Privacy Policy — 911jili

1. Introduction

911jili ("we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the 911jili platform, available at 911jili.app. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in connection with the 911jili platform and all related services.

This Privacy Policy applies to all members, registered users, and visitors of the 911jili platform, regardless of the device or method used to access the platform. It should be read together with our Terms and Conditions, which govern your use of the 911jili platform.

911jili operates in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Republic of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). We take our obligations under this law seriously and have implemented appropriate technical and organizational measures to protect your personal data.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer (DPO) using the details provided in Section 13 of this Policy.

2. Personal Data We Collect

911jili collects personal data from you in several ways — directly when you provide it to us, automatically when you use the platform, and from third parties where permitted by law. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, email address, Philippine mobile number, and chosen username and password when you create a 911jili account.
• Identity Verification (KYC) Data: Government-issued photo identification (such as a Philippine passport, SSS ID, PhilHealth ID, UMID, or driver's license), proof of address, and selfie photographs submitted for identity verification purposes.
• Payment Data: GCash account details, PayMaya account details, BPI, BDO, or Metrobank account information used for deposits and withdrawals. Note: 911jili does not store full bank account numbers or card numbers on its servers — payment data is processed through secure third-party payment processors.
• Communications Data: Messages, emails, and chat transcripts exchanged with our customer support team, including any attachments or documents you submit in connection with a support request or dispute.
• Responsible Gaming Data: Information you provide when setting deposit limits, cooling-off periods, or self-exclusion requests, including the reasons you provide for such requests where voluntarily given.

2.2 Data Collected Automatically

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, session duration, click patterns, wagering history, deposit and withdrawal history, and bonus usage history.
• Location Data: General geographic location derived from your IP address, used to verify that you are not accessing the platform from a prohibited jurisdiction.
• Cookie and Tracking Data: Data collected through cookies, web beacons, and similar technologies as described in Section 6 of this Policy.

2.3 Data from Third Parties

• Payment Processors: Transaction confirmation data, payment status, and fraud screening results from GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners.
• Identity Verification Providers: Results of automated identity and document verification checks conducted by our KYC service providers.
• Fraud Prevention Services: Risk scores and fraud indicators from third-party fraud detection services used to protect the integrity of the platform.

3. How We Use Your Personal Data

911jili uses the personal data we collect for the following purposes:

911jili will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 911jili processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 911jili — specifically, to create and manage your account, process your transactions, and deliver the gaming services you have requested.
• Legal Obligation: Processing is necessary to comply with applicable Philippine laws and regulations, including anti-money laundering laws, KYC requirements, and gaming regulatory obligations.
• Legitimate Interests: Processing is necessary for the legitimate interests of 911jili, including fraud prevention, platform security, and improving our services, provided that such interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Data Sharing & Disclosure

911jili does not sell your personal data. 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, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity Verification Providers: Third-party KYC and document verification service providers engaged to assist with identity verification and fraud prevention.
• Game Providers: Licensed game content providers whose games are available on the 911jili platform. These providers may receive limited technical data necessary to deliver their games to you.
• IT and Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: Philippine government agencies, regulatory bodies, and law enforcement authorities where disclosure is required by law, court order, or regulatory directive.
• Professional Advisors: Lawyers, accountants, and auditors engaged by 911jili, subject to professional confidentiality obligations.

6. Cookies & Tracking Technologies

911jili uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device when you visit a website. The following types of cookies are used on the 911jili platform:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting the functionality of the platform.
• Performance and Analytics Cookies: These cookies collect anonymized information about how visitors use the platform, such as which pages are visited most frequently and whether error messages are received. This data helps us improve the platform's performance and user experience.
• Functional Cookies: These cookies allow the platform to remember your preferences, such as your chosen language, display settings, and responsible gaming limits, to provide a more personalized experience.
• Marketing and Targeting Cookies: These cookies are used to deliver promotional content that is relevant to your interests. They are only placed with your consent and can be withdrawn at any time through your browser settings.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 911jili platform. For detailed instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

7. Data Retention

911jili retains your personal data for as long as is necessary to fulfill 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 Data: Retained for the duration of your active membership and for a period of at least five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Communications: Retained for a period of two (2) years from the date of the last communication, unless the communication relates to an ongoing dispute or legal matter.
• Marketing Consent Records: Retained for the duration of your consent and for a period of three (3) years following withdrawal of consent, as evidence of the consent given.

When personal data is no longer required for any of the above purposes, it will be securely deleted or anonymized in accordance with our data disposal procedures.

8. Data Security

911jili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS): All data transmitted between your device and the 911jili platform is encrypted using TLS 1.2 or higher, preventing interception during transmission.
• AES-256 Encryption at Rest: Sensitive personal data stored on 911jili's servers is encrypted using AES-256 encryption, one of the strongest encryption standards available.
• Access Controls: Access to personal data is restricted to authorized 911jili personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data protection training.
• Multi-Factor Authentication: Administrative access to systems containing personal data requires multi-factor authentication.
• Regular Security Audits: 911jili conducts regular security assessments, penetration testing, and vulnerability scans to identify and address potential security weaknesses.
• Incident Response: 911jili maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 911jili:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data that 911jili holds 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 that 911jili holds about you. You may update certain account information directly through your account settings.
• 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. You may also object to processing based on legitimate interests, subject to our ability to demonstrate compelling legitimate grounds.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• 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 that your data rights have been violated.

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 requests within the timeframes required by applicable law — generally within 15 business days of receipt of a complete request.

10. Children's Privacy

The 911jili platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. 911jili does not knowingly collect personal data from individuals under the age of 21.

If you are under 21 years of age, you are not permitted to register for or use the 911jili platform. If 911jili becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the 911jili platform, please contact our support team immediately so that we can investigate and take appropriate action.

11. Third-Party Links

The 911jili platform may contain links to third-party websites or services, including payment provider portals and game provider interfaces. This Privacy Policy applies only to the 911jili platform and does not cover the privacy practices of any third-party websites or services.

911jili is not responsible for the privacy practices, content, or security of any third-party websites. We encourage you to review the privacy policies of any third-party services you access in connection with your use of the 911jili platform.

12. Changes to This Privacy Policy

911jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When material changes are made, we will notify registered members via email or through a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the 911jili platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 911jili, please contact our Data Protection Officer (DPO):

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe that your data rights have been violated and your concern has not been adequately addressed by 911jili.