Privacy Policy

1 Introduction

phjil operates the online gaming platform at phjil.app, offering slot games, live dealer casino games, bingo, and related gaming entertainment services to adult players in the Philippines (collectively, "the Services"). In the course of providing these Services, phjil collects and processes personal data relating to registered and prospective players, website visitors, and customer support contacts.

phjil recognizes that privacy is a fundamental right and is committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection legislation, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, and the regulations of the National Privacy Commission (NPC) of the Philippines.

This Policy describes the types of personal data we collect, the purposes for which we process it, the legal bases for processing, how long we retain it, who we share it with, how we secure it, and the rights available to you as a data subject under Philippine law. This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy.

2 Data Controller

For the purposes of applicable data protection law, phjil is the personal information controller in respect of the personal data collected and processed through the phjil platform. This means phjil determines the purposes and means by which your personal data is processed.

If you have any questions about how phjil handles your personal data, or if you wish to exercise any of your rights as a data subject, please contact our Data Privacy Officer through the contact details set out in Section 17 of this Policy.

3 Personal Data We Collect

phjil collects and processes the following categories of personal data:

3.1 Identity and Contact Information

• Full legal name as it appears on government-issued identification;
• Date of birth (for age verification purposes);
• Residential address;
• Philippine mobile number;
• Email address;
• Government-issued identification number (e.g., PhilSys ID number, UMID number, Passport number, Driver's License number).

3.2 Account and Transaction Data

• phjil account username and account ID;
• Account creation date and modification history;
• Deposit and withdrawal transaction records, including amounts, dates, timestamps, and payment methods used (GCash, Maya, BPI, BDO, Metrobank, InstaPay, PesoNet, GrabPay, QR Ph, 7-Eleven CLiQQ, USDT TRC20, Coins.ph);
• Wallet balance records and transaction history;
• Bonus and promotion eligibility records, including wagering history.

3.3 Gaming Activity Data

• Game session records, including games played, bet amounts, game outcomes, and session timestamps;
• Win and loss records;
• Responsible gaming tool settings (deposit limits, loss limits, session time limits, self-exclusion status);
• Gaming pattern data used for responsible gaming monitoring.

3.4 KYC and Verification Documents

• Copies or images of government-issued identification documents submitted for KYC verification;
• Selfie photographs submitted for identity verification purposes;
• Source of funds documentation, where required for AML compliance.

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser version;
• Login timestamps and session duration records;
• Cookie identifiers and analytics data (see Section 11).

3.6 Communications Data

• Records of your communications with phjil customer support via live chat, email, or other channels;
• Feedback, complaints, and dispute records;
• Marketing communication preferences.

4 How We Collect Your Data

phjil collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the phjil platform, including IP address, device data, browser information, and session activity, collected via server logs, cookies, and similar technologies;
• Third-party verification services: Identity and address verification data returned from third-party KYC service providers engaged by phjil to assist with identity confirmation;
• Payment processors: Transaction confirmation and status data provided by GCash, Maya, BPI, BDO, Metrobank, and other payment processors in connection with your deposit and withdrawal transactions;
• Game providers: Game session and outcome data returned from the certified third-party game studios whose titles are integrated into the phjil platform.

5 Purposes of Processing

phjil processes your personal data for the following purposes:

6 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules, phjil processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you have accepted, including account management, service delivery, and payment processing;
• Legal obligation: Processing required to comply with applicable law, including KYC/AML obligations, regulatory reporting, and age verification requirements under PAGCOR guidelines;
• Legitimate interests: Processing for fraud prevention, security monitoring, platform analytics, and responsible gaming monitoring, where phjil's legitimate interests do not override your fundamental rights and freedoms;
• Consent: Processing for marketing communications, where you have expressly opted in to receive such communications. You may withdraw this consent at any time (see Section 14).

7 Data Sharing and Disclosure

phjil does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phjil may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

7.1 Service Providers and Processors

phjil engages third-party service providers who process personal data on our behalf, including: KYC and identity verification service providers; payment processing partners (GCash, Maya, BPI, BDO, Metrobank, and other Philippine payment channels); cloud hosting and infrastructure providers; game studio providers for the delivery of gaming content; customer support platform providers; and analytics service providers. All third-party processors are required to handle data in accordance with phjil's instructions and applicable data protection law.

7.2 Regulatory and Legal Authorities

phjil may disclose personal data to government authorities, law enforcement agencies, regulatory bodies, or courts when required to do so by applicable law, court order, or lawful regulatory request. This includes disclosures required under Philippine AML regulations and PAGCOR reporting obligations.

7.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of phjil's business, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy or a policy offering at least equivalent protection.

8 International Data Transfers

Some of phjil's third-party service providers, including cloud infrastructure providers and certain game studio partners, may be located outside the Philippines. Where personal data is transferred to countries that may not have data protection standards equivalent to those applicable in the Philippines, phjil will implement appropriate safeguards to protect your data, including contractual clauses that require the recipient to maintain standards of protection consistent with the Philippine Data Privacy Act of 2012.

By using the phjil platform, you consent to the transfer of your personal data to countries outside the Philippines in circumstances where such transfer is necessary for the delivery of the Services described in this Policy.

9 Data Retention

phjil retains your personal data for as long as is necessary for the purposes set out in this Policy, subject to the following principles:

• Active accounts: Personal data is retained for the full duration of your registered account with phjil;
• Closed accounts: Following account closure, phjil retains account records, transaction data, and KYC documentation for a minimum period of five (5) years after the date of closure, in accordance with applicable AML record-keeping requirements and the Philippine Data Privacy Act;
• Self-excluded accounts: Data relating to self-excluded accounts is retained for the duration of the self-exclusion period and for a minimum of five (5) years thereafter, to facilitate enforcement of the exclusion and AML compliance;
• Marketing data: Email addresses and marketing preferences are retained until you withdraw your consent to marketing communications, after which they are removed from active marketing lists, though residual records may be retained for compliance purposes;
• Technical data: Server log data, IP records, and session data are retained for a maximum of twelve (12) months for security and fraud prevention purposes, unless a longer retention period is required by law or for the investigation of a specific security incident.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with phjil's data disposal procedures.

10 Data Security

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

• 256-bit SSL/TLS encryption applied to all data transmitted between your device and the phjil platform;
• Hashed and salted password storage — plaintext passwords are never stored by phjil;
• Two-Factor Authentication (2FA) via SMS OTP, available to all registered players and strongly recommended;
• Login anomaly detection that flags and challenges suspicious login attempts;
• Role-based access controls limiting internal access to personal data to authorized personnel with a legitimate operational need;
• Regular security assessments and penetration testing of platform infrastructure;
• Data encryption at rest for sensitive personal data including KYC documentation and financial records.

In the event of a personal data breach that is likely to result in significant risk to your rights and freedoms, phjil will notify the National Privacy Commission and, where required, affected data subjects in accordance with the breach notification requirements of the Philippine Data Privacy Act and NPC Circular No. 16-03.

11 Cookies and Tracking Technologies

phjil uses cookies and similar technologies on the phjil.app platform to deliver and improve the Services. The following categories of cookies may be set when you access the phjil platform:

• Strictly necessary cookies: Required for the platform to function. These cookies manage your login session, maintain your authentication state, and support essential security functions. These cookies cannot be disabled without preventing use of the platform.
• Functional cookies: Remember your preferences and settings (such as language and display preferences) to improve your experience across sessions.
• Analytics cookies: Collect aggregated, anonymized data about how users interact with the phjil platform, including which pages are visited and how long sessions last. This data is used to improve platform performance and user experience.
• Security cookies: Support login anomaly detection and fraud prevention systems by establishing a baseline of normal behavior for your account.

phjil does not use advertising cookies or allow third-party advertisers to set tracking cookies on the phjil platform. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent you from accessing the platform or certain features.

12 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules, you have the following rights in relation to your personal data held by phjil:

• Right to Access: You have the right to request a copy of the personal data phjil holds about you, including information about how it is being processed;
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. You may update many of your account details directly through your account settings;
• Right to Erasure: You have the right to request deletion of your personal data in certain circumstances, subject to phjil's legal obligations to retain data (see Section 9). Erasure requests cannot override statutory retention requirements, including those under AML law;
• Right to Object: You have the right to object to processing of your personal data for purposes based on legitimate interests, or for direct marketing purposes;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request its transfer to another controller where technically feasible;
• Right to Damages: You have the right to claim damages in the event phjil's processing of your personal data causes you harm, in accordance with the provisions of the Philippine Data Privacy Act;
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phjil has not handled your personal data in accordance with applicable law.

To exercise any of the above rights, please contact phjil's Data Privacy Officer using the contact details in Section 17. phjil will respond to all verified data subject requests within fifteen (15) business days of receipt. In complex cases, phjil may extend this period by a further fifteen (15) business days, in which case you will be notified of the extension and the reasons for it.

13 Children's Privacy

The phjil platform is strictly prohibited for use by individuals under the age of 21 years. phjil does not knowingly collect personal data from individuals under the age of 21. If phjil becomes aware that it has collected personal data from an individual who is under 21 years of age, it will immediately suspend the relevant account, delete the data in question to the extent not required to be retained for compliance purposes, and take appropriate further action in accordance with its obligations under applicable law and PAGCOR guidelines.

If you believe that phjil may have collected personal data from a person under the age of 21, please contact our Data Privacy Officer immediately using the contact details in Section 17.

14 Marketing Communications

phjil may send you promotional offers, bonus announcements, and platform updates by email or SMS if you have opted in to marketing communications at the time of account registration or subsequently through your account settings. Your consent to marketing communications is voluntary and entirely separate from your consent to data processing for account management and service delivery purposes.

You may withdraw your consent to marketing communications at any time by: (a) updating your communication preferences in your account settings; or (b) clicking the unsubscribe link included in any marketing email; or (c) contacting our customer support team and requesting removal from marketing lists. Withdrawal of marketing consent will not affect your ability to use the phjil platform or receive transactional communications related to your account (such as deposit confirmations, withdrawal notifications, and security alerts).

15 Third-Party Links

The phjil platform does not contain links to third-party websites for commercial or advertising purposes. Any third-party services integrated into the phjil platform (such as game studio content and payment processors) are governed by their own privacy practices in relation to data that you submit directly to those services. phjil is not responsible for the privacy practices of third-party services and encourages you to review the privacy policies of any third-party provider with whom you interact.

16 Changes to This Privacy Policy

phjil reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Policy, phjil will notify registered players by email to their registered email address and/or by a prominent notice displayed upon next login to the phjil platform. The revised Policy will be posted on phjil.app with an updated effective date.

Your continued use of the phjil platform following notification of changes to this Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree with the changes, you must cease using the platform and may request closure of your account. We encourage you to review this Policy periodically to stay informed about how phjil protects your personal data.

17 Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or phjil's handling of your personal data, please contact phjil's Data Privacy Officer through the following channels:

• Live Chat: Available 24/7 at phjil.app — the fastest channel for urgent matters;
• Email: [email protected] — for written queries and formal data subject requests (displayed for reference; not a clickable link);

Please include your registered account email address, a description of your request or concern, and any relevant account reference numbers in your communication. phjil will acknowledge receipt of data-related requests within three (3) business days and provide a substantive response within fifteen (15) business days.

If you are not satisfied with phjil's response to your privacy-related concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the independent data protection authority responsible for enforcing the Philippine Data Privacy Act of 2012.