phljili Privacy Policy

1. Introduction

1.1 phljili ("phljili," "we," "us," "our") is committed to protecting the privacy and personal data of all individuals who interact with the phljili Platform. This Privacy Policy ("Policy") describes how phljili collects, uses, stores, shares, and protects personal information in connection with the operation of the phljili online gaming platform.

1.2 This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

1.3 Please read this Policy carefully. If you do not agree with the practices described herein, you should not use the phljili Platform. For questions about this Policy, please contact our Data Protection Officer using the details in Section 14.

2. Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012, phljili acts as the personal information controller in respect of the personal data it collects from Players and visitors to the phljili Platform.

2.2 phljili has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

3.1 phljili collects personal data in the following categories:

3.1 Registration & Identity Data

• Full legal name;
• Date of birth (for age verification — phljili requires players to be 21 years of age or older);
• Philippine mobile number;
• Email address;
• Username and encrypted password;
• Government-issued ID details (where required for KYC verification).

3.2 Financial & Transaction Data

• Deposit and withdrawal history;
• Payment method details (e.g., GCash account reference, bank account details for BPI, BDO, Metrobank transfers);
• Transaction amounts and timestamps;
• Bonus and promotional activity records.

3.3 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration and login timestamps;
• Game activity logs and betting history;
• Cookie identifiers and similar tracking data (see Section 9).

3.4 Communications Data

• Records of communications with phljili customer support (live chat transcripts, email correspondence);
• Feedback, complaints, and dispute records.

3.5 phljili does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance, such as government ID details for KYC purposes.

4. How We Use Your Personal Data

4.1 phljili uses the personal data it collects for the following purposes:

• Account Management: To create, maintain, and administer your phljili player account, including processing registrations, verifying your identity, and managing account settings;
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods;
• Regulatory Compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations, and other applicable Philippine laws and regulations;
• Age Verification: To verify that all Players are at least 21 years of age, as required by PAGCOR regulations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the phljili Platform;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To monitor gameplay patterns and implement responsible gaming tools, including deposit limits, session reminders, and self-exclusion, where applicable;
• Platform Improvement: To analyze aggregated, anonymized usage data to improve the phljili Platform, fix technical issues, and develop new features;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.

5. Legal Basis for Processing

5.1 phljili processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and phljili (i.e., to operate your player account and provide gaming services);
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations and AML obligations;
• Legitimate Interests: Processing is necessary for phljili's legitimate interests in fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

6.1 phljili does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

6.2 phljili may share your personal data with the following categories of recipients:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely for the purpose of processing your transactions;
• Identity Verification Providers: Third-party KYC and AML compliance service providers who assist phljili in verifying player identities and monitoring for suspicious activity;
• Technology Service Providers: Cloud hosting, data storage, and platform infrastructure providers who process data on phljili's behalf under strict data processing agreements;
• Game Providers: Licensed game studios and content providers whose games are available on the phljili Platform, to the extent necessary to deliver game services;
• Regulatory & Law Enforcement Authorities: PAGCOR, the National Privacy Commission, and other Philippine government authorities, where disclosure is required by law, court order, or regulatory mandate;
• Professional Advisers: Legal counsel, auditors, and other professional advisers, where necessary for the conduct of phljili's business operations.

6.3 All third-party service providers who receive personal data from phljili are contractually required to process such data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable data protection laws.

7. Data Retention

7.1 phljili retains personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law, whichever is longer.

7.2 The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of your phljili account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AML regulatory requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• Customer support records: Retained for three (3) years from the date of the last interaction;
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period thereafter for compliance documentation purposes.

7.3 Where personal data is no longer required, phljili will securely delete or anonymize it in accordance with its internal data disposal procedures.

8. Data Security

8.1 phljili implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the phljili Platform;
• AES-256 encryption for sensitive data stored at rest;
• Role-based access controls limiting data access to authorized personnel on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication for internal systems handling personal data;
• Staff training on data protection and information security obligations.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phljili will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

8.3 While phljili takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phljili login credentials and for notifying phljili immediately if you suspect unauthorized access to your account.

9. Cookies & Similar Technologies

9.1 phljili uses cookies and similar tracking technologies (such as web beacons and local storage) on the phljili Platform. Cookies are small text files stored on your device that help phljili recognize you, maintain your session, and improve your experience.

9.2 phljili uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and display options, to personalize your phljili experience.
• Analytics Cookies: Collect anonymized data about how Players use the phljili Platform, helping us identify areas for improvement. These are only set with your consent.
• Marketing Cookies: Used to deliver relevant promotional content to phljili Players. These are only set with your explicit consent.

9.3 You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phljili Platform. Instructions for managing cookies are available in your browser's help documentation.

10. Your Data Protection Rights

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

• 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 phljili holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• 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 phljili's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phljili has violated your data protection rights.

10.2 To exercise any of the above rights, please contact phljili's Data Protection Officer using the contact details in Section 14. phljili will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines.

10.3 phljili may need to verify your identity before processing a data rights request to ensure that personal data is not disclosed to unauthorized individuals.

11. Children's Privacy

11.1 If you are a parent or guardian and believe that your child has registered on the phljili Platform or provided personal data to phljili, please contact our support team immediately at [email protected] so that we can take appropriate action.

12. International Data Transfers

12.1 phljili primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines, phljili will ensure that such transfers are conducted in accordance with the requirements of the Data Privacy Act of 2012, including ensuring that the recipient country or organization provides an adequate level of data protection.

12.2 Where required, phljili will implement appropriate safeguards for international data transfers, such as contractual clauses approved by the National Privacy Commission or equivalent data protection agreements.

13. Updates to This Privacy Policy

13.1 phljili may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, phljili will post the updated Policy on the phljili Platform and update the "Last Updated" date at the top of this page.

13.2 Where changes are significant, phljili will provide additional notice to registered Players via email or in-platform notification. Your continued use of the phljili Platform following the posting of an updated Policy constitutes your acceptance of the changes.

13.3 We encourage you to review this Policy periodically to stay informed about how phljili protects your personal data.

14. Contact & Data Protection Officer

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or phljili's data protection practices, please contact our Data Protection Officer:

14.2 If you are not satisfied with phljili's response to your data protection concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC and how to file a complaint is available through official Philippine government channels.