amjilli Privacy
Policy

1. Introduction

This Privacy Policy ("Policy") describes how amjilli ("amjilli," "we," "us," or "the Platform"), the operator of the online gaming platform at amjilli.one, collects, uses, stores, discloses, and protects the personal data of users ("Player," "you," or "your") in accordance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission (NPC).

amjilli is licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing activities are undertaken in compliance with both the DPA and PAGCOR's regulatory requirements, some of which require the collection and retention of player data as a condition of the operating licence.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, amjilli is the personal information controller (PIC) in respect of the personal data of players collected through the amjilli.one platform. amjilli is responsible for determining the purposes and means by which your personal data is processed.

Where amjilli engages third-party service providers (such as payment processors, identity verification providers, or analytics companies) that process personal data on its behalf, those providers act as personal information processors (PIPs) and are contractually bound to process data only in accordance with amjilli's instructions and applicable Philippine law.

3. Personal Data We Collect

amjilli collects the following categories of personal data:

3.1 Identity & Account Data

• Full legal name (as it appears on your Philippine government-issued ID)
• Date of birth
• Philippine mobile number (Smart, Globe, or DITO)
• Username and encrypted password
• Profile photo (optional, user-uploaded)
• Nationality and country of residence

3.2 KYC / Verification Data

• Scanned or photographed copy of a valid Philippine government-issued ID (PhilSys, UMID, passport, driver's license, SSS ID, or PRC ID)
• Selfie photograph holding the presented ID
• Additional source-of-funds documentation where required for enhanced due diligence

3.3 Financial Data

• GCash account number and registered name (for deposit and withdrawal processing)
• Maya account details (for deposit and withdrawal processing)
• Bank account details for BPI, BDO, or Metrobank transfers (where used)
• Transaction history: deposit amounts, withdrawal amounts, dates, and payment method used
• PHP wallet balance history

3.4 Gameplay & Activity Data

• Bet records: game name, stake amount, result, timestamp
• Session duration and activity logs (login time, logout time, pages visited)
• Bonus and promotion usage records
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.5 Technical & Device Data

• IP address at time of login and significant account actions
• Device type, operating system version, and browser type
• Mobile network operator (Smart, Globe, DITO)
• Approximate geolocation derived from IP address
• Cookie and session identifiers (see Section 11)

3.6 Communication Data

• Content of live chat conversations with amjilli support
• Email correspondence with amjilli
• Records of SMS notifications sent to your registered mobile number
• Feedback, complaints, and dispute submissions

4. How We Collect Your Data

amjilli collects personal data through the following means:

• Directly from you: when you register an account, complete KYC, make a deposit or withdrawal, use live chat support, or submit a complaint.
• Automatically: through platform logs, cookies, and session tracking as you interact with amjilli.one on any device.
• From payment processors: transaction confirmation data from GCash, Maya, BPI, BDO, and other Philippine payment partners when you initiate a deposit or withdrawal.
• From identity verification providers: verification results and document authenticity assessments from our KYC service partner when you submit identity documents.
• From fraud and AML monitoring systems: flagged transaction patterns identified through automated screening tools that cross-reference data against watchlists maintained pursuant to Philippine AML law.

5. Purposes of Personal Data Processing

amjilli processes your personal data for the following purposes:

Purpose	Data Categories Used
Account registration and authentication	Identity, mobile number, device data
Identity verification (KYC) and age confirmation (21+)	KYC documents, selfie, identity data
Processing deposits and withdrawals	Financial data, identity data
Providing access to games and platform features	Account data, gameplay data, session data
Regulatory compliance and PAGCOR reporting	Identity, financial, gameplay data
Anti-money laundering (AML) and fraud prevention	Financial, identity, device, gameplay data
Responsible gaming programme monitoring	Gameplay, financial, account data
Customer support and dispute resolution	Communication, account, transaction data
Platform security and fraud detection	Device data, session data, IP address
Marketing communications (where consented)	Identity, contact, gameplay data
Platform improvement and analytics	Anonymized gameplay and session data

6. Legal Basis for Processing

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

• Contract performance: Processing necessary to provide the services you have contracted for by registering an account and agreeing to the Terms and Conditions.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine law.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and customer support — where these interests do not override your rights and freedoms.
• Consent: Processing for direct marketing communications. You may withdraw this consent at any time as described in Section 14.

7. Data Sharing & Disclosure

amjilli does not sell or rent your personal data to any third party for their own marketing purposes. amjilli may share your personal data with the following categories of recipients for the purposes stated:

• PAGCOR (Philippine Amusement and Gaming Corporation): As required under amjilli's operating licence, player account data, transaction records, and gameplay data may be disclosed to PAGCOR for regulatory oversight and compliance reporting.
• Anti-Money Laundering Council (AMLC): Transaction data and player information may be reported to AMLC where required under the Anti-Money Laundering Act (Republic Act 9160, as amended).
• Payment processors: GCash (G-Xchange Inc.), Maya (Voyager Innovations), BPI, BDO, and other Philippine payment partners receive the minimum data necessary to process your financial transactions.
• Identity verification providers: Your KYC documents and identity data are shared with our contracted identity verification service provider solely for the purpose of verifying your identity and age.
• Technology infrastructure providers: Cloud hosting, database management, and cybersecurity service providers who process data on amjilli's behalf as personal information processors under data processing agreements.
• Game content providers: Limited technical identifiers (not your full identity) may be shared with game providers (e.g., JILI, Pragmatic Play, BetterLive) for game session management purposes.
• Law enforcement and courts: Where required by a valid court order, subpoena, or other legal process under Philippine law, amjilli will disclose personal data as directed.

8. Cross-Border Data Transfers

Where amjilli engages service providers or technology partners whose infrastructure is located outside the Philippines, any transfer of personal data outside Philippine territory is subject to the requirements of Section 21 of the Data Privacy Act of 2012. amjilli ensures that such transfers are made only to countries or organizations that provide an adequate level of data protection, or under appropriate contractual safeguards (such as data processing agreements incorporating standard contractual clauses), and subject to prior notification to the National Privacy Commission where required.

By using amjilli's platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside the Philippines where necessary for the platform's operations, subject to the protections described above.

9. Data Retention

amjilli retains your personal data for the period necessary to fulfill the purpose for which it was collected, subject to the following minimum retention periods required by law and PAGCOR regulation:

• Account registration and KYC data: retained for a minimum of five (5) years following account closure, as required by PAGCOR and AML regulations.
• Financial transaction records: retained for a minimum of five (5) years following the date of the transaction, in compliance with the Anti-Money Laundering Act.
• Gameplay and bet history: retained for a minimum of three (3) years following account closure.
• Customer support communications: retained for two (2) years from the date of the interaction.
• Marketing consent records: retained for as long as consent remains active and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, amjilli will securely delete or irreversibly anonymize your personal data. Where retention beyond the standard period is required for an ongoing regulatory investigation, legal proceeding, or dispute, the data will be retained until the matter is resolved.

10. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and amjilli's servers.
• Encryption of sensitive data at rest, including KYC documents, payment details, and passwords (passwords are stored using one-way cryptographic hashing and are never stored in plaintext).
• Role-based access controls ensuring that amjilli personnel can only access personal data on a need-to-know basis relevant to their specific function.
• Regular security assessments and penetration testing of the amjilli platform infrastructure.
• Multi-factor authentication requirements for internal staff accessing player data systems.
• Incident response procedures for identifying, containing, and reporting personal data breaches, including notification to the NPC and affected players within the timeframes prescribed by the DPA.

11. Cookies & Tracking Technologies

amjilli uses cookies and similar tracking technologies (such as local storage and session identifiers) to operate and improve the platform. The types of cookies used include:

• Essential cookies: Strictly necessary for the platform to function — enabling login sessions, wallet balance display, and game loading. These cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and last-visited game category.
• Analytics cookies: Collect anonymized and aggregated data about how players interact with amjilli.one — page load times, navigation patterns, feature usage — to help us improve platform performance.
• Security cookies: Used for fraud detection, bot prevention, and session integrity verification.

amjilli does not use third-party advertising or behavioral tracking cookies. Your browser settings can be used to manage or delete cookies; however, disabling essential cookies will prevent the amjilli platform from functioning correctly.

12. Data of Minors

amjilli does not knowingly collect personal data from individuals under the age of 21. The amjilli platform is strictly restricted to players who are 21 years of age or older, in compliance with PAGCOR's age requirements for online casino-type gaming in the Philippines. Age is verified as part of the KYC process.

If amjilli becomes aware that personal data has been collected from an individual under the age of 21, the relevant account will be closed immediately, any balance will be returned through the deposit payment method after identity verification, and all collected data will be deleted as soon as the regulatory retention obligations (if any) permit. If you believe a minor has registered on amjilli, please contact our support team immediately.

13. Your Data Subject Rights

The Philippine Data Privacy Act of 2012 grants you the following rights with respect to your personal data held by amjilli. These rights may be subject to limitations where amjilli has an overriding legal obligation (such as AML retention requirements) that prevents immediate fulfillment.

To exercise any of these rights, submit a written request to amjilli's Data Protection Officer through the contact details provided in Section 16. amjilli will respond within fifteen (15) working days of receiving a valid, authenticated request, as required under NPC regulations. amjilli may request additional identification verification before processing a data rights request to ensure data is not disclosed to unauthorized parties.

14. Marketing Communications

With your consent, amjilli may send you marketing communications regarding promotions, new games, special events, and other amjilli offers via SMS to your registered Philippine mobile number and/or through in-platform notifications.

You can withdraw your consent to marketing communications at any time by:

• Adjusting your communication preferences in your amjilli account settings;
• Replying STOP to any marketing SMS received from amjilli; or
• Contacting amjilli support and requesting removal from all marketing lists.

Withdrawal of marketing consent takes effect within 5 business days. Transactional communications (such as deposit confirmations, withdrawal notifications, OTP messages, and account security alerts) are not marketing communications and cannot be opted out of while your account remains active.

15. Third-Party Platforms & Links

amjilli.one may contain references or navigation links to other amjilli pages or integrated services. This Policy applies solely to the amjilli.one platform. Game providers and payment processors integrated into the platform maintain their own privacy policies governing their own data processing activities. amjilli is not responsible for the privacy practices of third-party systems that process data independently of amjilli's instructions, and encourages players to review the relevant privacy policies of payment providers such as GCash and Maya before using those services.

16. Data Protection Officer

In compliance with Section 21 of the Data Privacy Act of 2012 and NPC Circular 16-01, amjilli has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and Philippine data protection law.

To contact amjilli's Data Protection Officer for data rights requests, privacy concerns, or privacy-related complaints, please reach out through amjilli's support live chat at amjilli.one or via the support email address published in the Contact section of the platform. All privacy-related communications should be clearly marked as a privacy inquiry addressed to the Data Protection Officer.

17. Changes to This Privacy Policy

amjilli may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or regulatory guidance from the NPC or PAGCOR. When material changes are made to this Policy, amjilli will:

• Update the "Last Updated" date at the top of this Policy;
• Display a notice within the amjilli platform informing registered players of the change upon next login; and/or
• Send an SMS notification to registered Philippine mobile numbers where the change significantly affects player data rights.

Your continued use of the amjilli platform following the effective date of any amended Policy constitutes your acceptance of the changes. If you do not agree with a material change, you should close your account before the amended Policy takes effect.

18. Contact Us

For questions, concerns, or formal data rights requests relating to this Privacy Policy, please contact amjilli through any of the following channels:

• Live Chat: Available 24/7 on amjilli.one — the fastest way to reach the support and data privacy team.
• Email: The amjilli support email address is published in the Contact section of amjilli.one. Please mark the subject line clearly as a Privacy Policy inquiry or Data Rights Request.

amjilli is committed to resolving all data privacy inquiries within fifteen (15) working days of receipt. For formal NPC complaints, please refer to the National Privacy Commission's complaint filing process as described in Section 16.