Privacy Policy

1. Introduction

291 Jili is committed to protecting the privacy and personal data of every player who uses our platform. This 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 applies to all personal data collected through the 291 Jili website, mobile platform, customer support channels, and any other touchpoint through which you interact with us. It covers data collected from players based in the Philippines and any other jurisdiction where 291 Jili operates.

We encourage you to read this Policy carefully. If you have questions about how 291 Jili handles your personal data, please contact our Data Protection Officer (DPO) using the details provided in Section 13 of this Policy.

2. Personal Data We Collect

291 Jili collects personal data that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the platform. The categories of personal data we collect include:

2.1 Identity and Contact Information

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify the 21+ age requirement)
• Philippine mobile number and email address
• Residential address (province, city, barangay)
• Government-issued ID details (e.g., PhilSys ID, passport, SSS ID, driver's license) — collected during KYC verification

2.2 Financial Information

• GCash or PayMaya account number (for deposit and withdrawal processing)
• Bank account details (BPI, BDO, Metrobank, or other linked banks) where applicable
• Transaction history, deposit amounts, and withdrawal records

2.3 Account and Gaming Activity Data

• Username and encrypted password
• Game history, bet amounts, win/loss records, and session durations
• Bonus and promotional activity linked to your account
• Responsible gaming settings (deposit limits, self-exclusion status)

2.4 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session timestamps and platform access logs
• Cookie identifiers and similar tracking technologies (see Section 7)

3. How We Collect Your Data

291 Jili collects personal data through the following means:

• Registration: When you create a 291 Jili account, you provide your name, date of birth, contact details, and login credentials directly.
• KYC Verification: When you submit identity documents to verify your account or process a withdrawal.
• Transactions: When you make deposits or withdrawals via GCash, PayMaya, or bank transfer, transaction data is recorded automatically.
• Platform Use: Your gaming activity, session data, and device information are collected automatically as you use the platform.
• Customer Support: When you contact our support team via live chat or email, the content of those communications is recorded.
• Cookies and Tracking: Cookies and similar technologies collect technical data about your browsing behavior on the 291 Jili platform (see Section 7).

4. How We Use Your Personal Data

291 Jili uses your personal data for the following purposes:

291 Jili 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 where you have given explicit consent.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 291 Jili processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration — including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with Philippine law, PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, and other applicable legal requirements.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes such as marketing communications, where we have obtained your explicit, informed consent. You may withdraw consent at any time by contacting our support team.

6. Data Sharing and Disclosure

291 Jili does not sell or rent your personal data to third parties. We may share your data only in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the 291 Jili platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC verification providers, cloud hosting services, and customer support tools. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

6.2 Regulatory and Legal Authorities

291 Jili may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts of competent jurisdiction where required by Philippine law or a valid legal order.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 291 Jili's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer.

7. Cookies and Tracking Technologies

The 291 Jili platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze platform usage. The types of cookies we use include:

• Essential Cookies: Required for the platform to function correctly, including session authentication and security tokens. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming limits.
• Analytics Cookies: Collect anonymized data about how players use the platform to help us identify areas for improvement. No personally identifiable information is included in analytics data.
• Security Cookies: Help detect and prevent fraudulent activity, unauthorized access, and bot traffic.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent you from logging in or using certain features of the 291 Jili platform. 291 Jili does not use third-party advertising cookies or behavioral tracking cookies for marketing purposes.

8. Data Retention

291 Jili retains your personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law. Specific retention periods include:

• Account Data: Retained for the duration of your active account plus five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act (AMLA) and PAGCOR regulations.
• KYC Documents: Retained for five (5) years following account closure or the last transaction, whichever is later.
• Customer Support Records: Retained for two (2) years following the resolution of the relevant inquiry or dispute.
• Technical Logs: Retained for up to twelve (12) months for security and fraud investigation purposes.

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

9. Data Security

291 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:

• AES-256 encryption for all personal data stored at rest
• TLS 1.3 encryption for all data transmitted between your device and our servers
• Multi-factor authentication (MFA) options for player accounts
• Regular security audits and penetration testing by independent third parties
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• 24/7 intrusion detection and monitoring systems
• Secure data centers with physical access controls

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 291 Jili:

• Right to be Informed: The right to know what personal data we collect, how we use it, and with whom we share it — as described in this Policy.
• Right of Access: The right to request a copy of the personal data we hold 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 legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13. We will respond to all verified requests within thirty (30) calendar days. Some requests may be subject to identity verification before we can process them.

11. Children's Privacy and Age Restriction

The 291 Jili platform is strictly intended for individuals who are 21 years of age or older, in compliance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the data, and report the incident to the relevant authorities where required. If you believe a minor has registered on the 291 Jili platform, please contact our support team immediately.

12. Changes to This Privacy Policy

291 Jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The "Last Updated" date at the top of this page will be revised accordingly.

Material changes to this Policy will be communicated to registered players via email notification or a prominent notice on the platform at least seven (7) days before the changes take effect. Your continued use of the 291 Jili platform following the effective date of any amendments constitutes your acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 291 Jili protects your personal data.

13. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 291 Jili, please contact our Data Protection Officer (DPO):