Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by 35jili (hereinafter "the Company," "we," "us," or "our") through the website https://35jili.cam (hereinafter "the Platform") and any associated mobile applications or services. By registering an account, providing personal information, or using the Platform in any capacity, you (hereinafter "the Player," "you," or "your") consent to the collection, use, and processing of your personal data as described in this Privacy Policy.

35jili is the data controller responsible for your personal information. We are committed to transparency in our data practices and compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all guidelines issued by the National Privacy Commission (NPC).

If you do not agree with any provision of this Privacy Policy, you must not use the Platform or provide any personal information. Continued use of the Platform constitutes acceptance of this Privacy Policy and any subsequent amendments.

2. Information We Collect

35jili collects various categories of personal information necessary to provide gaming services, verify your identity, process transactions, prevent fraud, and comply with legal obligations under PAGCOR regulations and Philippine anti-money laundering laws.

2.1 Information You Provide Directly

When you register an account or use the Platform, you provide the following information:

• Account Registration Data: Full legal name, date of birth, gender, email address, mobile phone number, residential address, username, and password.
• Identity Verification Data: Government-issued identification documents (e.g., Philippine passport, driver's license, PRC ID, UMID, Voter's ID, PhilSys ID), photographs for facial verification, and proof of address documents (utility bills, bank statements).
• Financial Information: Bank account details, e-wallet account numbers (GCash, Maya), cryptocurrency wallet addresses, deposit and withdrawal transaction records, and payment method preferences.
• Communication Data: Messages sent through customer support channels, including live chat transcripts, email correspondence, and support ticket content.
• Responsible Gaming Data: Self-imposed deposit limits, loss limits, session time limits, cooling-off periods, and self-exclusion requests.

2.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain technical and behavioral information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and unique device fingerprints.
• Connection Data: IP address, geographic location (country, city, region), Internet Service Provider (ISP), time zone, and connection timestamps.
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, click patterns, navigation paths, and feature usage statistics.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to recognize your device, remember preferences, analyze traffic patterns, and improve user experience. You can control cookie settings through your browser, though disabling cookies may affect Platform functionality.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction verification data from GCash, Maya, banks, and cryptocurrency networks.
• Identity Verification Services: Validation results from third-party KYC/AML screening providers that check government databases and watchlists.
• Fraud Prevention Services: Risk assessment data from specialized anti-fraud platforms that detect suspicious patterns or known fraudulent actors.

3. How We Use Your Information

35jili processes your personal information for the following lawful purposes:

3.1 Service Provision and Account Management

• To create, maintain, and manage your player account.
• To process deposits, withdrawals, and other financial transactions.
• To enable gameplay and calculate game outcomes, winnings, and bonuses.
• To provide customer support and respond to your inquiries.
• To communicate account notifications, transaction confirmations, and service updates.

3.2 Legal and Regulatory Compliance

• To verify your identity and age in compliance with PAGCOR's 21+ age restriction requirements.
• To conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as mandated by Philippine law.
• To detect, prevent, and investigate fraud, money laundering, terrorist financing, and other illegal activities.
• To respond to legal requests from law enforcement, courts, PAGCOR, the Anti-Money Laundering Council (AMLC), or other government authorities.
• To maintain transaction records for the periods required by law (typically seven years under AML regulations).

3.3 Security and Fraud Prevention

• To monitor account activity for suspicious behavior, unauthorized access, or Terms of Service violations.
• To detect and prevent multi-accounting, bonus abuse, collusion, and other forms of gaming misconduct.
• To protect the Platform from cyber attacks, hacking attempts, and security vulnerabilities.
• To investigate disputes, chargebacks, and player complaints.

3.4 Responsible Gaming

• To implement and enforce deposit limits, loss limits, and session time limits you have set.
• To process self-exclusion requests and prevent access during exclusion periods.
• To identify patterns of problem gambling behavior and offer responsible gaming resources.

3.5 Marketing and Personalization (With Consent)

• To send promotional offers, bonus notifications, and personalized game recommendations (you may opt out at any time).
• To analyze your preferences and gameplay behavior to improve service quality and tailor content.
• To conduct market research and gather feedback on Platform features.

3.6 Business Operations

• To analyze Platform performance, identify technical issues, and optimize user experience.
• To generate anonymized and aggregated statistics for business intelligence purposes.
• To train customer support staff and improve service quality.

4. Data Sharing and Disclosure

35jili does not sell, rent, or trade your personal information to third parties for their independent marketing purposes. However, we may share your data in the following limited circumstances:

4.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including payment processing, identity verification, fraud detection, cloud hosting, customer support software, and email delivery. These providers are contractually obligated to protect your data, use it only for the specified purposes, and comply with applicable data protection laws.

4.2 Legal and Regulatory Authorities

We may disclose your personal information to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council, law enforcement agencies, courts, or other government bodies when:

• Required by Philippine law, regulation, or court order.
• Necessary to comply with PAGCOR licensing conditions or regulatory audits.
• Requested in connection with investigations into fraud, money laundering, terrorist financing, or other criminal activity.
• Needed to enforce our Terms and Conditions or protect the rights, property, or safety of 35jili, our players, or the public.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor, subject to continued compliance with this Privacy Policy and applicable data protection laws.

4.4 With Your Consent

We may share your information with third parties for purposes not described in this Privacy Policy if we obtain your explicit consent.

5. Data Security Measures

35jili employs industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest (stored data) is encrypted using AES-256 encryption.
• Access Controls: Access to personal information is restricted to authorized personnel on a need-to-know basis. All employees and contractors sign confidentiality agreements and undergo background checks.
• Multi-Factor Authentication: Administrative access to our systems requires multi-factor authentication to prevent unauthorized login.
• Firewall Protection: Our servers are protected by enterprise-grade firewalls and intrusion detection/prevention systems.
• Regular Security Audits: We conduct regular security assessments, vulnerability scans, and penetration testing to identify and address potential weaknesses.
• Secure Data Centers: Our servers are hosted in Tier III or higher data centers within the Philippines with 24/7 physical security, surveillance, and environmental controls.
• Incident Response: We maintain an incident response plan to quickly detect, contain, and remediate security breaches, and to notify affected individuals as required by law.

Despite our best efforts, no method of data transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account. If you suspect unauthorized access, notify us immediately.

6. Data Retention

35jili retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

• Active Accounts: We retain all personal information for the duration of your active account.
• Closed Accounts: After account closure, we retain transaction records, identity verification documents, and certain other data for seven (7) years to comply with Philippine AML record-keeping requirements and PAGCOR regulations.
• Marketing Data: If you opt out of marketing communications, we retain only enough information to honor your opt-out preference.
• Dispute Records: Information related to disputes, complaints, or legal claims is retained until the matter is fully resolved and any applicable statute of limitations has expired.

After the retention period expires, personal information is securely deleted or anonymized in a manner that prevents reconstruction.

7. Your Privacy Rights Under Philippine Law

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

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal information.
• Right to Erasure: You may request deletion of your personal information, subject to legal retention requirements and legitimate business needs.
• Right to Object: You may object to processing of your personal information for direct marketing purposes or other legitimate interests.
• Right to Data Portability: You may request transfer of your personal information to another service provider in a structured, commonly used format, where techn ically feasible.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to File a Complaint: You may file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 10 below. We will respond to your request within fifteen (15) business days as required by the NPC's guidelines. Verification of your identity may be required before we process your request.

8. Cookies and Tracking Technologies

35jili uses cookies, web beacons, local storage, and similar tracking technologies to enhance your experience, analyze Platform usage, and deliver personalized content.

8.1 Types of Cookies We Use

• Essential Cookies: Required for basic Platform functionality, including login authentication, session management, and security features. These cannot be disabled without impairing core services.
• Performance Cookies: Collect anonymous data on how visitors use the Platform, including page views, error messages, and load times. This helps us identify and fix technical issues.
• Functionality Cookies: Remember your preferences (language, game filters, display settings) to provide a more personalized experience.
• Marketing Cookies: Track your activity across the Platform to deliver relevant promotional offers and measure campaign effectiveness. These cookies require your consent.

8.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when a cookie is being sent. Please note that disabling cookies may limit your ability to use certain features of the Platform. You can also clear stored cookies through your browser settings at any time.

9. International Data Transfers

35jili stores and processes your personal information primarily on servers located within the Republic of the Philippines. However, some of our third-party service providers (such as cloud infrastructure providers, payment processors, and fraud detection services) may process data in jurisdictions outside the Philippines.

When we transfer personal information to countries that do not provide an adequate level of data protection as determined by the National Privacy Commission, we implement appropriate safeguards such as Standard Contractual Clauses, Binding Corporate Rules, or other legally recognized transfer mechanisms to ensure your data remains protected.

By using the Platform, you consent to the transfer of your personal information to these third-party service providers, subject to the protections described in this Privacy Policy.

10. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, or if you wish to exercise your data protection rights, please contact our Data Protection Officer:

Data Protection Officer
35jili
Email: [email protected]
Subject Line: "Data Privacy Request"

For general customer support inquiries, you may also use our 24/7 live chat feature available on the Platform or send an email to the same address.

We aim to respond to all privacy-related inquiries within fifteen (15) business days. If you are not satisfied with our response, you have the right to file a complaint with the National Privacy Commission of the Philippines.

11. Changes to This Privacy Policy

35jili reserves the right to update, modify, or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. The "Last Updated" date at the top of this document indicates when the most recent changes were made.

Material changes to this Privacy Policy will be communicated to you via email to the address associated with your account or through a prominent notice on the Platform. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

Your continued use of the Platform after any amendments to this Privacy Policy constitutes acceptance of those changes. If you do not agree with the updated Privacy Policy, you must cease using the Platform and may request account closure.