101jili Privacy Policy

1. Who We Are

1.1 101jili ("we", "us", "our", "the Platform") operates the online gaming platform accessible at https://101jili.app. 101jili is an online gaming platform serving Filipino players and operates in accordance with applicable Philippine laws and regulations.

1.2 For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), 101jili acts as the Personal Information Controller in respect of the personal data of its registered players and website visitors.

1.3 We have appointed a Data Protection Officer (DPO) who is responsible for overseeing our data protection practices and ensuring compliance with applicable privacy laws. Contact details for our DPO are provided in Section 13 of this policy.

2. Personal Data We Collect

2.1 Registration Data. When you create a 101jili account, we collect your full name, date of birth, email address, mobile number, and residential address. This information is required to verify your identity, confirm your eligibility to play, and comply with our Know Your Customer (KYC) obligations.

2.2 Identity Verification Documents. As part of our KYC process, we may collect copies of government-issued identification documents (such as a Philippine passport, driver's license, SSS ID, or PhilSys national ID), proof of address, and proof of payment method. These documents are used solely for identity verification and anti-money laundering (AML) compliance purposes.

2.3 Financial Data. We collect information about your deposits, withdrawals, and transaction history on the 101jili platform. We do not store full payment card numbers. Payment processing is handled by our regulated payment partners, and only tokenized or masked payment references are retained by 101jili.

2.4 Gaming Activity Data. We collect records of your gaming sessions, game history, wagering activity, bonus usage, and account balance history. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory reporting.

2.5 Technical Data. When you access the 101jili platform, we automatically collect your IP address, device type, browser type and version, operating system, referring URLs, and session timestamps. This data is used for security monitoring, fraud prevention, and platform optimization.

2.6 Communications Data. We retain records of communications between you and the 101jili support team, including live chat transcripts, email correspondence, and support ticket history. These records are used for quality assurance and dispute resolution.

2.7 Marketing Preferences. If you opt in to receive marketing communications, we record your preferences and the communications sent to you. You may update your marketing preferences at any time through your account settings.

3. How We Use Your Personal Data

3.1 101jili uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your 101jili account, including processing deposits and withdrawals, managing bonuses, and providing customer support;
• Identity Verification & KYC: To verify your identity, confirm your age (21+), and comply with our KYC and AML obligations under Philippine law;
• Regulatory Compliance: To comply with applicable laws and regulations, including reporting obligations to PAGCOR and other relevant Philippine regulatory authorities;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform;
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the features and performance of the 101jili platform;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have opted in to receive such communications.

4. Legal Basis for Processing

4.1 101jili processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of our contract with you (i.e., the provision of gaming services under our Terms and Conditions);
• Legal Obligation: Processing is necessary for compliance with our legal obligations under Philippine law, including KYC, AML, and regulatory reporting requirements;
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and compliant gaming platform, provided those interests are not overridden by your data protection rights;
• Consent: Where we rely on your consent (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

5.1 101jili does not sell, rent, or trade your personal data to third-party marketers or data brokers under any circumstances.

5.2 We may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Processors: GCash, Maya, and our banking partners, for the purpose of processing your deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and AML service providers who assist us in verifying player identities and screening for financial crime risks;
• Game Software Providers: Licensed game studios and software providers whose games are available on the 101jili platform, to the extent necessary for game operation and dispute resolution;
• Regulatory Authorities: PAGCOR and other Philippine government agencies, where we are legally required to disclose information;
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by law or court order;
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict contractual obligations.

5.3 All third-party service providers who process personal data on behalf of 101jili are required to implement appropriate technical and organizational security measures and to process data only in accordance with our instructions.

6. Cookies & Tracking Technologies

6.1 The 101jili platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and analyze platform performance. The types of cookies we use include:

• Essential Cookies: Required for the platform to function correctly, including session management and security features. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings and display options.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the platform, helping us identify areas for improvement.
• Marketing Cookies: Used only where you have consented, to deliver relevant promotional content within the 101jili platform.

6.2 You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 101jili platform.

6.3 101jili does not use cookies or tracking technologies to monitor your activity on third-party websites unrelated to our platform.

7. Data Retention

7.1 101jili retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulation. Specifically:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations;
• KYC and identity verification documents are retained for a minimum of five (5) years following the end of the business relationship;
• Support communications are retained for three (3) years;
• Marketing preference records are retained until you withdraw consent or request deletion.

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

8. Data Security

8.1 101jili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data in transit between your device and our servers;
• Encryption of sensitive data at rest, including identity documents and financial records;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication for administrative access to our systems;
• 24/7 security monitoring and intrusion detection systems.

8.2 While we take all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your 101jili login credentials and for notifying us immediately if you suspect any unauthorized access to your account.

9. Your Data Protection Rights

9.1 Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by 101jili:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy;
• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

9.2 To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 13. We will respond to all verified data subject requests within fifteen (15) business days.

9.3 We may need to verify your identity before processing a data subject request. This is to ensure that personal data is not disclosed to unauthorized parties.

10. Children's Privacy

10.1 The 101jili platform is strictly intended for adults aged twenty-one (21) years and above, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from individuals under the age of 21.

10.2 If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the 101jili platform, please contact our support team immediately.

11. International Data Transfers

11.1 Some of our third-party service providers, including cloud infrastructure and game software providers, may be located outside the Philippines. Where personal data is transferred internationally, 101jili ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law.

11.2 Such safeguards may include contractual clauses requiring the recipient to process personal data in accordance with applicable data protection standards, or reliance on the recipient's participation in a recognized data protection framework.

12. Updates to This Privacy Policy

12.1 101jili reserves the right to update or amend this Privacy Policy at any time. Where changes are material, we will notify registered players via email or a prominent notice on the platform prior to the changes taking effect.

12.2 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 we are protecting your personal data.

12.3 Your continued use of the 101jili platform following the posting of any changes to this Privacy Policy constitutes your acceptance of those changes.

13. Contact Us & Data Protection Officer

13.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 101jili, please contact our Data Protection Officer:

13.2 If you are not satisfied with our response to your data protection concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.