Privacy Policy – jilispins Casino

1. Data Controller

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and all applicable Philippine data protection regulations, the data controller responsible for your personal information is jilispins Casino ("jilispins," "we," "us," or "our"), operating the online gaming platform accessible at jilispins.vip.

jilispins has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. Contact details for our DPO are provided in Section 13 of this Policy.

This Privacy Policy applies to all personal data collected through the jilispins website, mobile platform, customer support channels, and any other touchpoint through which you interact with jilispins Casino.

2. Data We Collect

jilispins collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is processed. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name, date of birth, and gender
• Residential address (including city, province, and postal code)
• Email address and mobile phone number
• Government-issued ID details (e.g., PhilSys National ID, passport, driver's license, SSS/GSIS ID, PRC ID, or voter's ID number, issuing authority, and expiry date)
• Selfie or photograph submitted for identity verification purposes

2.2 Financial & Transaction Data

• GCash or PayMaya account details (mobile number linked to the e-wallet)
• Bank account details (account name, account number, bank name) for bank transfer transactions
• Debit card details (card number, expiry date — stored in tokenized form only)
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used
• Source of funds declarations where required by anti-money laundering regulations

2.3 Gaming & Behavioural Data

• Game history, bet amounts, win/loss records, and session duration
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Customer support interaction records, including chat logs and email correspondence

2.4 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type and version
• Unique device identifiers and session tokens
• Log data, including access times, pages visited, and error reports

2.5 Data Collected Automatically via Cookies

jilispins uses cookies and similar tracking technologies to collect certain data automatically when you visit the Platform. Please refer to Section 8 (Cookies & Tracking) for full details.

3. Purpose of Processing

jilispins processes your personal data for the following specific, legitimate purposes:

jilispins does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or expressly consented to by you.

4. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you (account management, payment processing, game provision).
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing requirements, and tax obligations.
• Legitimate interests: Processing necessary for jilispins' legitimate interests in fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Where we rely on your consent (e.g., for optional marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

jilispins does not sell or rent 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, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing your financial transactions.
• Identity verification providers: Third-party KYC service providers engaged to verify your identity and age in compliance with PAGCOR requirements.
• Game providers: Licensed game software providers whose games are available on the jilispins Platform, to the extent necessary for game operation and integrity monitoring.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory obligation.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors engaged by jilispins under strict data processing agreements.
• Legal and professional advisers: Lawyers, auditors, and compliance consultants engaged by jilispins, subject to professional confidentiality obligations.

6. Data Retention

jilispins retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements under Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming and behavioural data: Retained for three (3) years from the date of the relevant gaming session or interaction.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Technical and device data: Retained for twelve (12) months from the date of collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jilispins' data disposal procedures.

7. Data Security

jilispins implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and jilispins servers is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including payment credentials, is stored in encrypted form.
• Access controls: Access to personal data is restricted to authorised jilispins personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Tokenisation: Payment card details are tokenised and never stored in plain text on jilispins systems.
• Penetration testing: jilispins conducts regular security assessments and penetration tests to identify and remediate vulnerabilities.
• Incident response: jilispins maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, we will notify the National Privacy Commission (NPC) within 72 hours and affected individuals without undue delay, as required by the DPA.
• Staff training: All jilispins personnel with access to personal data receive regular data protection and security training.

While jilispins takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying jilispins immediately if you suspect any unauthorised access to your account.

8. Cookies & Tracking

jilispins uses cookies and similar technologies (such as web beacons and local storage) to enhance your experience on the Platform, maintain session security, and gather analytics data. The types of cookies we use are:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences (e.g., language settings, display preferences) to personalise your experience.
• Analytics cookies: Collect anonymised data about how users interact with the Platform (pages visited, time spent, errors encountered) to help us improve our services. This data is aggregated and does not identify individual users.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jilispins Platform. jilispins does not use third-party advertising or behavioural tracking cookies.

9. Your Privacy Rights

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

• Right to be informed: The right to know what personal data jilispins collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data jilispins holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to jilispins' legal retention obligations and regulatory requirements.
• Right to object: The right to object to the processing of your personal data where jilispins relies on legitimate interests as the legal basis.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 13. jilispins will respond to all verified requests within fifteen (15) business days, as required by the DPA. We may need to verify your identity before processing your request.

10. Minors & Age Restriction

jilispins Casino is strictly intended for persons aged 21 years and above, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

As part of our Know Your Customer (KYC) process, jilispins verifies the age of all registered users before permitting access to real-money gaming. Any account found to belong to a person under 21 years of age will be immediately closed and all associated personal data will be deleted, except where retention is required by law.

If you are a parent or guardian and believe that a minor has registered an account on jilispins without your knowledge, please contact our support team immediately at the details provided in Section 13. We will investigate and take appropriate action without delay.

11. Cross-Border Data Transfers

In certain circumstances, jilispins may transfer your personal data to recipients located outside the Philippines — for example, where we engage international cloud hosting providers or game software vendors. Any such cross-border transfer of personal data is conducted in compliance with Section 21 of the Data Privacy Act of 2012 and the implementing rules of the National Privacy Commission.

Before transferring personal data outside the Philippines, jilispins ensures that:

• The recipient country provides an adequate level of data protection, as recognised by the NPC; or
• Appropriate safeguards are in place, such as contractual clauses approved by the NPC or binding corporate rules; or
• The transfer is necessary for the performance of our contract with you or is otherwise permitted under the DPA.

You may request further information about the safeguards applicable to any specific cross-border transfer by contacting our DPO.

12. Amendments to This Policy

jilispins 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. When material changes are made, 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, where practicable.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how jilispins protects your personal data. Your continued use of the jilispins Platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy.

If any amendment materially affects your rights or the way we process your personal data in a manner that requires fresh consent, we will seek your explicit consent before the changes take effect.

13. Contact & DPO

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

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated. The NPC can be reached through their official government channels.

For responsible gaming concerns and self-exclusion requests, please visit our Responsible Gaming page.