jilulu Privacy Policy

1. Introduction

jilulu is committed to protecting the privacy and personal data of every Filipino player who uses our Platform. We understand that trust is the foundation of any relationship — and when it comes to your personal information, we take that responsibility seriously. This Policy applies to all personal data collected through the jilulu website, mobile-optimised platform, customer support channels, and any other touchpoints through which you interact with jilulu.

This Policy should be read alongside our Terms & Conditions, which govern your use of the jilulu Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

jilulu acts as the data controller for all personal data collected through the Platform. As data controller, jilulu determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

If you have any questions about how jilulu handles your personal data, or wish to exercise any of your data subject rights, you may contact our Data Protection Officer (DPO) via the support channels listed in Section 14 of this Policy.

3. Personal Data We Collect

jilulu collects personal data through several channels, including account registration, identity verification, payment processing, gameplay activity, and customer support interactions. The categories of personal data we collect include:

jilulu does not collect sensitive personal information (as defined under the Philippine Data Privacy Act) unless strictly required for regulatory compliance, such as government ID details for mandatory KYC verification.

4. How We Use Your Personal Data

jilulu uses the personal data we collect for the following purposes:

• Account creation and management: To register your jilulu account, verify your identity, and maintain your account in good standing.
• Age verification: To confirm that you are at least 21 years of age, as required under Philippine gambling regulations.
• Payment processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, UnionBank, and other accepted Philippine payment methods.
• Platform operation: To provide access to jilulu's games, process wagers, calculate and credit winnings, and maintain game integrity.
• Regulatory compliance: To comply with PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine laws.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other security threats.
• Responsible gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may need support.
• Customer support: To respond to your enquiries, resolve disputes, and improve our support services.
• Marketing communications: To send you promotional offers and updates about jilulu, where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyse usage patterns, conduct research, and improve the jilulu Platform's features and performance.

5. Legal Basis for Processing

jilulu processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your jilulu account and provide gaming services.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, tax reporting requirements, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming purposes, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

jilulu 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:

• Payment processors: GCash, Maya, BPI, BDO, UnionBank, and other Philippine payment service providers, solely to process your financial transactions.
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and age in compliance with PAGCOR requirements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where required by law or regulatory obligation.
• Fraud prevention services: Third-party fraud detection and security monitoring providers used to protect the integrity of the jilulu Platform.
• Game providers: Licensed game studios and live dealer operators whose games are available on the jilulu Platform, to the extent necessary to operate those games and resolve disputes.
• IT and hosting providers: Cloud infrastructure and technical service providers who host and maintain the jilulu Platform under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, where necessary for jilulu's legal and regulatory obligations.

All third parties with whom jilulu shares personal data are required to handle that data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose beyond the specific service they provide to jilulu.

7. Data Retention

jilulu retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your jilulu account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act.
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer support records: Retained for three (3) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period thereafter to demonstrate compliance.

When personal data is no longer required, jilulu will securely delete or anonymise it in accordance with our internal data disposal procedures.

8. Cookies & Tracking Technologies

jilulu uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how you use the Platform.

The types of cookies jilulu uses include:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your jilulu account. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options to personalise your jilulu experience.
• Analytics cookies: Help us understand how users interact with the Platform — which pages are visited most, where users drop off, and how performance can be improved. Data collected is aggregated and anonymised.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorised access attempts on the jilulu Platform.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the jilulu Platform. jilulu does not use third-party advertising or behavioural tracking cookies.

9. Data Security

jilulu implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jilulu's servers.
• Encryption of sensitive data at rest, including financial account details and government ID information.
• Two-factor authentication (2FA) via OTP for account login, available to all jilulu users.
• Role-based access controls ensuring that jilulu staff can only access personal data necessary for their specific job function.
• Regular security audits, penetration testing, and vulnerability assessments of the jilulu Platform.
• Intrusion detection systems and 24/7 security monitoring of Platform infrastructure.
• Staff training on data protection obligations and secure data handling practices.

Despite these measures, no electronic system is completely immune to security risks. In the event of a personal data breach that is likely to result in harm to affected users, jilulu will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Philippine Data Privacy Act.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jilulu:

• Right to be informed: The right to know what personal data jilulu collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data jilulu holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data jilulu holds about you.
• 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 jilulu's legal and regulatory retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller where technically feasible.
• 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 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 jilulu has violated your data protection rights.

To exercise any of these rights, please contact jilulu's Data Protection Officer via the live chat support channel available within the Platform. jilulu will respond to all data subject requests within thirty (30) calendar days of receipt, in accordance with NPC guidelines.

Please note that certain rights may be subject to limitations where jilulu has overriding legal obligations — for example, we cannot delete transaction records that we are required to retain under the Anti-Money Laundering Act.

11. Children's Privacy and the 21+ Rule

The jilulu Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. jilulu does not knowingly collect personal data from individuals under the age of 21.

If jilulu discovers or has reasonable grounds to believe that a user is under 21 years of age, the account will be immediately suspended, all gaming activity will be voided, and any deposited funds will be returned to the payment source after deducting any winnings, which will be forfeited. The matter may also be reported to PAGCOR as required.

If you are a parent or guardian and believe that a minor has registered on the jilulu Platform, please contact our support team immediately via live chat so that we can take prompt action.

12. Third-Party Links

The jilulu Platform may contain links to third-party websites or services — for example, links to payment provider portals or responsible gaming support organisations. This Privacy Policy applies solely to the jilulu Platform and does not cover the privacy practices of any third-party websites.

jilulu is not responsible for the content, privacy policies, or data handling practices of any third-party websites. We encourage you to review the privacy policy of any third-party site you visit before providing any personal information.

13. Changes to This Privacy Policy

jilulu 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, jilulu will notify registered users via the mobile number or email address associated with their account, and will update the "Last updated" date at the top of this page.

Your continued use of the jilulu Platform following the effective date of any amendment constitutes your acknowledgement of the revised Policy. We recommend reviewing this page periodically to stay informed about how jilulu protects your personal data.

If you disagree with any changes to this Policy, you may request account closure in accordance with the Terms & Conditions. Your data will be retained for the minimum periods required by law following closure.

14. Contact Us

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

• Live Chat: Available 24/7 directly within the jilulu Platform — the fastest way to reach our support and DPO team.
• Email: [email protected]

For complaints that cannot be resolved directly with jilulu, you have the right to escalate to the National Privacy Commission of the Philippines via their official channels.

For responsible gaming concerns, self-exclusion requests, or gaming limit adjustments, please visit our Responsible Gaming page.