Privacy Policy — 639 Jili Casino

Introduction and Scope

This Privacy Policy ("Policy") is issued by 639 Jili Casino ("639 Jili," "we," "us," "our"), the operator of the online gaming platform accessible at 639jili.one and its associated interfaces, and describes how we collect, use, store, protect, share, and dispose of personal data in connection with your use of our platform and services.

This Policy applies to all personal data processed by 639 Jili in connection with: (a) registered player accounts; (b) visitors to the 639 Jili website who have not yet registered; (c) persons who contact 639 Jili via customer support or other communication channels; and (d) individuals whose personal data 639 Jili receives from third parties such as payment processors and identity verification providers in connection with our services.

This Policy should be read alongside the 639 Jili Terms and Conditions, which govern your use of the platform generally. By creating a 639 Jili account or continuing to use the platform, you acknowledge that you have read this Policy and consent to the data practices described herein, to the extent consent is the applicable legal basis for the processing concerned.

Data Controller Identity

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, the personal information controller responsible for your data is 639 Jili Casino, the operator of the 639jili.one platform.

639 Jili has designated a Data Protection Officer (DPO) as required under the Data Privacy Act and NPC regulations. The DPO is responsible for overseeing 639 Jili's data protection compliance programme, advising on privacy impact assessments, and serving as the primary point of contact for data subject inquiries and NPC communications.

Personal Data We Collect

639 Jili collects the following categories of personal data in connection with the operation of the platform and the provision of gaming services to Filipino players:

Sensitive Personal Information: 639 Jili may process sensitive personal information within the meaning of the Data Privacy Act — including government ID numbers and financial account details — strictly for the purposes of identity verification (KYC) and payment processing. Such data is handled with the heightened care required under the Act and its IRR.

How We Collect Personal Data

639 Jili collects personal data through the following means:

Purposes of Data Processing

639 Jili processes personal data for the following specific, legitimate, and declared purposes:

• Account Creation and Management: Registering and maintaining your 639 Jili player account, including authentication, password management, and account security notifications.
• Identity Verification (KYC): Verifying your identity and age (21+) in compliance with PAGCOR-aligned requirements and anti-money laundering obligations under Philippine law.
• Payment Processing: Processing deposits and withdrawals via GCash, Maya, BPI, BDO, UnionBank, and other accepted payment methods, including currency reconciliation and transaction record-keeping.
• Game Provision and Dispute Resolution: Operating games, maintaining game round records, and resolving any disputes relating to game outcomes or wager amounts.
• Regulatory Compliance and AML: Complying with the Anti-Money Laundering Act (R.A. 9160, as amended), PAGCOR regulatory requirements, tax reporting obligations, and any other applicable Philippine law.
• Fraud Prevention and Platform Security: Detecting and preventing fraudulent activity, multi-accounting, bonus abuse, and unauthorized access to the platform.
• Responsible Gaming: Administering responsible gaming tools including deposit limits, self-exclusion, session timers, and cooling-off periods; monitoring for indicators of problem gambling behavior.
• Customer Support: Responding to inquiries, resolving complaints, and providing technical assistance via live chat, email, and SMS.
• Marketing and Promotions: Sending promotional communications about 639 Jili offers, bonuses, and new games — only where you have provided consent or where permitted by applicable law. You may withdraw consent at any time via account settings or by contacting support.
• Platform Improvement: Analyzing usage patterns and player behavior in aggregate to improve the platform, optimize game selection, and enhance the Filipino player experience.

Legal Basis for Processing

Under the Data Privacy Act of 2012 and its IRR, 639 Jili processes personal data on the following legal bases, depending on the processing activity concerned:

Sharing and Disclosure of Personal Data

639 Jili does not sell, rent, or trade your personal data to third parties for their independent commercial use. We share personal data only in the following circumstances and only to the extent necessary for each purpose:

• Payment Processors and Financial Institutions: GCash (GXI), Maya (Paymaya Philippines, Inc.), BPI, BDO, UnionBank, Metrobank, Coins.ph, and cryptocurrency transaction processors, to the extent necessary to execute your deposit and withdrawal instructions.
• Identity Verification and KYC Providers: Third-party identity verification service providers engaged to assist with KYC compliance. These providers process your ID documents under contract and are prohibited from using your data for any other purpose.
• Game Providers: JILI Games, PG Soft, Pragmatic Play, Spadegaming, and other certified game studios may receive game round data, wager records, and session identifiers for the purposes of game operation, dispute resolution, and game integrity monitoring.
• Regulatory Authorities and Law Enforcement: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), Philippine courts, and law enforcement agencies, where disclosure is required by applicable law, court order, or lawful regulatory requirement.
• Fraud Prevention and Security Providers: Anti-fraud and cybersecurity service providers engaged to protect the 639 Jili platform and player accounts from fraudulent activity and unauthorized access.
• Professional Advisers: Legal counsel, auditors, and other professional advisers, where necessary for the conduct of their professional services on behalf of 639 Jili, subject to confidentiality obligations.

All third-party service providers with whom 639 Jili shares personal data are required by contract to maintain appropriate technical and organizational data security measures, to process personal data only on 639 Jili's documented instructions, and to comply with applicable Philippine data protection law.

Data Retention Periods

639 Jili retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification. Anonymized data that can no longer be used to identify any individual may be retained indefinitely for aggregate analytics purposes.

Security Measures

639 Jili implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, destruction, alteration, or unauthorized disclosure. These measures are regularly reviewed and updated in response to the evolving threat landscape and applicable security standards.

• Encryption in Transit: All data transmitted between player devices and the 639 Jili platform is encrypted using TLS 1.2 or higher with 256-bit AES encryption.
• Encryption at Rest: Personal data stored in 639 Jili's databases is encrypted at rest using industry-standard encryption protocols.
• Access Controls: Access to personal data within 639 Jili's systems is restricted to authorized personnel on a need-to-know basis. Role-based access controls and multi-factor authentication are required for all administrative system access.
• Two-Factor Authentication: Player accounts support SMS OTP-based two-factor authentication, which 639 Jili strongly encourages all Filipino players to enable, particularly given the value of GCash-linked accounts.
• Fraud Monitoring: Automated fraud detection systems monitor account activity in real time for indicators of unauthorized access, suspicious transaction patterns, and identity fraud.
• Security Testing: 639 Jili's platform undergoes periodic security assessments including vulnerability scanning and penetration testing conducted by qualified security professionals.
• Staff Training: Personnel with access to personal data receive regular training on data protection obligations and secure data handling practices.

Cookies and Tracking Technologies

The 639 Jili platform uses cookies and similar tracking technologies (collectively, "Cookies") to operate essential platform functions, remember your preferences, analyze platform usage, and, where you have consented, support marketing and retargeting activities.

Types of Cookies used by 639 Jili:

• Strictly Necessary Cookies: Essential for the operation of the 639 Jili platform — including maintaining your authenticated session, remembering your language and display preferences, and enabling core security features. These cookies cannot be disabled without breaking essential platform functionality.
• Performance and Analytics Cookies: Collect aggregated, anonymized information about how players navigate the 639 Jili platform — which games are most popular, which pages are visited most frequently, and where players encounter difficulties. This data helps us improve the platform experience for Filipino players.
• Functional Cookies: Remember your preferences and settings (e.g., game display preferences, notification settings) to provide a more personalized experience on return visits.
• Marketing and Targeting Cookies: Used only where you have provided consent, these cookies enable 639 Jili to deliver relevant promotional content. You may withdraw consent for marketing cookies at any time via your browser settings or account preferences.

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the 639 Jili platform. On mobile browsers (Chrome for Android, Safari for iOS — the most commonly used browsers among Filipino players), cookie management is available through the browser's privacy settings menu.

Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 639 Jili. To exercise any of these rights, contact 639 Jili's Data Protection Officer at the contact details provided in Section 15.

Minors and Age Policy

The 639 Jili platform is strictly intended for persons who are 21 years of age or older, in accordance with the minimum age requirement for casino-style gaming in the Philippines as established by PAGCOR regulations and applicable Philippine law.

639 Jili does not knowingly collect personal data from persons under 21 years of age. Age verification is performed at registration through OTP-based mobile number verification and, for higher-value withdrawal requests, through KYC identity document verification confirming the account holder's date of birth.

If 639 Jili becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to: (a) close the associated account; (b) void any transactions conducted by the minor; (c) delete or anonymize the personal data collected; and (d) return any net deposits to the payment method used, subject to our anti-fraud and AML compliance obligations.

If you believe that a person under 21 years of age has created a 639 Jili account, please notify us immediately via [email protected] with the subject line "Minor Account Report."

Cross-Border Data Transfers

Some of 639 Jili's service providers — including game providers (JILI, PG Soft, Pragmatic Play) and certain technical infrastructure providers — may process personal data in jurisdictions outside the Philippines. Where such cross-border data transfers occur, 639 Jili implements appropriate safeguards to ensure that your personal data receives an equivalent level of protection as required under the Data Privacy Act of 2012.

Safeguards for cross-border data transfers include: contractual data processing agreements that impose DPA-equivalent obligations on overseas processors; transfers only to jurisdictions with adequate data protection standards as recognized by the NPC; and restriction of transferred data to the minimum necessary for the processing purpose.

Changes to This Privacy Policy

639 Jili may update this Privacy Policy from time to time to reflect changes in our data processing practices, the services we offer, or applicable Philippine law and NPC guidance. All changes will be reflected in the "Last Updated" date at the top of this Policy.

Material changes to this Policy — meaning changes that significantly affect how we collect, use, or share personal data — will be communicated to registered 639 Jili players via SMS notification to the registered Philippine mobile number and/or prominent in-platform notification at least seven (7) days before the changes take effect.

Your continued use of the 639 Jili platform following any update to this Policy constitutes your acknowledgment of the changes and, where consent is the applicable legal basis, your consent to the updated practices. If you do not agree with any material change, you may close your account before the effective date of the change by contacting 639 Jili support.

Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or 639 Jili's data processing practices, or to exercise your data subject rights under the Data Privacy Act of 2012, please contact 639 Jili's Data Protection Officer using the details below:

Where you are not satisfied with 639 Jili's response to a data privacy inquiry or rights request, you have the right to escalate your complaint to the National Privacy Commission of the Philippines — the independent government body responsible for enforcing the Data Privacy Act of 2012. NPC contact details and complaint procedures are publicly available on the NPC's official government website.