Privacy Policy

1. Introduction

jilbay is committed to protecting the privacy and security of your personal information. As a licensed online gaming operator under the Philippine Amusement and Gaming Corporation (PAGCOR), we are required to collect and process certain personal data to comply with regulatory obligations, prevent fraud, and provide you with a safe and enjoyable gaming experience.

This Privacy Policy is designed to help you understand:

• What personal information we collect and why we collect it
• How we use, store, and protect your personal information
• When and with whom we share your personal information
• Your rights under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173)
• How to contact us if you have questions or concerns about your privacy

We comply with all applicable Philippine data protection laws, including the Data Privacy Act of 2012, its Implementing Rules and Regulations (IRR), and all issuances of the National Privacy Commission (NPC).

2. Personal Data We Collect

jilbay collects several categories of personal information to provide our services, comply with legal obligations, and improve your gaming experience. The types of data we collect include:

2.1 Account Registration Data

When you create a jilbay account, we collect:

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify you are 21 years or older)
• Email address
• Mobile phone number
• Residential address (street, barangay, city, province, postal code)
• Username and password (password is stored in encrypted form)
• Preferred currency (PHP)

2.2 Identity Verification Data (KYC)

To comply with PAGCOR's Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements, we collect:

• Government-issued ID (Philippine passport, SSS ID, driver's license, UMID, Postal ID, or Voter's ID)
• Proof of address (utility bill, bank statement, or government correspondence dated within the last 3 months)
• Selfie photograph holding your ID (for identity verification)
• Source of funds declaration (for high-value transactions)

2.3 Payment & Transaction Data

When you deposit or withdraw funds, we collect:

• Payment method details (GCash number, PayMaya account, bank account number, account name)
• Transaction history (deposits, withdrawals, wagers, winnings)
• Payment processor transaction IDs and timestamps
• IP address and device information at the time of transaction

2.4 Gaming Activity Data

To provide gaming services and detect fraud, we collect:

• Game play history (games played, bets placed, outcomes, timestamps)
• Bonus and promotion participation
• Session duration and frequency
• Responsible gaming settings (deposit limits, self-exclusion status)

2.5 Technical & Device Data

When you access jilbay, we automatically collect:

• IP address and geolocation data (to verify you are in the Philippines)
• Device type, operating system, and browser type
• Screen resolution and device identifiers
• Cookies and similar tracking technologies (see Section 7)
• Referral source (how you found jilbay)

2.6 Communications Data

When you contact customer support or communicate with jilbay, we collect:

• Live chat transcripts
• Email correspondence
• Support ticket history
• Feedback and survey responses

3. How We Use Your Personal Data

jilbay uses your personal information for the following purposes:

• Account Management: To create, maintain, and secure your jilbay account, verify your identity, and process your registration.
• Service Provision: To provide access to games, process bets, calculate winnings, and manage your account balance.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other Philippine payment methods.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, AML/CFT regulations, and other Philippine gaming laws.
• Fraud Prevention: To detect and prevent fraud, money laundering, underage gambling, bonus abuse, and other prohibited activities.
• Responsible Gaming: To implement deposit limits, self-exclusion, reality checks, and other responsible gaming tools.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send promotional offers, bonuses, and updates (only with your consent; you may opt out at any time).
• Platform Improvement: To analyze usage patterns, improve game selection, optimize user experience, and develop new features.
• Legal Obligations: To respond to court orders, legal processes, and requests from Philippine government authorities.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act, jilbay processes your personal data based on the following legal grounds:

• Consent: You have given explicit consent for us to process your personal data for specific purposes (e.g., marketing communications).
• Contract Performance: Processing is necessary to fulfill our contractual obligations to you under the jilbay Terms & Conditions (e.g., providing gaming services, processing payments).
• Legal Obligation: Processing is required to comply with Philippine laws and regulations, including PAGCOR licensing requirements, AML/CFT laws, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and platform improvement, provided these interests do not override your fundamental rights and freedoms.

5. Data Sharing & Disclosure

jilbay does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your data with the following categories of recipients when necessary:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers to process your deposits and withdrawals.
• Game Providers: Third-party game developers and software providers who power jilbay's slot, bingo, fishing, and casino games.
• Identity Verification Services: KYC/AML verification providers to confirm your identity and comply with regulatory requirements.
• Regulatory Authorities: PAGCOR, National Privacy Commission, Anti-Money Laundering Council (AMLC), Bureau of Internal Revenue (BIR), and other Philippine government agencies when required by law.
• Legal & Professional Advisors: Lawyers, accountants, auditors, and consultants who assist jilbay with legal compliance and business operations.
• Cloud Service Providers: Secure data hosting and cloud infrastructure providers located in the Philippines.
• Fraud Prevention Services: Third-party fraud detection and prevention tools to protect jilbay and its users from fraudulent activity.

All third-party service providers are contractually obligated to protect your personal data and use it only for the specific purposes for which it was shared. We conduct due diligence to ensure our partners comply with Philippine data protection standards.

6. Data Security Measures

jilbay implements comprehensive technical, organizational, and physical security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and jilbay servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest (passwords, payment details) is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized jilbay personnel on a need-to-know basis. All employees sign confidentiality agreements.
• Secure Infrastructure: jilbay's servers are hosted in secure, ISO 27001-certified data centers in the Philippines with 24/7 monitoring, redundant power, and fire suppression systems.
• Regular Audits: We conduct regular security audits, penetration testing, and vulnerability assessments to identify and address potential security risks.
• Incident Response: jilbay maintains a data breach response plan to quickly detect, contain, and remediate security incidents. In the event of a data breach affecting your personal information, we will notify you and the National Privacy Commission within 72 hours as required by law.
• Two-Factor Authentication: Optional 2FA is available to add an extra layer of security to your account.

7. Cookies & Tracking Technologies

jilbay uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and personalize content. Cookies are small text files stored on your device that help us remember your preferences and improve site functionality.

Types of cookies we use:

• Essential Cookies: Required for the jilbay platform to function properly (e.g., session management, security, load balancing). These cannot be disabled.
• Performance Cookies: Collect anonymous data about how you use jilbay to help us improve site performance and user experience.
• Functional Cookies: Remember your preferences (e.g., language, currency) to provide a more personalized experience.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising (only with your consent).

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may limit your ability to use some jilbay features.

8. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal data:

• Right to Be Informed: You have the right to know what personal data we collect, how we use it, and with whom we share it (as described in this Policy).
• Right to Access: You may request a copy of all personal data we hold about you. We will provide this information within 30 days of your request.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. You can update most information directly in your jilbay account settings.
• Right to Erasure: You may request deletion of your personal data, subject to legal and regulatory retention requirements (e.g., PAGCOR requires us to retain transaction records for 5 years).
• Right to Object: You may object to processing of your personal data for direct marketing purposes. You can opt out of marketing emails by clicking "unsubscribe" in any promotional email.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe jilbay has violated your data privacy rights, you may file a complaint with the National Privacy Commission at privacy.gov.ph.

To exercise any of these rights, please contact our Data Protection Officer using the contact information in Section 13.

9. Data Retention

jilbay retains your personal data only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and resolve disputes. Specific retention periods include:

• Account Data: Retained for the duration of your active account, plus 24 months after account closure (to handle disputes and comply with regulatory requirements).
• Transaction Records: Retained for 5 years after the transaction date, as required by PAGCOR and Philippine AML regulations.
• KYC Documents: Retained for 5 years after account closure, as required by PAGCOR and AMLC regulations.
• Marketing Consent: Retained until you withdraw consent or for 2 years of inactivity, whichever comes first.
• Support Communications: Retained for 3 years to maintain service quality and resolve disputes.

After the applicable retention period expires, your personal data will be securely deleted or anonymized so that it can no longer be associated with you.

10. Children's Privacy

jilbay is strictly for users aged 21 years and above. We do not knowingly collect personal information from individuals under 21 years of age. If we discover that we have inadvertently collected personal data from a minor, we will immediately delete that information and close the associated account.

If you are a parent or guardian and believe your child has provided personal information to jilbay, please contact our Data Protection Officer immediately so we can take appropriate action.

11. International Data Transfers

jilbay primarily stores and processes your personal data within the Philippines. However, some of our third-party service providers (e.g., game developers, cloud infrastructure providers) may be located outside the Philippines.

When we transfer personal data internationally, we ensure that appropriate safeguards are in place, such as:

• Standard contractual clauses approved by the National Privacy Commission
• Adequacy determinations by the NPC for countries with equivalent data protection standards
• Binding corporate rules for multinational service providers

We will not transfer your personal data to any country that does not provide adequate data protection unless we have obtained your explicit consent or the transfer is necessary to fulfill our contract with you.

12. Changes to This Privacy Policy

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

• Posting a prominent notice on the jilbay homepage
• Sending an email to your registered email address
• Displaying a notification when you log in to your account

The "Last updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of jilbay after any changes constitutes your acceptance of the updated Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

13. Contact Our Data Protection Officer

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

• Data Protection Officer: jilbay DPO
• Email: [email protected] (plain text, not clickable)
• Mailing Address: jilbay Data Protection Office, Manila, Philippines
• Response Time: We aim to respond to all privacy inquiries within 15 business days.

For general customer support inquiries unrelated to data privacy, please use our 24/7 live chat or email [email protected].

If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph or by calling their hotline at 1-8888-PRIVCY (1-8888-774829).