Privacy Policy — 78jili

1. Introduction

78jili ("78jili," "we," "us," or "our") operates the online gaming platform accessible at 78jili.app. We are committed to safeguarding the personal information of all users ("Player," "you," or "your") in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

This Privacy Policy describes the types of personal data we collect when you register and use the 78jili platform, the purposes for which we process that data, the parties with whom we may share it, and the rights available to you as a data subject under Philippine law. This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy.

2. Personal Data We Collect

78jili collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with the platform, and from third-party sources where permitted by law. The categories of personal data we collect include:

We do not collect sensitive personal information (as defined under RA 10173) such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required for responsible gaming assessments or legal compliance.

3. How We Use Your Personal Data

78jili processes your personal data only for specified, legitimate purposes. The primary purposes for which we use your data are:

• Account management: Creating, maintaining, and securing your 78jili account; verifying your identity and age (21+ requirement); processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers.
• Service delivery: Providing access to casino games, slot titles, bingo rooms, and sports betting markets; personalizing your gaming experience based on preferences and history.
• Legal and regulatory compliance: Fulfilling obligations under the Data Privacy Act of 2012, Anti-Money Laundering Act (RA 9160 as amended), and applicable PAGCOR regulations; responding to lawful requests from the NPC, PAGCOR, AMLC, or other Philippine government authorities.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, money laundering, and other prohibited conduct; maintaining the integrity of the platform.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior; administering self-exclusion requests and deposit limit tools.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time via your account settings or by contacting support.
• Customer support: Responding to queries, complaints, and disputes; improving the quality of our support services through interaction analysis.
• Platform improvement: Analyzing aggregated, anonymized usage data to improve game performance, user interface design, and overall platform reliability.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 78jili processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed consent to the processing of your personal data for a specific purpose (e.g., marketing communications, optional analytics).
• Contractual necessity: Where processing is necessary to perform the contract between you and 78jili — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Where processing is required to comply with a legal obligation applicable to 78jili, including AML reporting, age verification, and regulatory record-keeping.
• Legitimate interests: Where processing is necessary for the legitimate interests of 78jili (e.g., fraud prevention, platform security, responsible gaming monitoring), provided those interests are not overridden by your rights and freedoms.

5. Data Sharing and Disclosure

78jili 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 agreements:

• Payment processors: GCash (Mynt), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and other Philippine payment service providers, solely to process your deposits and withdrawals.
• Game providers: Licensed third-party game studios and RNG certification bodies, to the extent necessary to deliver and audit game content.
• Identity verification providers: KYC and AML compliance service providers engaged to verify your identity and screen against sanctions lists.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulatory directive.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors operating under strict data processing agreements that prohibit independent use of your data.
• Professional advisers: Lawyers, auditors, and accountants bound by professional confidentiality obligations, where necessary for legal or financial compliance.

6. Cookies and Tracking Technologies

78jili uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies we use include:

• Strictly necessary cookies: Essential for the platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game lobby layout, and notification preferences.
• Analytics cookies: Collect anonymized data about how players navigate the platform, which games are most popular, and where technical errors occur. This data is used solely to improve the 78jili experience.
• Security cookies: Help detect and prevent fraudulent activity, bot access, and account takeover attempts.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the 78jili platform. We do not use third-party advertising cookies or behavioral tracking cookies for cross-site advertising purposes.

7. Data Retention

78jili retains your personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods required by Philippine law:

• Account and transaction records: Minimum five (5) years from the date of the last transaction, as required by the Anti-Money Laundering Act.
• KYC and identity verification documents: Minimum five (5) years from account closure.
• Customer support communications: Two (2) years from the date of the interaction, unless the matter is subject to ongoing legal proceedings.
• Marketing consent records: Until you withdraw consent, plus one (1) year thereafter for compliance documentation purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with NPC-approved data disposal procedures.

8. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 78jili:

• Right to be informed: The right to know what personal data we collect and how it is processed — as set out in this Policy.
• Right of access: The right to request a copy of the personal data we hold about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• 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, machine-readable format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days, as required by the NPC's implementing rules.

9. Data Security

78jili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 78jili platform — the same standard used by BPI, BDO, and Metrobank for online banking.
• Encrypted storage of sensitive data at rest, including financial information and government ID details.
• Multi-factor authentication (MFA) options for account login, including OTP verification to your registered Philippine mobile number.
• Role-based access controls ensuring that 78jili staff can only access personal data necessary for their specific job functions.
• Regular security audits and penetration testing conducted by independent cybersecurity firms.
• Incident response procedures aligned with NPC Circular 16-03 on personal data breach management, including mandatory breach notification within 72 hours of discovery where required.

While we take all reasonable precautions, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

10. Children's Privacy

The 78jili platform is strictly intended for adults aged 21 years and older, consistent with PAGCOR regulations governing online gaming in the Philippines. 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 person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the 78jili platform, please contact our support team immediately at [email protected].

11. Cross-Border Data Transfers

Some of 78jili's service providers — including cloud infrastructure and game content providers — may be located outside the Philippines. Where personal data is transferred to recipients in other countries, 78jili ensures that appropriate safeguards are in place, including:

• Data processing agreements incorporating standard contractual clauses approved by the NPC
• Transfers only to jurisdictions that provide an adequate level of data protection as recognized by the NPC
• Binding corporate rules where transfers occur within a group of companies

By using the 78jili platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

12. Changes to This Privacy Policy

78jili 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 guidance from the NPC. When material changes are made, we will notify registered players via the email address or mobile number on file, or by displaying a prominent notice on the platform.

The "Last updated" date at the top of this page will always reflect the date of the most recent revision. Your continued use of the 78jili platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

13. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact 78jili's Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 within the 78jili platform
• Response time: Within 15 business days for formal data subject requests

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.