jilibaby Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how jilibaby ("jilibaby," "we," "us," "our") collects, uses, discloses, stores, and protects the personal data of users ("you," "Player," "Data Subject") of the jilibaby website at jilibaby.org and its associated mobile applications and services (collectively, the "Platform").

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and applicable circulars and guidelines issued by the National Privacy Commission of the Philippines. By registering a jilibaby account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2. Data Controller Information

jilibaby operates as the Personal Information Controller (PIC) in respect of personal data collected through the Platform, as defined under Section 3(h) of the Data Privacy Act. jilibaby has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy laws. Contact details for the DPO are set out in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Registration Data

When you create a jilibaby account, we collect: full legal name, date of birth, Philippine mobile number, email address, residential address, username, and password (stored in hashed form). This data is required to open and manage your account.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR requirements and the Anti-Money Laundering Act, we collect copies of government-issued identification documents (e.g., Philippine Passport, PhilSys National ID, SSS ID, Driver's License, PRC ID) and selfie photographs for identity verification purposes prior to processing withdrawals.

3.3 Financial Data

We collect information about your deposits and withdrawals, including GCash account numbers, Maya wallet details, and bank account information (BPI, BDO, Metrobank or other Philippine banks) as necessary to process financial transactions. We do not store full payment card numbers on our servers.

3.4 Gameplay & Transaction Data

We collect records of your wagering activity, game session history, bet amounts, game outcomes, bonus usage, and transaction history. This data is required to operate the Platform, settle wagers, calculate bonuses, and comply with regulatory reporting obligations.

3.5 Technical & Device Data

We automatically collect technical information when you access the Platform, including IP address, device type and model, operating system version, browser type and version, session timestamps, and geolocation data (country and region level). This data is used for security monitoring, fraud detection, and geographic access control.

3.6 Communications Data

We retain records of your communications with jilibaby customer support, including live chat transcripts, email correspondence, and any supporting documentation you provide in connection with a support request or dispute.

4. How We Use Your Personal Data

jilibaby uses the personal data described in Section 3 for the following purposes:

• Account creation and management: To register your account, verify your identity, and enable access to the Platform;
• Transaction processing: To process deposits, settle winning wagers, and execute withdrawal requests to your GCash, Maya, or bank account;
• Regulatory compliance: To fulfill obligations under PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws, including transaction reporting to the AMLC where required;
• Fraud prevention and security: To detect and prevent fraudulent activity, multiple account registrations, bonus abuse, and unauthorized access to your account;
• Customer support: To respond to your inquiries, resolve disputes, and provide account-related assistance;
• Responsible gaming: To monitor gambling patterns and fulfil responsible gaming obligations, including enforcing self-exclusion requests and applying deposit and loss limits you have set;
• Platform improvement: To analyze usage patterns (in aggregated, anonymized form where possible) to improve game selection, user interface, and platform performance;
• Marketing communications: To send you promotional offers and bonus notifications where you have provided consent and have not opted out. You may withdraw marketing consent at any time via account settings or by contacting our DPO.

5. Legal Basis for Processing

jilibaby processes your personal data on the following legal bases under the Data Privacy Act:

• Contract performance: Processing necessary to deliver the services you have contracted for by registering a jilibaby account;
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLC reporting requirements, and other applicable Philippine legal obligations;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing;
• Legitimate interests: Processing for fraud detection, security monitoring, and Platform improvement where our legitimate interests do not override your fundamental data privacy rights.

6. Data Sharing and Disclosure

jilibaby does not sell, rent, or otherwise commercially exploit your personal data. We share personal data with third parties only in the following circumstances:

• Service providers: Payment processors (GCash, Maya, Philippine banks), KYC verification providers, cloud infrastructure providers, and customer support platform operators engaged under written data processing agreements that require them to protect your data;
• Game content providers: JILI Games and other game software licensors receive session-level data necessary to authenticate gameplay. No additional personal data is shared;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies where we are legally obligated or have a good-faith basis to report;
• Corporate transactions: In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the successor entity, subject to this Policy or a materially equivalent privacy policy.

7. Cookies and Tracking Technologies

jilibaby uses cookies and similar tracking technologies to operate the Platform and improve your experience. The categories of cookies we use are:

• Strictly necessary cookies: Required for session authentication and platform security. These cannot be disabled without impairing Platform functionality;
• Functional cookies: Store your preferences (e.g., language settings, preferred game lobby view) to personalize your experience;
• Analytics cookies: Collect aggregated, anonymized data about how players interact with the Platform to help us improve performance and user experience. We use privacy-respecting analytics solutions that do not share your data with third-party advertising networks;
• Marketing cookies: Used only where you have given explicit consent to receive personalized promotions. You may opt out at any time via the cookie preferences panel accessible in the Platform footer.

Most browsers allow you to manage cookie preferences through browser settings. Disabling strictly necessary cookies will impair your ability to use the jilibaby Platform.

8. Data Retention

jilibaby retains personal data for the following periods, after which data is securely deleted or anonymized:

• Account data: For the duration of your active account plus five (5) years following account closure, in accordance with PAGCOR regulatory record-keeping requirements;
• KYC and AML records: Minimum five (5) years from the date of the relevant transaction or account closure, as required by the Anti-Money Laundering Act;
• Transaction records: Five (5) years from transaction date;
• Customer support communications: Three (3) years from the date of the communication;
• Technical logs: Ninety (90) days for routine operational logs; up to twelve (12) months for security incident-related logs.

Where retention beyond these periods is required by a specific legal obligation, regulatory directive, or active legal proceeding, data will be retained until the obligation is resolved.

9. Security Measures

jilibaby implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption for all data in transit between your device and jilibaby servers;
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records;
• Bcrypt password hashing — jilibaby staff cannot access your actual password;
• Multi-factor authentication (SMS OTP) available for all player accounts and enforced for all administrative access;
• Regular third-party penetration testing and security audits;
• Role-based access controls limiting personal data access to staff with a demonstrated operational need;
• Automated intrusion detection and anomaly-based alerting systems;
• Incident response procedures aligned with NPC breach notification requirements under Section 20 of the Data Privacy Act.

In the event of a personal data breach that is likely to adversely affect your rights and freedoms, jilibaby will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

10. Your Data Subject Rights

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

To exercise any of these rights, contact the jilibaby Data Protection Officer using the contact details in Section 14. We will respond to verified requests within fifteen (15) business days. We may require identity verification before processing a rights request. Where we are unable to fulfill a request — for example, because it conflicts with a legal obligation — we will explain the reasons in writing.

If you are unsatisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

11. Minors

jilibaby is a real-money gambling platform strictly restricted to individuals aged 21 years and older. We do not knowingly collect personal data from persons under the age of 21. Where jilibaby discovers that an account has been registered by a minor, the account will be immediately and permanently closed, any funds held will be reviewed and handled in accordance with applicable law, and the matter will be referred to the relevant authorities. Parents or guardians who believe their child has registered a jilibaby account are encouraged to contact us immediately via the support chat on jilibaby.org.

12. Cross-Border Data Transfers

Some of jilibaby's service providers — including cloud infrastructure and game content providers — may process or store data in jurisdictions outside the Philippines. Where personal data is transferred outside the Philippines, jilibaby ensures that appropriate safeguards are in place, including contractual clauses approved by the National Privacy Commission or equivalent data protection standards. We do not transfer personal data to jurisdictions that do not provide an adequate level of protection comparable to the Data Privacy Act.

13. Changes to This Privacy Policy

jilibaby may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes — meaning changes that affect your rights or the way we use your personal data in a significant way — will be communicated to you via a notice on the Platform or by email to your registered address at least fourteen (14) days before the changes take effect. Non-material changes (e.g., clarifications, corrections to typographical errors) may be made without prior notice. The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of the Platform after the effective date constitutes acceptance of the updated Policy.

14. Contact Us & Data Protection Officer

For any privacy-related inquiries, to exercise your data subject rights, or to contact the jilibaby Data Protection Officer, please use the following contact information. All requests are acknowledged within three (3) business days: