91jili Privacy Policy

This Privacy Policy ("Policy") describes how 91jili ("91jili," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you," "Player," or "User") who access or use the 91jili website and associated gaming services (collectively, the "Platform").

91jili is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. This Policy is drafted in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC").

By registering an account with 91jili, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the 91jili Platform.

This Policy should be read together with our Terms and Conditions, which are incorporated herein by reference. In the event of any conflict between this Policy and the Terms and Conditions with respect to data privacy matters, this Policy shall prevail.

For the purposes of the Data Privacy Act of 2012 and this Policy, 91jili acts as the personal information controller in respect of the personal data collected from users of the Platform. As the personal information controller, 91jili determines the purposes and means of processing your personal data.

If you have any questions, concerns, or requests relating to this Policy or the processing of your personal data, you may contact our Data Protection Officer using the contact details provided in Section 15 of this Policy.

91jili collects the following categories of personal data from users of the Platform:

Where 91jili requires you to submit identity verification documents (such as a passport, driver's licence, or national ID), these documents are processed solely for the purpose of verifying your identity and age, and are stored securely in accordance with Section 10 of this Policy.

91jili collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and similar tracking technologies (see Section 8).
• Third-party sources: Information received from payment processors, identity verification service providers, fraud prevention agencies, and gaming regulatory authorities, where permitted by law.
• Public sources: Publicly available information used to verify your identity or to comply with anti-money laundering obligations, such as sanctions screening databases.

91jili uses the personal data we collect for the following purposes:

1. Account management: To create, maintain, and administer your 91jili account, including verifying your identity and age.
2. Service delivery: To provide you with access to the games, features, and services available on the Platform.
3. Payment processing: To process your deposits and withdrawals through your chosen payment method, including GCash, Maya, and Philippine bank transfers.
4. Legal and regulatory compliance: To comply with our obligations under applicable Philippine law, including anti-money laundering (AML) requirements, know-your-customer (KYC) obligations, and gaming regulatory requirements.
5. Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
6. Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
7. Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
8. Platform improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the Platform.
9. Marketing communications: To send you promotional offers and updates about 91jili, where you have consented to receive such communications. You may opt out at any time.

Under the Data Privacy Act of 2012, 91jili processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and service delivery.
• Legal obligation : Processing required to comply with applicable Philippine laws and regulations, including AML, KYC, and gaming regulatory obligations.
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

91jili does not sell, rent, or trade your personal data to any third party. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Game providers: Software providers whose games are available on the 91jili Platform, to the extent necessary for the delivery of those games.
• Fraud prevention agencies: Third-party services used to detect and prevent fraudulent activity, money laundering, and other financial crimes.
• Regulatory and law enforcement authorities: Philippine gaming regulators, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies, where disclosure is required by law or lawful order.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by 91jili, subject to professional confidentiality obligations.
• Technology and infrastructure providers: Cloud hosting, analytics, and platform technology providers engaged to support the operation of the Platform, subject to contractual data protection obligations.

All third parties with whom 91jili shares personal data are required to process that data in accordance with applicable data protection law and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

91jili uses cookies and similar tracking technologies to enhance your experience on the Platform, to maintain your session, and to collect usage and analytics data. A cookie is a small text file placed on your device when you visit a website. Cookies do not contain executable code and cannot access other data on your device.

The types of cookies used on the 91jili Platform include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security. These cannot be disabled.
• Functional cookies: Used to remember your preferences and settings, such as language and display options.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, helping us identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You may control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality of the Platform. By continuing to use the 91jili Platform after being presented with our cookie notice, you consent to our use of non-essential cookies as described above.

91jili retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general guide, 91jili applies the following retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements under Philippine law.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• Gaming activity records: Retained for a minimum of three (3) years from the date of the activity, for dispute resolution and regulatory compliance purposes.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given.

When personal data is no longer required for any of the purposes described in this Policy and no legal obligation requires its continued retention, 91jili will securely delete or anonymise that data.

91jili implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption of personal data in transit using TLS (Transport Layer Security) protocols.
• Encryption of sensitive personal data at rest using industry-standard encryption algorithms.
• Strict access controls limiting access to personal data to authorised personnel on a need-to-know basis.
• Regular security assessments and penetration testing of the Platform and supporting infrastructure.
• Staff training on data protection obligations and information security best practices.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 91jili will notify the National Privacy Commission and, where required, affected individuals, in accordance with the notification requirements of the Data Privacy Act of 2012 and its implementing rules.

While 91jili takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by 91jili:

1. Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
2. Right of access: The right to request a copy of the personal data 91jili holds about you, together with information about how it is being processed.
3. Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
4. Right to erasure: 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.
5. Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
6. Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
7. Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that your data rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified requests within thirty (30) days. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

Please note that certain rights are subject to limitations under applicable law. For example, we may be unable to delete data that we are legally required to retain for AML or regulatory compliance purposes.

The 91jili Platform is strictly intended for adults aged 21 years and above. 91jili does not knowingly collect personal data from individuals under the age of 21. If you are under 21 years of age, you must not register an account or use the Platform.

If 91jili becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account with 91jili, please contact us immediately using the details in Section 15.

91jili primarily stores and processes personal data within the Philippines. In some cases, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or game software suppliers operating internationally.

Where personal data is transferred outside the Philippines, 91jili ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to process your data in accordance with standards equivalent to those required under the Data Privacy Act of 2012. Such transfers are carried out only where necessary and only to recipients who can demonstrate adequate data protection standards.

By using the 91jili Platform, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

91jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered users by email or by posting a prominent notice on the Platform, at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed of how 91jili is protecting your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 91jili, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that your data rights have not been adequately addressed by 91jili. The NPC can be reached through their official website at privacy.gov.ph (for reference only — not a clickable link).