Section 13. jilljuck will respond to verified data subject requests within 15 business days.

10. Children and Minors

jilljuck strictly prohibits access by persons under the age of 21. We do not knowingly collect personal data from individuals under 21. If jilljuck becomes aware that personal data has been collected from an underage individual, the account will be immediately suspended, all personal data associated with the account will be deleted as required by law, and any funds in the account will be handled in accordance with our Terms & Conditions and applicable regulatory requirements.

If you are a parent or guardian and believe your child has accessed jilljuck, please contact our DPO immediately at the contact details in Section 13.

11. Cross-Border Data Transfers

Some of jilljuck's technical service providers and game studios are located outside the Philippines. Where personal data is transferred to entities in other countries, jilljuck ensures that appropriate contractual safeguards are in place, including data processing agreements that require recipient parties to provide a standard of data protection equivalent to that required under Philippine law. jilljuck will not transfer personal data to jurisdictions that do not provide adequate data protection without implementing appropriate safeguards.

12. Updates to This Privacy Policy

jilljuck may update this Privacy Policy from time to time to reflect changes in our data practices, Philippine regulatory requirements, or Platform features. Material changes will be communicated to registered players via email to the address on file or through a prominent notice on the Platform no less than seven (7) days before the revised Policy takes effect. The "Last Updated" date at the top of this page will reflect the most recent revision. Your continued use of jilljuck after the effective date of any update constitutes your acknowledgment of the revised Policy.

13. Contact and Data Protection Officer

For questions, concerns, or requests regarding this Privacy Policy or jilljuck's processing of your personal data, you may contact our Data Protection Officer through the following channel: