37jili Privacy Policy

1. Introduction

37jili 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 good gaming experience, and that trust starts with being completely transparent about how we handle your information.

This Policy applies to all personal data collected through the 37jili website, mobile platform, customer support channels, and any other touchpoint where you interact with 37jili. It covers data collected both automatically (such as through cookies and server logs) and data you provide directly (such as during registration or KYC verification).

We encourage you to read this Policy in full alongside our Terms & Conditions. If you have any questions about how we handle your data, our Data Protection Officer (DPO) is available to assist — contact details are provided in Section 13.

2. Personal Data We Collect

2.1 Data You Provide Directly

When you register for a 37jili account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions, you provide us with personal data including:

• Full legal name and date of birth
• Residential address (street, city, province, postal code)
• Email address and mobile phone number
• Government-issued ID details (e.g., Philippine passport number, SSS/UMID/PhilSys ID)
• Payment method information (e.g., GCash mobile number, bank account name and number for BPI, BDO, or Metrobank)
• Selfie photographs submitted for identity verification
• Communications sent to our support team

2.2 Data Collected Automatically

When you access 37jili, our systems automatically collect certain technical data, including your IP address, browser type, device type, operating system, referring URL, pages visited, time spent on each page, and session identifiers. This data is collected through server logs, cookies, and similar tracking technologies.

2.3 Data from Third Parties

We may receive personal data about you from third-party identity verification providers, payment processors (such as GCash, PayMaya, and banking partners), fraud prevention services, and publicly available sources, where this is necessary to verify your identity or comply with our legal obligations.

3. How We Use Your Personal Data

37jili uses your personal data for the following specific purposes:

Purpose	Data Used
Account registration and management	Identity, contact, and login data
Identity verification (KYC)	Identity documents, selfie, address data
Processing deposits and withdrawals	Financial and transaction data
Providing gaming services	Gaming and behavioural data
Customer support	Communications and account data
Fraud prevention and security	Technical, financial, and identity data
Regulatory compliance and AML	Identity, financial, and transaction data
Responsible gaming monitoring	Gaming, behavioural, and account data
Platform improvement and analytics	Technical and behavioural data (anonymised)
Marketing communications (with consent)	Contact and preference data

We do not use your personal data for any purpose not listed above without first obtaining your explicit consent or as otherwise required by law.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 37jili processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to when registering your 37jili account, including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

37jili 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:

• Identity Verification Providers: Third-party KYC and AML service providers who assist us in verifying your identity and screening against sanctions lists.
• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers necessary to process your deposits and withdrawals.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law.
• Technology Service Providers: Cloud hosting, data storage, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.
• Law Enforcement: Where required by a valid court order, subpoena, or other lawful request from Philippine law enforcement authorities.

6. Data Retention

37jili retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML and regulatory record-keeping requirements.
• Transaction and Financial Data: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• Gaming and Behavioural Data: Retained for the duration of your account and for up to three (3) years after account closure for responsible gaming and dispute resolution purposes.
• Communications Data: Customer support records are retained for up to three (3) years from the date of the last interaction.
• Technical and Device Data: Server logs and technical data are retained for up to twelve (12) months for security and fraud prevention purposes.

When your personal data is no longer required, it is securely deleted or anonymised in accordance with our data destruction procedures.

7. Cookies & Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device, remember your preferences, and collect information about how you use the site. 37jili uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the platform.

7.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences (such as language settings and responsible gaming limits) to provide a personalised experience.
• Analytics Cookies: Collect anonymised data about how players use 37jili, helping us identify areas for improvement. No personally identifiable information is collected through analytics cookies.
• Marketing Cookies: Used only with your explicit consent to deliver relevant promotional content. You may opt out at any time through your browser settings.

7.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 37jili platform. Instructions for managing cookies are available in the help documentation of all major browsers.

8. Data Security

37jili 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 our servers
• AES-256 encryption for sensitive data stored in our databases
• Multi-factor authentication (MFA) for all administrative access to systems holding personal data
• Regular penetration testing and vulnerability assessments conducted by independent security firms
• Role-based access controls ensuring that only authorised personnel can access personal data, on a strict need-to-know basis
• Continuous monitoring of our systems for suspicious activity and potential security incidents
• Regular staff training on data protection and information security best practices

While we take every reasonable precaution to protect your data, no system is completely immune to security risks. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 37jili will notify you and the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required by Philippine law.

9. Your Data Protection Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 37jili:

• Right to Be Informed: The right to know what personal data we collect about you, why we collect it, 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 we hold 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 we hold 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 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 our legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 13. We will respond to all valid requests within thirty (30) days. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.

10. Children & Minors

37jili is strictly an adult gaming platform. In accordance with Philippine gaming regulations, our services are available only to individuals who are at least 21 years of age. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will immediately delete that data and close the associated account. If you believe that a minor has registered on 37jili, please contact us immediately at the details provided in Section 13.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gaming platforms. For more information on protecting young people from gambling harm, please visit our Responsible Gaming page.

11. Third-Party Links

The 37jili platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to data collected by 37jili and does not cover the privacy practices of any third-party websites. We are not responsible for the content or privacy practices of any external sites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Updates to This Privacy Policy

37jili 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 notify registered players via email or through a prominent notice on the platform prior to the changes taking effect.

The updated Policy will be published on this page with a revised effective date. Your continued use of 37jili following the effective date of any update constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how we protect your data.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 37jili handles your personal data, please contact our Data Protection Officer (DPO). Our DPO is responsible for overseeing compliance with the Philippine Data Privacy Act and for handling all data subject rights requests.

You may reach the 37jili Data Protection Officer by email at: [email protected]

Please include "Privacy Request" or "Data Subject Rights" in the subject line of your email, along with your full name and registered email address, so we can locate your account and respond efficiently. We aim to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within thirty (30) days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.