Privacy Policy

1. Introduction

This Privacy Policy describes how 78jili ("Company," "we," "us," or "our") collects, uses, stores, discloses, and protects personal information of users ("you," "your," or "Player") who access our online gaming platform at 78jili.cam or through our mobile applications. This Privacy Policy applies to all services offered by 78jili and should be read in conjunction with our Terms & Conditions.

78jili is committed to protecting your privacy and complying with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations. We are also bound by regulations set forth by the Philippine Amusement and Gaming Corporation (PAGCOR) regarding the protection of player information in the online gaming industry.

By creating an account, accessing our website, or using any 78jili services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with any aspect of this Privacy Policy, you must refrain from using our services.

2. Information We Collect

78jili collects various types of personal and non-personal information to provide, maintain, improve, and secure our services. The information we collect falls into the following categories:

2.1 Information You Provide Directly

When you register an account with 78jili, you voluntarily provide us with personal information including:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (as required for age verification and KYC compliance)
• Contact Information: Residential address, email address, mobile phone number registered in the Philippines
• Account Credentials: Username, password, security questions and answers, and two-factor authentication settings
• Financial Information: Bank account details (bank name, account number, account holder name), GCash or PayMaya wallet information, credit/debit card numbers (last 4 digits stored), transaction history, deposit and withdrawal records
• Verification Documents: Copies of government-issued IDs (Philippine passport, driver's license, UMID, national ID), proof of address documents (utility bills, bank statements), selfie photographs for identity verification
• Communication Data: Messages you send to our customer support team, chat transcripts, emails, and any other correspondence with 78jili

2.2 Information Collected Automatically

When you access 78jili services, we automatically collect certain technical and usage information through cookies, web beacons, and similar tracking technologies:

• Device Information: Device type (mobile, tablet, desktop), operating system, browser type and version, unique device identifiers, mobile network information
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, click patterns, feature usage, search queries within our platform
• Location Data: IP address, geographic location (country, region, city) to verify you are accessing services from within the Philippines as required by law
• Log Data: Access times, error logs, crash reports, referring/exit pages, and other diagnostic data

2.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment processors (GCash, PayMaya, banks) verifying transaction authenticity
• Identity verification services conducting KYC checks
• Fraud prevention services providing risk assessment data
• Game providers supplying gameplay statistics and RTP data
• Marketing partners (only if you have consented to receive promotional materials)

3. How We Use Your Information

78jili uses the personal information we collect for the following legitimate business purposes:

3.1 Service Provision and Account Management

• Create, maintain, and manage your 78jili account
• Process your deposits, withdrawals, and other financial transactions
• Enable you to play games, place bets, and access all platform features
• Track your gaming activity, transaction history, and account balance
• Provide customer support and respond to your inquiries
• Communicate important account notifications, terms updates, and service announcements

3.2 Legal and Regulatory Compliance

• Verify your age (21+ requirement) and identity in compliance with PAGCOR regulations
• Conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures
• Comply with anti-money laundering (AML) laws under RA 9160 and its amendments
• Detect, prevent, and investigate fraud, money laundering, and other illegal activities
• Respond to legal requests, court orders, and government inquiries
• Maintain records as required by Philippine gaming and financial regulations
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC) when legally required

3.3 Security and Fraud Prevention

• Monitor account activity for suspicious behavior and security threats
• Detect and prevent unauthorized access, account takeover, and identity theft
• Identify duplicate accounts and bonus abuse
• Analyze betting patterns to detect collusion, arbitrage, and advantage play
• Protect the integrity of our games and prevent cheating
• Secure our systems against cyberattacks, malware, and data breaches

3.4 Service Improvement and Personalization

• Analyze user behavior to improve platform functionality and user experience
• Develop new features, games, and services based on player preferences
• Personalize game recommendations and content based on your play history
• Optimize website performance, loading speeds, and mobile responsiveness
• Conduct internal research, analytics, and testing

3.5 Marketing and Promotions (With Your Consent)

• Send promotional emails about bonuses, free spins, and exclusive offers (you may opt out)
• Display personalized advertisements on our platform
• Notify you about tournaments, leaderboards, and special events
• Communicate VIP program benefits and personalized rewards

Note: Marketing communications are always optional. You can unsubscribe at any time through your account settings or by contacting customer support. 78jili will never sell your personal information to third-party marketers.

3.6 Responsible Gaming

• Monitor gambling behavior for signs of problem gambling
• Enforce deposit limits, loss limits, and self-exclusion requests
• Provide access to responsible gaming tools and support resources
• Comply with PAGCOR's responsible gaming requirements

4. Legal Basis for Processing Personal Data

Under the Philippine Data Privacy Act, 78jili must have a valid legal basis to collect and process your personal information. We process your data based on the following legal grounds:

Legal Basis	Description	Examples at 78jili
Consent	You have given clear, informed consent for us to process your personal data for specific purposes.	Marketing emails, personalized advertisements, optional data collection for service improvement
Contract Performance	Processing is necessary to fulfill our contractual obligations under the Terms & Conditions you agreed to.	Account creation, game access, processing deposits/withdrawals, providing customer support
Legal Obligation	We must process your data to comply with Philippine laws and regulations.	Age verification (21+), KYC/AML compliance, PAGCOR reporting, tax obligations, responding to law enforcement
Legitimate Interest	Processing is necessary for our legitimate business interests, provided it does not override your rights and freedoms.	Fraud prevention, security monitoring, platform improvement, analytics, enforcing terms of service

5. How We Share Your Information

78jili does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with carefully selected third parties under the following circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to assist with business operations. These providers have access to your personal information only to perform specific tasks on our behalf and are contractually obligated to protect your data:

• Payment Processors: GCash, PayMaya, banks, and payment gateways processing your deposits and withdrawals
• Identity Verification Services: Third-party KYC/AML compliance providers verifying your identity and screening for fraud
• Game Providers: Software developers supplying slots, live casino, and other games (they may collect gameplay data)
• Cloud Hosting Providers: Companies hosting our servers and databases (all data stored in secure, encrypted environments)
• Customer Support Tools: Live chat platforms, ticketing systems, and CRM software
• Email Service Providers: Platforms sending transactional and marketing emails on our behalf
• Analytics Providers: Services helping us understand user behavior and improve our platform

5.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, regulators, and law enforcement when required by law or when we believe disclosure is necessary to:

• Comply with court orders, subpoenas, or legal processes
• Report to PAGCOR as required under our licensing obligations
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Cooperate with law enforcement investigations
• Respond to National Privacy Commission (NPC) inquiries
• Enforce our Terms & Conditions and protect our legal rights
• Protect the safety and security of 78jili, our users, or the public

5.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. You will be notified of any such change via email or prominent notice on our website.

5.4 Aggregated and Anonymized Data

We may share aggregated, de-identified, or anonymized data that cannot be used to identify you personally. This includes statistical reports on user demographics, popular games, betting trends, and platform usage patterns. Such data may be shared with business partners, industry analysts, or the public.

6. Data Security Measures

Protecting your personal information is a top priority at 78jili. We implement comprehensive technical, administrative, and physical security measures to safeguard your data against unauthorized access, disclosure, alteration, and destruction:

6.1 Technical Security

• Encryption: All data transmitted between your device and 78jili servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Secure Infrastructure: Our servers are hosted in Tier 3+ data centers with redundant power, climate control, and physical security measures.
• Firewalls and Intrusion Detection: Multi-layered firewalls and real-time intrusion detection systems monitor network traffic for suspicious activity.
• Regular Security Audits: Independent third-party cybersecurity firms conduct penetration testing and vulnerability assessments quarterly.
• Secure Payment Processing: Payment card data is processed through PCI-DSS compliant processors. 78jili does not store full credit card numbers.

6.2 Administrative Security

• Access Controls: Access to personal information is restricted to authorized personnel on a need-to-know basis using role-based access controls.
• Employee Training: All 78jili staff undergo mandatory data privacy and security training upon hiring and annually thereafter.
• Confidentiality Agreements: Employees and contractors sign confidentiality agreements prohibiting unauthorized disclosure of user data.
• Incident Response Plan: We maintain a comprehensive data breach response plan to quickly address and mitigate security incidents.

6.3 Your Security Responsibilities

While 78jili employs robust security measures, you also play a critical role in protecting your account:

• Use a strong, unique password and change it regularly
• Enable two-factor authentication (2FA) for additional security
• Never share your login credentials with anyone
• Log out after each session, especially on shared devices
• Beware of phishing attempts - 78jili will never ask for your password via email
• Keep your contact information up-to-date so we can reach you about security matters
• Report suspicious account activity to our support team immediately

7. Your Privacy Rights Under Philippine Law

The Philippine Data Privacy Act grants you specific rights regarding your personal information. As a 78jili user, you have the following rights:

7.1 Right to Be Informed

You have the right to be informed about the collection, use, and disclosure of your personal information. This Privacy Policy fulfills that obligation by transparently explaining our data practices.

7.2 Right to Access

You may request access to the personal information we hold about you. We will provide you with a copy of your data in a structured, commonly used format within fifteen (15) business days of your request.

7.3 Right to Rectification

If you believe any personal information we hold about you is inaccurate, incomplete, or outdated, you may request correction. You can update most information directly through your account settings or by contacting customer support.

7.4 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal information when it is no longer necessary for the purposes it was collected, you withdraw consent, or the processing is unlawful. However, we may be required to retain certain data to comply with legal obligations (e.g., financial records for tax/AML purposes, dispute resolution records).

7.5 Right to Object

You may object to processing of your personal information for direct marketing purposes at any time. Simply opt out of marketing emails or contact support to stop receiving promotional communications. You may also object to processing based on legitimate interests by providing compelling reasons related to your particular situation.

7.6 Right to Data Portability

You have the right to receive your personal data in a structured, machine-readable format and transmit it to another service provider where technically feasible. This applies to information you provided to 78jili with your consent or under contract.

7.7 Right to Lodge a Complaint

If you believe 78jili has violated your privacy rights or the Data Privacy Act, you may file a complaint with the National Privacy Commission (NPC). Contact details: National Privacy Commission, 5th Floor, Philippine International Convention Center (PICC), CCP Complex, Roxas Boulevard, Pasay City 1308; Email: [email protected]; Website: privacy.gov.ph

7.8 How to Exercise Your Rights

To exercise any of these rights, please submit a written request to our Data Protection Officer. Requests can be sent via email or through our customer support system. We will verify your identity before processing your request and respond within the timeframes required by law. There is no fee for exercising your rights unless your request is manifestly unfounded or excessive.

8. Data Retention

78jili retains your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with legal, regulatory, and business requirements:

8.1 Retention Periods

• Active Accounts: Personal information is retained for the duration of your active 78jili account.
• Closed Accounts: After voluntary account closure, most personal data is anonymized or deleted within ninety (90) days, except where longer retention is required by law.
• Financial Records: Transaction records, deposit/withdrawal history, and related financial data are retained for seven (7) years to comply with tax and anti-money laundering regulations.
• Legal and Regulatory Records: Data related to compliance obligations (KYC documents, age verification, suspicious activity reports) is retained as required by PAGCOR and other regulatory authorities.
• Dispute Resolution: Information related to disputes, complaints, or legal proceedings is retained until final resolution plus applicable statute of limitations periods.
• Security and Fraud Prevention: Logs and records related to security incidents, fraud investigations, and account suspensions may be retained longer to protect 78jili and other users.

8.2 Deletion and Anonymization

Once the retention period expires, personal information is securely deleted or permanently anonymized so it can no longer be associated with you. Deletion methods include secure wiping of electronic storage and destruction of physical documents. Anonymized data may be retained indefinitely for statistical and analytical purposes.

9. Cookies and Tracking Technologies

78jili uses cookies, web beacons, pixels, and similar technologies to enhance your user experience, analyze platform usage, and deliver personalized content.

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow the website to remember your preferences, recognize you on return visits, and track your activity.

9.2 Types of Cookies We Use

• Essential Cookies: Necessary for website functionality (login, session management, security). These cannot be disabled.
• Performance Cookies: Collect anonymous data about website usage, page load times, and error messages to help us improve performance.
• Functionality Cookies: Remember your preferences (language, currency, display settings) to provide a personalized experience.
• Targeting/Advertising Cookies: Track your browsing behavior to deliver relevant advertisements and promotions. You can opt out of these cookies.

9.3 Managing Cookies

Most browsers allow you to control cookies through their settings. You can set your browser to refuse all cookies or alert you when cookies are being sent. However, disabling essential cookies may affect website functionality and your ability to access certain features of 78jili.

10. Children's Privacy

78jili services are strictly for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. Our age verification procedures are designed to prevent minors from creating accounts.

If we discover that we have inadvertently collected information from someone under 21, we will immediately delete that information and close the account. If you believe a minor has created an account on 78jili, please contact us immediately so we can take appropriate action.

Parents and guardians are responsible for monitoring their children's internet usage and ensuring minors do not access gambling websites.

11. International Data Transfers

78jili primarily stores and processes data within the Philippines. However, some of our service providers (cloud hosting, payment processors, game providers) may be located outside the Philippines. When we transfer your personal information internationally, we ensure adequate safeguards are in place:

• Contractual clauses requiring recipients to protect your data in accordance with Philippine standards
• Verification that destination countries provide adequate data protection under Philippine law
• Use of service providers with international certifications (ISO 27001, SOC 2, etc.)

We do not transfer personal information to countries that do not provide adequate data protection without your explicit consent or unless required by law.

12. Changes to This Privacy Policy

78jili reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated Privacy Policy on our website with a new "Last Updated" date
• Sending an email notification to your registered email address
• Displaying a prominent notice on our platform

Continued use of 78jili services after changes become effective constitutes your acceptance of the revised Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

13. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer: