Jilitt Privacy Policy

1 Introduction

Jilitt ("Jilitt," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the Jilitt online gaming platform ("Platform"). This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information when you access or use the Jilitt Platform available at jilitt.app.

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission of the Philippines. By registering an account on Jilitt or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with the Jilitt Terms & Conditions and Responsible Gaming Policy, which together govern your use of the Jilitt Platform.

2 Data Controller

For the purposes of applicable Philippine data privacy legislation, Jilitt is the personal information controller in respect of the personal data collected through the Platform. Jilitt determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with this Policy and applicable law.

If you have any questions about how Jilitt processes your personal data, or if you wish to exercise any of your data subject rights as described in Section 11 of this Policy, please contact our Data Protection Officer using the contact details provided in Section 14.

3 Personal Data We Collect

Jilitt collects the following categories of personal data from players and Platform visitors:

3.1 Identity & Contact Data

• Full legal name;
• Date of birth;
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence);
• Email address;
• Mobile phone number;
• Residential address (including city, province, and postal code).

3.2 Financial Data

• GCash account number or registered mobile number;
• PayMaya account details;
• Bank account details (BPI, BDO, Metrobank, or other accepted banks);
• Transaction history, including deposits, withdrawals, and wager amounts;
• Source of funds documentation where required for KYC compliance.

3.3 Gaming & Behavioural Data

• Game play history, including games played, wagers placed, and outcomes;
• Session duration and frequency of Platform use;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status).

3.4 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Unique device identifiers;
• Log data, including access times, pages viewed, and error reports.

3.5 Communications Data

• Records of communications between you and Jilitt customer support;
• Feedback, complaints, and survey responses submitted to Jilitt.

Jilitt does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive personal information is collected (such as government ID numbers), it is handled with the heightened level of care required under the Data Privacy Act of 2012.

4 How We Collect Your Data

Jilitt collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and device data collected automatically when you access the Platform, including through cookies and similar tracking technologies (see Section 8);
• Third-party sources: Identity verification data from K YC and identity verification service providers; fraud prevention and anti-money laundering screening data from compliance service providers; and payment processing data from GCash, PayMaya, and banking partners.

5 How We Use Your Personal Data

Jilitt uses the personal data we collect for the following purposes:

Jilitt will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

Jilitt processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and delivery of gaming services;
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering obligations, KYC requirements, and regulatory reporting;
• Legitimate interests: Processing necessary for Jilitt's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including the sending of promotional communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

7.1 Service Providers

Jilitt shares personal data with carefully selected third-party service providers who assist us in operating the Platform, including: identity verification and KYC providers; payment processors (GCash, PayMaya, BPI, BDO, Metrobank, and other banking partners); game software providers; cloud hosting and infrastructure providers; customer support platform providers; and fraud prevention and cybersecurity service providers. All service providers are contractually required to process personal data only on Jilitt's instructions and to maintain appropriate security measures.

7.2 Regulatory & Law Enforcement Authorities

Jilitt may disclose personal data to relevant Philippine government agencies, regulatory authorities, and law enforcement bodies where required by law, court order, or regulatory direction. This includes disclosures required under anti-money laundering regulations and applicable gaming regulations.

7.3 No Sale of Personal Data

Jilitt does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Any sharing of personal data is limited to what is strictly necessary for the purposes described in this Policy.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of Jilitt's business, your personal data may be transferred to the relevant successor entity. Jilitt will provide reasonable notice of any such transfer and ensure that the successor entity is bound by privacy obligations no less protective than those set out in this Policy.

8 Cookies & Tracking Technologies

The Jilitt Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and collect analytical data about Platform usage. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function, including session authentication and security cookies. These cannot be disabled.
• Functional cookies: Remember your preferences and settings, such as language and display preferences, to personalise your experience on Jilitt.
• Analytical cookies: Collect aggregated, anonymised data about how players use the Platform, helping Jilitt identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats to the Jilitt Platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Jilitt Platform. Strictly necessary and security cookies cannot be disabled without impacting your ability to use the Platform.

9 Data Retention

Jilitt retains personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with applicable anti-money laundering regulations;
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming and behavioural data: Retained for the duration of your account and for two (2) years following account closure;
• Customer support communications: Retained for three (3) years from the date of the communication;
• Technical and device data: Retained for up to twelve (12) months from collection.

Where personal data is no longer required for any lawful purpose, Jilitt will securely delete or anonymise it in accordance with our data disposal procedures.

10 Data Security

Jilitt implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Jilitt Platform;
• Encryption of sensitive data at rest, including financial data and government identification numbers;
• Role-based access controls limiting access to personal data to authorised Jilitt personnel on a need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform;
• Multi-factor authentication requirements for account access and administrative systems;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While Jilitt takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your Jilitt account credentials and for notifying us immediately of any suspected unauthorised access to your account.

11 Your Data Subject Rights

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

• 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;
• Right of access: The right to request a copy of the personal data Jilitt holds about you and information about how it is processed;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held by Jilitt;
• 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 Jilitt's legal retention obligations;
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, including processing for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact Jilitt's Data Protection Officer using the contact details in Section 14. Jilitt will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with applicable NPC guidelines. We may require you to verify your identity before processing your request.

12 Children's Privacy

The Jilitt Platform is strictly restricted to individuals who are twenty-one (21) years of age or older, in accordance with applicable Philippine gaming regulations. Jilitt does not knowingly collect personal data from persons under the age of 21. If Jilitt becomes aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you believe that a person under 21 has registered an account on Jilitt or provided personal data to us, please contact our Data Protection Officer immediately using the contact details in Section 14.

13 Changes to This Privacy Policy

Jilitt reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, Jilitt will provide reasonable advance notice to registered players via email or a prominent notice on the Platform, at least fifteen (15) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the Jilitt Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically to stay informed about how Jilitt protects your personal data.

14 Contact & Complaints

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

If you are not satisfied with Jilitt's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about the NPC complaints process is available through official Philippine government channels.

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