31jili Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes the practices of 31jili ("we", "us", "our", "the Platform") with respect to the personal data of users ("you", "your", "the Data Subject") who access https://31jili.cam and any associated mobile-optimized web interfaces operated by 31jili.

By registering an account with 31jili, accessing the Platform, or otherwise providing your personal information to us, you acknowledge that you have read and understood this Policy and consent to the collection, processing, storage, and use of your personal data as described herein. This Policy is incorporated by reference into our Terms & Conditions and should be read in conjunction with those terms.

We are committed to handling your personal information with the highest standards of confidentiality, integrity, and transparency. If you have any questions about this Policy or how your data is handled, please refer to Section 14 for our contact information.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), 31jili acts as the Personal Information Controller (PIC) with respect to the personal data of its registered users and Platform visitors. As a PIC, 31jili determines the purposes and means of processing your personal data and bears primary accountability for ensuring that processing is conducted lawfully, fairly, and transparently.

31jili operates the online casino platform accessible at https://31jili.cam and is regulated under the online gaming framework administered by the Philippine Amusement and Gaming Corporation (PAGCOR). Our designated Data Protection Officer (DPO) can be contacted via the email address listed in Section 14 of this Policy.

3. Personal Data We Collect

31jili collects personal data from you through several means: directly when you register and use the Platform, automatically as you interact with our services, and in some cases from third parties such as payment processors and identity verification providers. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name (first name, middle name, last name)
• Date of birth (for age verification — 21+ requirement under PAGCOR regulations)
• Philippine mobile number (e.g., Globe, Smart, DITO numbers)
• Email address
• Username and encrypted password
• Residential address in the Philippines

3.2 Identity Verification (KYC) Data

• Government-issued photo ID (Philippine National ID, passport, driver's license, PhilSys card, SSS/GSIS card, or equivalent)
• Selfie photograph taken while holding the ID document
• Proof of address (utility bills, bank statements, or equivalent)
• Source of funds documentation for large transactions, where required by AML regulations

3.3 Financial & Transaction Data

• GCash account details (mobile number linked to GCash)
• Maya / PayMaya account details
• Bank account information (BPI, BDO, UnionBank, or other linked bank accounts)
• Cryptocurrency wallet addresses (for USDT TRC20 transactions)
• Deposit amounts, withdrawal amounts, and transaction timestamps
• Betting history, game participation records, and wagering totals

3.4 Technical & Usage Data

• IP address and geolocation data (country and region)
• Device type, operating system, browser type and version
• Session timestamps and duration
• Pages visited, game sessions started, and clickstream data
• Login attempts and security event logs
• Device identifiers and mobile network operator (Globe, Smart, DITO)

3.5 Communications Data

• Records of communications with 31jili support staff (live chat transcripts, email exchanges)
• Feedback and survey responses
• Complaints and dispute records

3.6 Data Collected From Third Parties

We may receive personal data about you from third-party identity verification providers, payment processors (GCash, Maya, BPI, BDO), fraud detection services, and publicly available sources where relevant to our legal compliance obligations. Such data is processed under the same standards described in this Policy.

4. Purpose of Processing & Legal Basis

The table below summarizes the primary purposes for which 31jili processes your personal data and the corresponding legal bases under RA 10173:

5. Data Retention

31jili retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law, PAGCOR regulations, and anti-money-laundering (AML) obligations. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR AML requirements and the Anti-Money Laundering Act (RA 9160, as amended).
• Transaction records: Retained for a minimum of five (5) years from the transaction date.
• Support and communications records: Retained for three (3) years from the date of the last communication.
• Technical and usage logs: Retained for twelve (12) months from the date of collection, unless retention is required for ongoing security investigations.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter for compliance documentation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our internal data destruction procedures.

6. Data Sharing & Disclosure

31jili does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly for the purposes described in Section 4:

6.1 Payment Service Providers

We share necessary financial data with GCash, Maya, BPI, BDO, UnionBank, and other payment processors to facilitate deposits and withdrawals. These providers are independently regulated financial institutions subject to Bangko Sentral ng Pilipinas (BSP) oversight and their own privacy obligations.

6.2 Identity Verification Providers

We engage licensed third-party KYC service providers to verify government-issued IDs and conduct liveness checks. These providers process your identity data solely for verification purposes and are contractually bound to handle your data in accordance with RA 10173.

6.3 Game Software Providers

Our game providers (including Jili Games and other licensed studios) may receive anonymized or pseudonymized session data necessary for game operation, RNG certification, and technical support. These providers do not receive your full identity or financial data.

6.4 Regulatory Authorities

We are legally obligated to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies upon lawful request or as required by our operating license conditions. We will notify you of any such disclosure unless prohibited by law from doing so.

6.5 Legal & Professional Advisors

We may share data with our legal counsel, auditors, and other professional advisors under strict confidentiality obligations where necessary to protect our legal rights or comply with applicable law.

7. Cross-Border Data Transfers

Some of our service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a country that does not provide an adequate level of data protection equivalent to Philippine standards, 31jili ensures that appropriate safeguards are in place — including contractual data protection clauses — to protect the security and confidentiality of your personal data in transit and at the recipient's location.

By using the 31jili Platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the operation of our services, subject to the safeguards described in this Section.

8. Security Measures

31jili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 31jili Platform — the same standard used by Philippine banks for online banking.
• Data encryption at rest for sensitive personal data, KYC documents, and financial records stored on our servers.
• Two-factor authentication (2FA) via SMS OTP for all account logins, withdrawals, and sensitive account changes.
• Role-based access controls ensuring that only authorized 31jili personnel with a legitimate need can access specific categories of personal data.
• Regular security audits and penetration testing conducted by qualified cybersecurity professionals.
• IP monitoring and anomaly detection to identify and block suspicious login attempts in real time.
• Incident response procedures — in the event of a personal data breach, 31jili will notify affected users and the National Privacy Commission (NPC) within 72 hours of discovery, as required by RA 10173.

While we take all reasonable steps to secure your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. Please notify us immediately at the email address in Section 14 if you suspect unauthorized access to your account.

9. Cookies & Tracking Technologies

31jili uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session state, analyze usage patterns, and detect fraudulent activity. The categories of cookies we use are:

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that support fraud detection. These cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your preferences (such as language settings and last-used game) to personalize your experience.
• Analytics Cookies: Help us understand how players interact with the Platform — which pages are visited most, where users encounter errors, and how game sessions progress. Data collected is aggregated and does not identify individual users.
• Security & Fraud Detection Cookies: Used to detect multiple account registrations from the same device, monitor for bot activity, and flag suspicious login patterns.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may limit the functionality of the 31jili Platform, including your ability to remain logged in across sessions.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 31jili. To exercise any of these rights, contact our Data Protection Officer at the details provided in Section 14:

We will respond to all verified data subject rights requests within fifteen (15) working days of receipt. In cases requiring further investigation, we may extend this period by an additional fifteen (15) working days and will notify you of the extension.

If you are dissatisfied with our response or believe that your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Minors & Age Policy

The 31jili Platform is strictly prohibited to individuals below the age of 21 years, in accordance with PAGCOR regulations governing online gaming in the Philippines. We do not knowingly collect personal data from persons under 21 years of age. Age verification is a mandatory step during account registration and prior to any withdrawal being processed.

If 31jili discovers or is notified that personal data has been collected from an individual under the age of 21, we will immediately suspend the associated account, initiate a full refund of any deposits made, and delete all personal data associated with the underage user from our systems as promptly as permissible under our legal retention obligations.

Parents or guardians who believe that their child has registered on the Platform without authorization should contact us immediately at the email address in Section 14 to initiate account closure and data deletion.

12. Third-Party Services & Links

The 31jili Platform may reference third-party services such as payment providers (GCash, Maya, BPI, BDO). These third-party services operate under their own privacy policies and terms, which are independent of this Policy. 31jili is not responsible for the privacy practices or content of any third-party service. We encourage you to review the privacy policies of any third-party service you use in connection with your 31jili account.

13. Changes to This Privacy Policy

31jili reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will post a prominent notice on the Platform and update the "Last Updated" date at the top of this page. For significant changes affecting your rights or the way we use your personal data, we will also notify you via the email address registered to your account.

Your continued use of the 31jili Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should discontinue use of the Platform and contact us to arrange account closure.

14. Contact & Data Privacy Complaints

For all data privacy inquiries, rights requests, or complaints, please contact 31jili's Data Protection Officer through the following channels:

• Email: [email protected] — subject line: "Data Privacy Request"
• Live Chat: Available 24/7 on the 31jili Platform after logging in — ask to be connected to the Data Privacy team.
• Response Time: Within 15 working days of receipt for standard requests.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent regulatory authority responsible for enforcing RA 10173.