1 Introduction
This Privacy Policy ("Policy") describes how 123jilli ("we," "us," "our," or "the Platform") collects, uses, stores, discloses, and protects the personal information of users ("you," "Player," or "User") who access or use the 123jilli website at https://123jilli.one and all associated services.
123jilli is committed to protecting the privacy and personal data of all Filipino players who use our platform. We operate in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission ("NPC").
By registering an account on 123jilli, accessing the platform, or using any of our services, 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 Policy, please discontinue use of the platform immediately.
This Policy should be read together with our Terms and Conditions, which are available at 123jilli.one/terms-conditions, and our Responsible Gaming Policy at 123jilli.one/responsible-gaming.
2 Data We Collect
123jilli collects personal data that is necessary for the operation of the platform, the provision of gaming services, and compliance with applicable legal and regulatory obligations. The categories of personal data we collect include:
2.1 Registration & Identity Data
- Full legal name as it appears on your government-issued identification
- Date of birth (used to verify that you meet the 21+ age requirement)
- Residential address, including barangay, city or municipality, and province
- Email address and mobile phone number
- Username and encrypted password
- Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys ID, driver's license) submitted during Know Your Customer (KYC) verification
2.2 Financial & Transaction Data
- GCash account number or registered mobile number
- PayMaya account details
- Bank account details for BPI, BDO, Metrobank, or other Philippine banks used for deposits or withdrawals
- Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references
- Bonus and promotional activity records
2.3 Gaming & Activity Data
- Game history, including games played, wager amounts, outcomes, and session durations
- Sports betting history, including markets selected, odds accepted, and bet results
- Login timestamps, session durations, and platform activity logs
- Responsible gaming tool usage, including deposit limits set and self-exclusion requests
2.4 Technical & Device Data
- IP address and approximate geolocation derived from IP
- Device type, operating system, and browser type and version
- Cookie identifiers and session tokens
- Referring URL and pages visited within the 123jilli platform
2.5 Communications Data
- Records of communications between you and the 123jilli support team, including live chat transcripts, email correspondence, and support ticket history
- Feedback, complaints, and dispute records
3 How We Use Your Data
123jilli uses the personal data we collect for the following purposes:
- Account Management: To create, maintain, and manage your 123jilli player account, including processing your registration, verifying your identity, and enabling you to log in securely.
- Age Verification: To confirm that you are at least 21 years of age, as required by Philippine law and PAGCOR regulations. 123jilli strictly prohibits access by minors.
- Service Delivery: To provide you with access to our games, sports betting, live casino, and all other platform features.
- Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and bank transfer, and to maintain accurate financial records of all transactions.
- Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct on the platform.
- Regulatory Compliance: To comply with applicable Philippine laws and regulations, including the Data Privacy Act of 2012, Anti-Money Laundering Act (AMLA), and PAGCOR licensing requirements.
- Responsible Gaming: To monitor gaming activity for signs of problem gambling, to administer responsible gaming tools such as deposit limits and self-exclusion, and to fulfill our duty of care to players.
- Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support team.
- Platform Improvement: To analyze usage patterns, identify technical issues, and improve the performance, features, and user experience of the 123jilli platform.
- Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time by contacting support.
4 Legal Basis for Processing
Under the Data Privacy Act of 2012 of the Philippines, 123jilli processes your personal data on the following legal bases:
- Consent: Where you have given your explicit consent to the processing of your personal data, such as for marketing communications or the use of non-essential cookies.
- Contractual Necessity: Where processing is necessary for the performance of the contract between you and 123jilli, including account registration, payment processing, and service delivery.
- Legal Obligation: Where processing is required to comply with applicable Philippine laws and regulations, including KYC obligations, AMLA reporting requirements, and PAGCOR compliance.
- Legitimate Interests: Where processing is necessary for the legitimate interests of 123jilli, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.
5 Data Sharing & Disclosure
123jilli does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients,
strictly on a need-to-know basis and subject to appropriate data protection obligations:
- Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers receive the financial data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are bound by applicable Philippine financial regulations.
- Game Providers: Third-party game software providers may receive limited technical data necessary to deliver their games on the 123jilli platform. These providers are contractually prohibited from using your data for any purpose other than service delivery.
- Identity Verification Services: KYC and identity verification service providers may process your identification documents and personal data to confirm your eligibility to use the platform.
- Regulatory Authorities: We may disclose your personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other Philippine government authorities where required by law, court order, or regulatory directive.
- Law Enforcement: Where required by applicable law or where we have a good-faith belief that disclosure is necessary to prevent fraud, illegal activity, or harm to persons, we may share data with Philippine law enforcement agencies.
- Service Providers: IT infrastructure providers, cloud hosting services, customer support platforms, and analytics providers who assist in the operation of the 123jilli platform. All such providers are bound by data processing agreements that restrict their use of your data.
In all cases of data sharing, 123jilli takes reasonable steps to ensure that recipient parties maintain appropriate security standards and process your data only for the specified purpose.
6 Cookies & Tracking
123jilli uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and deliver a personalized experience. The types of cookies we use include:
- Essential Cookies: Required for the platform to function correctly, including session management, login authentication, and security features. These cannot be disabled without affecting platform functionality.
- Functional Cookies: Used to remember your preferences, such as language settings and display options, to improve your experience on return visits.
- Analytics Cookies: Used to collect aggregated, anonymized data about how players use the platform, helping us identify areas for improvement. This data does not identify you personally.
- Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the platform.
You may manage your cookie preferences through your browser settings. Please note that disabling essential cookies may impair your ability to use certain features of the 123jilli platform. By continuing to use the platform after being notified of our cookie use, you consent to the placement of cookies on your device in accordance with this Policy.
7 Data Retention
123jilli retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, and to resolve any disputes or enforce our agreements.
Specifically, account and transaction records are retained for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations and PAGCOR requirements. Communications records are retained for a minimum of three (3) years. Technical and device data is retained for up to twelve (12) months.
Where personal data is no longer required for any lawful purpose, 123jilli will securely delete or anonymize it in accordance with our internal data retention and disposal procedures.
8 Data Security
123jilli implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:
- SSL/TLS 256-bit encryption for all data transmitted between your device and the 123jilli platform
- Encryption of sensitive data at rest, including financial information and identification documents
- Role-based access controls limiting staff access to personal data on a strict need-to-know basis
- Regular security audits, vulnerability assessments, and penetration testing
- Multi-factor authentication options for player accounts
- Continuous monitoring for suspicious activity and unauthorized access attempts
While 123jilli takes all reasonable precautions to protect your data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 123jilli will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.
9 Your Rights
Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by 123jilli:
- Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy.
- Right of Access: You have the right to request a copy of the personal data that 123jilli holds about you, along with information about how it is being processed.
- Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain account details directly through your account settings.
- Right to Erasure: You have the right to 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 have the right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time by contacting our support team.
- Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format where technically feasible.
- Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that your data privacy rights have been violated.
To exercise any of these rights, please contact the 123jilli Data Privacy Officer at [email protected]. We will respond to all verified requests within thirty (30) days in accordance with the requirements of the Data Privacy Act.
10 Children's Privacy
The 123jilli platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.
If you are a parent or guardian and believe that your child has registered on the 123jilli platform or provided us with personal data, please contact us immediately at [email protected] so that we can take appropriate action.
11 Third-Party Links
The 123jilli platform may contain references to third-party services, such as payment processors and game providers. This Privacy Policy applies solely to data collected and processed by 123jilli. We are not responsible for the privacy practices of third-party services, and we encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the platform.
12 International Transfers
In some cases, your personal data may be transferred to, stored, or processed in countries outside the Philippines, for example where our technology service providers or game providers operate servers in other jurisdictions. Where such transfers occur, 123jilli ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012, including contractual data protection clauses with the receiving parties.
By using the 123jilli platform, you consent to the transfer of your personal data to other countries where necessary for the provision of our services, subject to the safeguards described above.
13 Changes to This Policy
123jilli reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will update the "Last Updated" date at the top of this page and, where required, notify you by email or through a prominent notice on the platform.
Your continued use of the 123jilli platform following the posting of any updated Privacy Policy constitutes your acceptance of the revised Policy. We recommend that you review this page periodically to stay informed of how we protect your personal data.
14 Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 123jilli, please contact our Data Privacy Officer:
Email: [email protected]
Our support team is available 24 hours a day, 7 days a week. For formal data privacy requests, please include "Data Privacy Request" in your subject line along with your registered account username and a clear description of your request. We aim to acknowledge all data privacy inquiries within 72 hours and to resolve them within 30 days.
You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your data privacy concern.