Privacy Policy

1.Introduction and Scope

This Privacy Policy ("Policy") is issued by 38jili ("38jili," "we," "us," or "our") and applies to all personal data collected, processed, and stored in connection with your use of the 38jili online gaming platform, including the 38jili website at https://38jili.app, the 38jili mobile application, and any related services, features, or content made available by 38jili (collectively, the "Platform").

This Policy is intended to inform you — as a registered player, prospective player, or visitor to the 38jili Platform — about the types of personal data we collect, the purposes for which we process that data, the parties with whom we may share it, and the rights available to you under applicable Philippine law.

By accessing the 38jili Platform, registering an account, or otherwise providing your personal data to 38jili, 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. This Policy should be read together with our Terms and Conditions and Responsible Gaming Policy.

This Policy applies to all players located in the Philippines, including those in Manila, Cebu, Davao, Quezon City, Makati, and all other regions of the country.

2.Data Controller Information

38jili is the data controller responsible for your personal data collected through the Platform. As data controller, 38jili determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 38jili, you may contact our Data Protection Officer at:

Email: [email protected]

We aim to respond to all privacy-related inquiries within five (5) business days of receipt.

3.Personal Data We Collect

38jili collects the following categories of personal data in connection with your use of the Platform:

38jili does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where such data is voluntarily provided by you in the context of a responsible gaming self-exclusion request or similar welfare-related interaction.

4.How We Collect Your Data

38jili collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, placing bets, contacting support, or submitting feedback through the Platform.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and similar tracking technologies. See Section 9 for more details on our use of cookies.
• Third-party sources: Identity and financial verification data received from payment processors (such as GCash and PayMaya), identity verification service providers, and fraud prevention agencies, where necessary to comply with our legal obligations.
• Publicly available sources: Information available from public records or databases where relevant to our anti-money laundering or fraud prevention obligations.

5.How We Use Your Data

38jili uses your personal data for the following purposes:

• Account management: To register and maintain your 38jili player account, verify your identity and age (21+ requirement), and manage your account settings and preferences.
• Transaction processing: To process deposits and withdrawals in Philippine Peso via your chosen payment method, and to maintain accurate records of all financial transactions on your account.
• Service delivery: To provide access to 38jili's games, sports betting markets, promotions, and other Platform features.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Legal and regulatory compliance: To comply with our obligations under Philippine law, including anti-money laundering regulations, PAGCOR licensing requirements, and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, collusion, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Marketing communications: To send you promotional offers, bonus notifications, and news about 38jili, where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 38jili Platform.

6.Legal Basis for Processing

38jili processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Contractual necessity: Processing required to perform our contract with you, including operating your account, processing transactions, and delivering Platform services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering laws, PAGCOR requirements, and tax obligations.
• Legitimate interests: Processing necessary for 38jili's legitimate business interests, including fraud prevention, Platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications and certain cookie-based tracking. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7.Sharing Your Data

38jili does not sell, rent, or trade your personal data to third parties for their own commercial 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 safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with our regulatory compliance obligations.
• IT and platform service providers: Cloud hosting, data storage, cybersecurity, and software service providers who support the operation of the 38jili Platform under strict data processing agreements.
• Fraud prevention agencies: Third-party fraud detection and prevention services used to protect the integrity of the Platform and its players.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by 38jili in connection with legal proceedings, regulatory matters, or business operations, subject to professional confidentiality obligations.

Where 38jili engages third-party service providers to process personal data on its behalf, we ensure that appropriate data processing agreements are in place and that such providers implement adequate technical and organizational security measures.

8.Data Retention

38jili retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general guide, 38jili applies the following retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• Transaction and betting records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable Philippine law.
• Customer support communications: Retained for three (3) years from the date of the interaction, or longer where relevant to an ongoing dispute or legal proceeding.
• Marketing consent records: Retained until you withdraw your consent or for three (3) years from the date of last interaction, whichever is earlier.
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer for security or fraud investigation purposes.

Upon expiry of the applicable retention period, 38jili will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

9.Cookies and Tracking

38jili uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session security, and analyze Platform usage. Cookies are small text files stored on your device when you visit the Platform.

38jili uses the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including maintaining your login session and enabling secure transactions. These cookies cannot be disabled.
• Performance and analytics cookies: Used to collect anonymized information about how players use the Platform, helping us identify areas for improvement and optimize the user experience.
• Functional cookies: Used to remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 38jili Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

10.Your Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights in relation to your personal data held by 38jili:

• Right to be informed: The right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data that 38jili holds about you, together with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by 38jili.
• Right to erasure: 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: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 38jili has processed your personal data in violation of applicable law.

To exercise any of the above rights, please contact 38jili's Data Protection Officer at [email protected]. We will respond to all valid requests within fifteen (15) business days. We may need to verify your identity before processing your request.

11.Data Security

38jili implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 38jili Platform.
• Encryption of sensitive personal and financial data at rest using industry-standard algorithms.
• Role-based access controls limiting access to personal data to authorized 38jili personnel on a strict need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While 38jili takes all reasonable steps to protect your personal 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, 38jili will notify you and the National Privacy Commission as required by applicable Philippine law.

12.Children's Privacy

The 38jili Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing casino-style gaming and sports betting. 38jili does not knowingly collect personal data from individuals under the age of 21.

If 38jili becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 38jili Platform, please contact us immediately at [email protected].

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent access to gambling platforms. For more information on protecting minors from gambling harm, please visit our Responsible Gaming page.

13.Changes to This Policy

38jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Where changes are material, we will provide reasonable advance notice to registered players via email or a prominent notice on the Platform.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how 38jili protects your personal data. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.

14.Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 38jili handles your personal data, please do not hesitate to reach out to our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.

Data Protection Officer — 38JILI
Email: [email protected]

For complaints that remain unresolved after contacting 38jili, you have the right to escalate your concern to the National Privacy Commission of the Philippines through their official channels.