36jili Privacy Policy

1. Introduction

36jili is committed to protecting the privacy and personal data of every player who uses our platform. We understand that trust is the foundation of a good gaming experience, and that trust begins with being transparent about how we handle your information.

This Privacy Policy applies to all personal data collected through the 36jili website at https://36jili.app, the 36jili mobile application, and any other channel through which 36jili services are made available to players in the Philippines and elsewhere.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and the implementing rules and regulations issued by the National Privacy Commission (NPC). Where applicable, we also observe internationally recognized data protection principles.

2. Personal Data We Collect

36jili collects only the personal data that is necessary to provide you with a safe, compliant, and fully functional gaming experience. The categories of personal data we collect include the following:

2.1 Registration and Identity Data

• Full legal name
• Date of birth (for age verification purposes — players must be 21 years of age or older)
• Residential address, including city and province (e.g., Manila, Cebu, Davao, Makati, Quezon City)
• Email address and mobile phone number
• Username and encrypted password
• Government-issued identification document details (e.g., Philippine passport, SSS ID, PhilSys national ID, driver's license)

2.2 Financial and Payment Data

• GCash account number or registered mobile number
• PayMaya / Maya wallet details
• Bank account details for BDO, BPI, Metrobank, or other linked bank accounts
• Transaction history, including deposit amounts, withdrawal requests, and payment method used

2.3 Gaming Activity Data

• Game session history, including games played, wager amounts, and outcomes
• Bonus and promotion usage records
• Responsible gaming tool settings, including deposit limits and self-exclusion status

2.4 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session timestamps and platform access logs
• Cookie identifiers and similar tracking data (see Section 7)

2.5 Communications Data

• Records of communications between you and 36jili customer support
• Feedback, complaints, and dispute records
• Marketing preference settings and communication opt-in or opt-out records

3. How We Collect Your Data

36jili collects personal data through the following means:

• Directly from you — when you register an account, complete identity verification, make a deposit or withdrawal, contact customer support, or update your account settings.
• Automatically — through cookies, web beacons, and server logs when you access and interact with the 36jili platform.
• From third parties — including payment service providers (such as GCash and PayMaya), identity verification services, and fraud prevention partners, where necessary to verify your identity or process transactions.

4. How We Use Your Personal Data

36jili uses the personal data we collect for the following purposes:

Purpose	Data Used
Account registration and management	Identity data, contact details
Age and identity verification (KYC)	Identity documents, date of birth
Processing deposits and withdrawals	Financial data, transaction records
Providing gaming services and game history	Gaming activity data
Fraud prevention and security monitoring	Technical data, transaction records
Regulatory compliance and anti-money laundering	Identity data, financial data
Customer support and dispute resolution	Communications data, account data
Responsible gaming monitoring and tools	Gaming activity, responsible gaming settings
Sending promotional communications (with consent)	Contact details, marketing preferences
Platform improvement and analytics	Technical data, gaming activity (aggregated)

5. Legal Basis for Processing

36jili processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its implementing rules:

• Contractual necessity — processing is required to fulfill our obligations to you under the 36jili Terms and Conditions, including account management, payment processing, and game provision.
• Legal obligation — processing is required to comply with applicable laws and regulations, including anti-money laundering obligations, age verification requirements, and regulatory reporting duties.
• Legitimate interests — processing is necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent — where we rely on your consent as the legal basis for processing (for example, for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing and Disclosure

36jili 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 only where necessary and on a strictly limited basis:

• Payment service providers — GCash, PayMaya, BDO, BPI, Metrobank, and other payment processors, solely for the purpose of processing your deposits and withdrawals.
• Identity verification and KYC providers — third-party services engaged to verify your identity and age in compliance with our regulatory obligations.
• Fraud prevention and security partners — services used to detect and prevent fraudulent activity, money laundering, and unauthorized account access.
• Regulatory and law enforcement authorities — where we are required by law, court order, or regulatory directive to disclose personal data to competent authorities in the Philippines.
• Technology and infrastructure providers — cloud hosting, data storage, and platform technology providers who process data on our behalf under strict data processing agreements.

7. Cookies and Tracking Technologies

36jili uses cookies and similar tracking technologies to operate the platform, improve your experience, and analyze usage patterns. Cookies are small text files stored on your device when you visit the 36jili website or use the mobile application.

7.1 Types of Cookies We Use

• Essential cookies — required for the platform to function correctly, including maintaining your login session and remembering your account preferences. These cannot be disabled.
• Analytics cookies — used to collect aggregated, anonymized data about how players interact with the platform, helping us identify areas for improvement.
• Security cookies — used to detect and prevent fraudulent activity, unauthorized access, and other security threats.
• Preference cookies — used to remember your settings and preferences, such as language and display options.

You can manage your cookie preferences through your browser settings. Please note that disabling non-essential cookies may affect the functionality of certain features on the 36jili platform.

8. Data Retention

36jili retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering regulations.
• Financial and transaction data — retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial regulations.
• Gaming activity data — retained for the duration of your account and for two (2) years following account closure.
• Customer support communications — retained for two (2) years from the date of the last communication.
• Marketing preference records — retained until you withdraw consent or close your account, plus one (1) year for compliance documentation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

36jili implements a comprehensive range of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 36jili platform.
• Encryption of sensitive data at rest, including identity documents and financial information.
• Role-based access controls limiting internal access to personal data to authorized personnel only.
• Regular security assessments, vulnerability testing, and penetration testing of platform infrastructure.
• Multi-factor authentication options for player accounts.
• Continuous monitoring for suspicious activity and automated fraud detection systems.

10. Your Data Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 36jili:

• Right to be informed — you have the right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of access — you have the right to request a copy of the personal data we hold about you.
• Right to rectification — you have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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 or where processing is based on our legitimate interests.
• Right to data portability — you have the right to receive your personal data in a structured, commonly used 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 your data rights have been violated.

11. Children and Minors

The 36jili 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. Age verification is conducted as part of the account registration and KYC process.

If we become aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. Any funds held in such an account will be returned to the verified payment source.

If you believe that a minor has registered an account on the 36jili platform, please contact our support team immediately via live chat so that we can investigate and take appropriate action.

12. Third-Party Links

The 36jili platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 36jili platform and does not extend to any third-party websites or services that may be accessible via links on our platform.

36jili is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit independently of the 36jili platform.

13. Amendments to This Policy

36jili 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. The date of the most recent revision is displayed at the top of this page.

Where changes to this Policy are material, we will notify registered players via email or an on-platform notification prior to the changes taking effect. Your continued use of the 36jili platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 36jili protects your personal data.

14. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 36jili, please contact our Data Protection Officer. Our DPO is responsible for overseeing compliance with the Data Privacy Act of 2012 and for handling all data subject requests.

You may reach our Data Protection Officer and customer support team via the 24/7 live chat function available within the 36jili platform. Email support is also available, and our contact address is displayed in the footer of this page. Please allow up to 48 hours for email responses during periods of high volume.