Privacy Policy

34jili ("we," "us," "our," or "the Company") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, store, and protect the personal data of users ("you," "your," or "Player") who access and use our online gaming platform, websites, mobile applications, and related services (collectively, the "Service"). By registering an account with 34jili, accessing the Service, or providing personal information to us, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy.

This Privacy Policy is designed to comply with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, implementing rules and regulations issued by the National Privacy Commission, and gaming regulations established by the Philippine Amusement and Gaming Corporation (PAGCOR). We are committed to handling your personal data responsibly, transparently, and in accordance with applicable Philippine and international data protection laws.

1. Information We Collect

1.1 Personal Information You Provide

When you register an account with 34jili, we collect personal information that you voluntarily provide to us, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (such as passport number, driver's license number, or national ID number).
• Contact Information: Residential address, email address, mobile phone number, and alternative contact details.
• Financial Information: Bank account details, GCash account information, PayMaya account information, credit/debit card details, transaction history, deposit and withdrawal records, and payment verification documents.
• Account Credentials: Username, password, security questions and answers, and any other authentication information.
• Verification Documents: Copies of government-issued identification documents, utility bills, bank statements, selfie photographs for identity verification, and any other documents required to comply with Know Your Customer (KYC) and anti-money laundering (AML) regulations.

1.2 Automatically Collected Information

When you access and use the Service, we automatically collect certain technical and usage information through cookies, web beacons, server logs, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifier (IMEI, MAC address, or similar), and mobile network information.
• Connection Information: IP address, internet service provider (ISP), geolocation data derived from IP address, connection timestamps, and network quality metrics.
• Usage Data: Pages visited, games played, betting patterns, session duration, click-through rates, navigation paths, search queries, feature interactions, and engagement metrics.
• Marketing Interactions: Response to promotional emails, participation in campaigns, bonus claim history, and communication preferences.

1.3 Information from Third Parties

We may receive information about you from third-party sources, including payment processors (GCash, PayMaya, banks), identity verification services, fraud detection providers, marketing partners, and social media platforms if you choose to link your social accounts. This information helps us verify your identity, prevent fraud, process transactions, and enhance your user experience.

2. How We Use Your Information

34jili collects and processes your personal information for the following legitimate business purposes:

2.1 Account Management and Service Provision

• Creating and maintaining your player account
• Authenticating your identity and verifying account credentials
• Processing deposits, withdrawals, and other financial transactions
• Providing customer support and responding to inquiries
• Managing bonuses, promotions, and loyalty rewards
• Facilitating gameplay and delivering gaming services

2.2 Legal and Regulatory Compliance

• Verifying that you meet the minimum age requirement of 21 years
• Conducting Know Your Customer (KYC) verification as required by PAGCOR regulations
• Implementing anti-money laundering (AML) and counter-terrorism financing (CTF) measures
• Complying with legal obligations, court orders, and government requests
• Maintaining audit trails and records as required by gaming regulations
• Reporting suspicious transactions to relevant authorities

2.3 Security and Fraud Prevention

• Detecting and preventing fraudulent activity, collusion, and bonus abuse
• Monitoring for multiple accounts, identity theft, and unauthorized access
• Implementing security measures to protect your account and funds
• Analyzing betting patterns to identify irregular or suspicious behavior
• Investigating disputes, complaints, and Terms of Service violations

2.4 Marketing and Communications

• Sending promotional offers, bonuses, and exclusive deals tailored to Filipino players
• Notifying you of new games, features, and platform updates
• Conducting market research and analyzing user preferences
• Personalizing your gaming experience based on your activity and interests
• Sending transactional emails regarding deposits, withdrawals, and account activity

2.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve Service functionality and user experience
• Conducting A/B testing to optimize features and interfaces
• Identifying technical issues and improving platform performance
• Developing new games, features, and services based on user behavior
• Generating aggregated, anonymized statistics for business intelligence

3. Legal Basis for Processing

Under the Data Privacy Act of 2012 and applicable data protection laws, 34jili processes your personal data based on the following legal grounds:

Legal Basis	Purpose
Consent	Marketing communications, personalized promotions, and non-essential cookies. You may withdraw consent at any time.
Contractual Necessity	Account registration, transaction processing, game provision, and fulfillment of Terms and Conditions.
Legal Obligation	Age verification, KYC/AML compliance, tax reporting, regulatory audits, and law enforcement cooperation.
Legitimate Interests	Fraud prevention, security monitoring, platform improvement, and business analytics, provided such interests do not override your rights.

4. How We Share Your Information

34jili does not sell your personal data to third parties. However, we may share your information with the following categories of recipients for the purposes described in this Privacy Policy:

4.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform business functions on our behalf, including payment processors (GCash, PayMaya, banks), identity verification services, cloud hosting providers, customer support platforms, email service providers, marketing agencies, analytics tools, and fraud detection systems. These providers are contractually obligated to use your data only for specified purposes and to maintain appropriate security measures.

4.2 Regulatory and Government Authorities

We may disclose your information to PAGCOR, the National Privacy Commission, law enforcement agencies, tax authorities, and other government bodies when required by law, regulation, legal process (such as subpoena or court order), or to comply with gaming license obligations. We will disclose only the information necessary to fulfill such legal requirements.

4.3 Corporate Transactions

In the event of a merger, acquisition, reorganization, sale of assets, or other corporate transaction involving 34jili, your personal data may be transferred to the successor entity or acquiring party, subject to the same privacy protections outlined in this Privacy Policy. You will be notified of any such change in ownership or control of your personal information.

4.4 Legal Protection and Public Safety

We may disclose your information when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of 34jili, our users, or the public; to enforce our Terms and Conditions; to investigate fraud, security breaches, or Terms violations; or to respond to emergency situations involving threats to personal safety.

5. Data Security Measures

34jili employs industry-standard technical, administrative, and physical security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction:

• Encryption: All sensitive data transmitted between your device and our servers is encrypted using SSL/TLS protocols (minimum 256-bit encryption). Stored financial information and passwords are encrypted at rest.
• Access Controls: Personal data is accessible only to authorized personnel who require such access to perform their job functions. Multi-factor authentication and role-based access controls limit data exposure.
• Security Monitoring: We employ 24/7 security monitoring, intrusion detection systems, firewalls, and regular security audits to identify and respond to potential threats.
• Secure Infrastructure: Our platform is hosted on secure, internationally recognized cloud infrastructure with redundant backups, disaster recovery capabilities, and compliance with security standards.
• Employee Training: All personnel with access to personal data undergo regular training on data privacy, security best practices, and regulatory compliance.

Despite these measures, no method of electronic transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us of any unauthorized account access.

6. Data Retention

34jili retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our Terms and Conditions, and maintain business records.

Specifically:

• Active Accounts: Personal data associated with active accounts is retained for the duration of your relationship with 34jili and for a period of five (5) years following account closure, as required by PAGCOR regulations and anti-money laundering laws.
• Transaction Records: Financial transaction data, including deposits, withdrawals, wagers, and winnings, is retained for a minimum of seven (7) years to comply with tax, accounting, and audit requirements.
• KYC/AML Documents: Identity verification documents and KYC records are retained for five (5) years after the end of the business relationship, as mandated by anti-money laundering regulations.
• Marketing Data: If you opt out of marketing communications, we will retain a record of your opt-out preference indefinitely to honor your request.
• Legal Holds: Data subject to litigation, investigation, or legal hold will be retained until the matter is resolved, regardless of standard retention periods.

After the applicable retention period expires, personal data will be securely deleted or anonymized so that it can no longer identify you.

7. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request access to the personal data we hold about you. Upon request, we will provide you with a copy of your data in a structured, commonly used format. You may access and update much of your account information directly through your account settings.

7.2 Right to Rectification

If you believe that any personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request correction or update of such information. You can update most account details yourself through your profile settings.

7.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purpose it was collected, when you withdraw consent (where consent was the legal basis), or when the data has been unlawfully processed. However, this right is subject to legal limitations, including our regulatory obligations to retain certain records for specified periods.

7.4 Right to Object

You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. If you object to marketing communications, we will cease such processing immediately. For objections based on legitimate interests, we will assess the request and cease processing unless we can demonstrate compelling legitimate grounds that override your rights.

7.5 Right to Data Portability

Where technically feasible, you have the right to receive your personal data in a structured, machine-readable format and to request transmission of that data to another service provider, provided such transmission does not adversely affect the rights of others.

7.6 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Note that withdrawal of consent may prevent us from providing certain services to you.

7.7 Right to Lodge a Complaint

If you believe your privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Contact information for the NPC is available at privacy.gov.ph.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. We will respond to verified requests within thirty (30) days as required by law. We may request additional information to verify your identity before processing your request.

8. Cookies and Tracking Technologies

34jili uses cookies, web beacons, pixels, and similar tracking technologies to enhance your user experience, analyze site usage, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you on return visits and remember your preferences.

Types of Cookies We Use:

• Essential Cookies: Necessary for the platform to function properly, including authentication, security, and session management. These cannot be disabled.
• Performance Cookies: Collect anonymous usage statistics to help us improve the platform's performance and user experience.
• Functional Cookies: Remember your preferences, language settings, and customization choices.
• Marketing Cookies: Track your browsing behavior across sessions to deliver personalized advertisements and measure campaign effectiveness.

You can manage cookie preferences through your browser settings. However, disabling certain cookies may limit your ability to use some features of the Service. Most browsers accept cookies by default, but you can configure your browser to refuse cookies or alert you when cookies are being sent.

9. International Data Transfers

While 34jili primarily serves Filipino players and operates within the Philippines, certain service providers and infrastructure partners may be located outside the Philippines. When we transfer personal data internationally, we ensure that appropriate safeguards are in place, such as standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms to protect your data in accordance with Philippine data protection standards.

10. Children's Privacy

34jili strictly prohibits use of the Service by individuals under 21 years of age. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected data from a person under 21, we will take immediate steps to delete such information and terminate the associated account. If you believe a minor has provided personal information to 34jili, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

34jili reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated to you via email or prominent notice on the platform at least thirty (30) days before the changes take effect. Your continued use of the Service after such notice constitutes acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

34jili Data Protection Officer
Email: [email protected]
Subject Line: Privacy Inquiry / Data Protection Request
Response Time: Within 30 days of receipt

For urgent security matters or suspected data breaches, please mark your email as "URGENT - Security Issue" to ensure expedited handling.