291jili Privacy Policy

1. Introduction

291jili ("we," "us," or "our") is committed to protecting the personal data of all players and visitors who interact with the 291jili platform. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations as enforced by the National Privacy Commission (NPC).

This Privacy Policy applies to all personal data collected through the 291jili website, mobile platform, customer support channels, and any other service operated under the 291jili brand. By registering an account or using any part of the 291jili platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

If you do not agree with any part of this Privacy Policy, you should discontinue use of the 291jili platform and may request account closure by contacting our support team. This Privacy Policy should be read alongside the 291jili Terms & Conditions, which govern the overall use of the platform.

2. Personal Data We Collect

291jili collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include:

We do not collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. We do not collect biometric data, political opinions, religious beliefs, or health information unless specifically required by law.

3. How We Collect Your Data

291jili collects personal data through the following channels:

• Direct Registration: When you create a 291jili account, you provide identity and contact information directly through the registration form.
• KYC Verification: When you submit identity documents for account verification, we collect and process the information contained in those documents.
• Deposits and Withdrawals: Financial data is collected when you initiate transactions through GCash, PayMaya, bank transfer, or debit card.
• Platform Usage: Technical and usage data is collected automatically as you navigate and interact with the 291jili platform, including game play activity and session information.
• Customer Support: When you contact 291jili support via live chat or email, we collect the content of your communications and any information you provide.
• Cookies and Tracking Technologies: We use cookies and similar technologies to collect technical data about your device and browsing behavior on the 291jili platform. See Section 7 for full details.

4. How We Use Your Personal Data

291jili uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 291jili player account, including processing your registration and verifying your identity.
• Age Verification: To confirm that you are at least 21 years of age, as required under Philippine law for casino-style gambling platforms.
• Transaction Processing: To process deposits, withdrawals, and bonus credits accurately and securely.
• Regulatory Compliance: To comply with PAGCOR requirements, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine laws and regulations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible Gaming: To monitor gaming activity and enforce responsible gaming tools such as deposit limits, session reminders, and self-exclusion requests.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the 291jili platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided consent or where permitted by applicable law. You may opt out at any time.

291jili will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), 291jili processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 291jili — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA obligations, and NPC requirements.
• Legitimate Interests: Processing is necessary for 291jili's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your data protection 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 & Third Parties

291jili 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, and Philippine banking partners require certain financial and identity data to process your transactions securely.
• Identity Verification Providers: Third-party KYC service providers assist in verifying government-issued IDs and confirming your identity and age.
• IT and Platform Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or court order.
• Game Content Providers: Licensed game studios may receive anonymized or aggregated usage data for game performance analysis. No personally identifiable information is shared with game providers.

All third-party service providers engaged by 291jili are contractually required to process personal data only for the specified purpose, maintain appropriate security measures, and comply with the Data Privacy Act of 2012.

7. Cookies & Tracking Technologies

291jili uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and analyze platform performance. The types of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings and display options to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players use the 291jili platform, helping us identify areas for improvement. These are only set with your consent.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your explicit consent and can be withdrawn at any time.

8. Data Retention

291jili retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our standard retention periods are as follows:

• Account Data: Retained for the duration of your active account plus five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act.
• KYC Documents: Retained for five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 291jili's data disposal procedures.

9. Data Security

291jili implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 291jili platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Multi-factor authentication options for player account access.
• Regular security audits, penetration testing, and vulnerability assessments.
• Strict access controls ensuring that only authorized 291jili personnel can access personal data, on a need-to-know basis.
• Staff training on data protection obligations and security best practices.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

10. Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 291jili:

• Right to Access: You may request a copy of the personal data 291jili holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may 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 may object to the processing of your personal data for direct marketing purposes at any time, with immediate effect.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the 291jili Data Privacy Officer using the contact details in Section 13. We will respond to all verified data subject requests within seventy-two (72) hours.

11. Children's Privacy

If you are a parent or guardian and believe that a minor has registered on the 291jili platform or provided personal data without your consent, please contact us immediately at the details provided in Section 13. We take underage access extremely seriously and will act promptly upon receiving such a report.

12. Changes to This Privacy Policy

291jili reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, we will notify registered players via email or an in-platform notification prior to the changes taking effect.

The updated Privacy Policy will be published on this page with a revised effective date. Your continued use of the 291jili platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed of how 291jili protects your personal data.

13. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 291jili, please contact our designated Data Privacy Officer:

For general support inquiries unrelated to data privacy, please contact [email protected] or use the live chat feature within the 291jili platform.