Privacy Policy

1. Introduction and Scope

1.1 95 Jili takes the privacy of its players seriously. This Policy has been prepared in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA) of the Republic of the Philippines, its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC).

1.2 This Policy applies to all personal information collected from individuals who visit or use the 95 Jili Platform, including registered players, prospective registrants who browse the Platform without completing registration, and individuals who contact our customer support team.

1.3 By using the 95 Jili Platform or by registering an account, you acknowledge that you have read and understood this Policy and you consent to the collection and processing of your personal information as described herein. If you do not agree with this Policy, you must not use the Platform.

1.4 Where this Policy refers to "personal information," this includes personal data as defined under the Philippine DPA: any information from which the identity of an individual is apparent or can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual.

2. Personal Information We Collect

2.1 Registration Data: When you create a 95 Jili account, we collect your full legal name, date of birth, email address, mobile phone number, and a username of your choosing.

2.2 Identity Verification (KYC) Data: To comply with anti-money laundering obligations and PAGCOR regulatory requirements, we collect copies of government-issued identity documents (such as PhilSys, UMID, Passport, or LTO Driver's License), proof of address where required, and — for high-value accounts — source-of-funds documentation.

2.3 Financial Data: We collect data related to your payment transactions, including GCash account references, PayMaya account references, bank account names and partial numbers (for BPI, BDO, Metrobank transfers), and transaction history. We do not store full card numbers or full bank account numbers on our servers.

2.4 Gaming Activity Data: We collect records of your game sessions, wagers placed, outcomes, bonus claims, and account balance history. This data is essential for platform integrity, dispute resolution, and regulatory compliance.

2.5 Technical and Device Data: We automatically collect your IP address, browser type and version, device type and operating system, session timestamps, and pages visited on the Platform. This data is used for security monitoring, fraud detection, and platform performance analysis.

2.6 Communications Data: When you contact 95 Jili customer support via live chat or email, we retain records of your communications for quality assurance, dispute resolution, and legal compliance purposes.

2.7 Voluntary Data: Any additional information you choose to provide — such as preferences shared through surveys or feedback submitted to 95 Jili — is collected on a voluntary basis.

3. How We Collect Your Information

3.1 Directly from You: Most personal information is collected directly when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or voluntarily provide information through forms or surveys on the Platform.

3.2 Automatically: Technical and device data is collected automatically when you access the Platform, through server logs, session tracking technology, and cookies (see Section 7).

3.3 From Third Parties: We may receive information from payment service providers (such as GCash/GXchange Inc. and PayMaya/Maya Philippines Inc.), identity verification service providers, and fraud detection partners strictly for the purposes described in this Policy.

4. Purposes of Processing

4.1 95 Jili processes your personal information for the following purposes:

• Account management: creating, maintaining, verifying, and closing your player account;
• Service delivery: enabling you to use all features of the Platform including games, deposits, withdrawals, and bonus programmes;
• Identity verification: conducting KYC checks as required by applicable AML and PAGCOR regulations;
• Fraud prevention and security: detecting, investigating, and preventing fraudulent transactions, account breaches, and prohibited conduct;
• Legal and regulatory compliance: meeting obligations imposed by Philippine law, PAGCOR regulations, and AML reporting requirements;
• Customer support: responding to your enquiries, resolving disputes, and providing technical assistance;
• Responsible gaming: implementing self-exclusion requests, deposit limits, and other player protection measures;
• Platform improvement: analysing aggregated usage data to improve the performance, functionality, and user experience of the Platform;
• Marketing communications: sending you promotional offers and platform updates where you have provided consent and not subsequently withdrawn it.

5. Legal Basis for Processing

5.1 95 Jili processes your personal information on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: processing required to perform our obligations under the account agreement and Terms & Conditions;
• Legal obligation: processing required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (AMLA), its amendments, and PAGCOR regulatory requirements;
• Legitimate interests: processing for fraud prevention, platform security, and aggregated analytics that do not override your fundamental privacy rights;
• Consent: processing for marketing communications, where your opt-in consent has been obtained and can be withdrawn at any time.

6. Sharing Your Personal Information

6.1 95 Jili does not sell your personal information. We may share your information with third parties in the following limited circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers strictly to process your financial transactions;
• KYC/AML service providers: accredited identity verification and anti-money laundering screening providers engaged by 95 Jili to fulfil regulatory obligations;
• Game suppliers: game content providers (such as JILI, PG Soft, Pragmatic Play) receive anonymised session data necessary to operate their games on our Platform;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or any other competent Philippine authority where disclosure is required by law or regulation;
• Professional advisers: lawyers, auditors, and insurers bound by confidentiality obligations, where necessary for the operation of 95 Jili's business;
• Business transfers: in the event of a merger, acquisition, or sale of substantially all assets of 95 Jili, personal data may be transferred as part of that transaction, subject to equivalent privacy protections.

6.2 All third-party processors engaged by 95 Jili are contractually required to process personal data only as directed by 95 Jili, to implement appropriate security measures, and to comply with applicable Philippine privacy law.

7. Cookies and Tracking Technologies

7.1 The 95 Jili Platform uses cookies and similar tracking technologies to operate certain features of the Platform, maintain your session after login, and collect analytics data about Platform usage.

7.2 Essential cookies are strictly necessary for the Platform to function — for example, maintaining your authentication session. These cannot be disabled.

7.3 Analytics cookies help us understand how players interact with the Platform so we can improve it. These are set on an aggregated, anonymised basis.

7.4 Preference cookies remember your settings and preferences (such as language or display options) to personalise your experience.

7.5 You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform.

8. Data Retention

8.1 95 Jili retains personal information for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC records: retained for a minimum of 5 years from the date of account closure, as required by Philippine AML regulations;
• Transaction records: retained for a minimum of 5 years from the date of the transaction;
• Game activity records: retained for a minimum of 2 years;
• Customer support communications: retained for a minimum of 2 years from the date of the communication;
• Marketing consent records: retained for the duration of the consent period plus 1 year for compliance documentation purposes.

8.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised, unless continued retention is required for ongoing legal proceedings or regulatory investigations.

9. Data Security

9.1 95 Jili implements technical and organisational security measures designed to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These measures include, without limitation:

• Transport Layer Security (TLS/SSL) encryption for all data in transit between your device and our servers;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Multi-factor authentication requirements for system administrators;
• Incident response procedures for personal data breach detection, containment, and notification.

9.2 While 95 Jili takes these measures seriously, no system is completely impenetrable. Players are encouraged to maintain strong, unique passwords and to enable two-factor authentication on their accounts to reduce personal risk.

10. Your Rights as a Data Subject

10.1 Under the Philippine Data Privacy Act, you have the following rights with respect to your personal information held by 95 Jili:

• Right to be informed: the right to know how your personal data is being collected and processed;
• Right to access: the right to obtain a copy of the personal data we hold about you;
• Right to correction: the right to request correction of inaccurate or incomplete personal data;
• Right to erasure or blocking: the right to request deletion or blocking of personal data where processing is no longer necessary, was unlawful, or where consent has been withdrawn, subject to our legal retention obligations;
• Right to damages: the right to be compensated for damages sustained as a result of inaccurate, incomplete, or unauthorised processing of your data;
• Right to data portability: the right to receive your personal data in a structured, commonly used format for transmission to another controller;
• Right to object: the right to object to processing based on legitimate interests or for direct marketing purposes;
• Right to lodge a complaint: the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your rights under the DPA have been violated.

10.2 To exercise any of the above rights, please contact our Data Protection Officer (see Section 14). We will respond to valid requests within 15 business days. We may request identity verification before processing your request.

11. Children's Privacy

11.1 The 95 Jili Platform is strictly for individuals aged 21 years and above. We do not knowingly collect personal information from individuals below this age.

11.2 If 95 Jili becomes aware that personal data has been collected from a person under the age of 21, we will immediately close the associated account, delete the data, and — where required — report the matter to the appropriate regulatory authority.

11.3 If you are a parent or guardian and have reason to believe your child has registered on the 95 Jili Platform, please contact us immediately at the address provided in Section 14.

12. International Data Transfers

12.1 Certain service providers engaged by 95 Jili may be located outside the Philippines. Where personal data is transferred to a recipient in a foreign jurisdiction, 95 Jili ensures that appropriate safeguards are in place, including contractual data processing agreements that impose data protection standards consistent with Philippine law.

12.2 By using the Platform, you acknowledge that your personal data may be processed in jurisdictions outside the Philippines where equivalent data protection laws may apply through contractual mechanisms.

13. Amendments to This Policy

13.1 95 Jili reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. Material changes will be communicated to registered players via email and/or a prominent notice on the Platform prior to taking effect.

13.2 The date of the most recent revision is indicated at the top of this Policy. Continued use of the Platform after the effective date of any amendment constitutes acceptance of the revised Policy.