Privacy Policy

1. Introduction

Welcome to the 37 Jili Casino Privacy Policy. At 37 Jili, we understand that your personal information is important to you, and we take our responsibility as a data controller seriously. This Privacy Policy applies to all personal data collected through the 37 Jili website at 37jili.org, our mobile platform, customer support channels, and any other services we provide to registered players and site visitors.

By registering an account with 37 Jili, accessing our platform, or otherwise interacting with our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this policy, please discontinue use of the 37 Jili platform immediately.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of the 37 Jili platform.

2. Data We Collect

2.1 Information You Provide Directly

When you register an account, verify your identity, make a deposit or withdrawal, or contact our support team, we collect the following categories of personal data:

• Identity Data: Full legal name, date of birth, nationality, and government-issued ID details (e.g., Philippine passport, driver's license, PhilSys National ID, SSS/GSIS ID).
• Contact Data: Residential address (including city, province, and ZIP code within the Philippines), email address, and mobile phone number.
• Financial Data: GCash account details, PayMaya/Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and debit card details used for deposits and withdrawals.
• Account Data: Username, encrypted password, account preferences, communication preferences, and responsible gaming settings.
• Verification Data: Copies of identity documents, selfies or photographs submitted for KYC (Know Your Customer) verification, and proof of address documents.

2.2 Information Collected Automatically

When you access the 37 Jili platform, we automatically collect certain technical and behavioral data, including:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, session duration, click patterns, search queries within the platform, and feature interactions.
• Transaction Data: Details of all deposits, withdrawals, wagers, game results, bonus activations, and account balance history.
• Location Data: General geographic location derived from your IP address, used to verify compliance with jurisdictional requirements.

3. How We Use Your Data

37 Jili processes your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 37 Jili player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to our casino games, process your deposits and withdrawals, credit bonuses and promotions, and deliver customer support.
• Legal Compliance: To comply with our obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012. This includes conducting KYC checks, transaction monitoring, and filing required regulatory reports.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other illegal or prohibited conduct on the platform.
• Responsible Gaming: To monitor gaming behavior, identify potential problem gambling indicators, enforce self-exclusion requests, and apply deposit limits or cooling-off periods as requested or required.
• Communications: To send you transactional notifications (e.g., deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about 37 Jili offers and new games.
• Platform Improvement: To analyze usage patterns, conduct A/B testing, and improve the functionality, performance, and user experience of the 37 Jili platform.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws and PAGCOR regulations, including KYC verification, AMLA compliance, and regulatory reporting.
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given, and informed consent. You may withdraw this consent at any time.

5. Data Sharing & Disclosure

37 Jili does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this policy:

• Payment Processors: GCash, PayMaya, and Philippine banking partners, to process your deposits and withdrawals securely.
• Identity Verification Providers: Third-party KYC and AML screening services used to verify your identity and screen against sanctions lists.
• Game Software Providers: Licensed game developers and live casino operators whose games are available on the 37 Jili platform, to the extent necessary to deliver gameplay.
• 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 obligation.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers operating under strict data processing agreements.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

6. Cookies & Tracking Technologies

37 Jili uses cookies and similar tracking technologies to enhance your experience on the platform, maintain your session, and analyze usage patterns. The categories of cookies we use include:

• Strictly Necessary Cookies: Essential for the platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game favorites, and display options to personalize your experience.
• Analytics Cookies: Collect anonymized data about how players use the platform to help us improve performance and user experience. Used only with your consent.
• Marketing Cookies: Used to deliver relevant promotional content about 37 Jili. Used only with your explicit consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 37 Jili platform.

7. Data Retention

37 Jili retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AMLA obligations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by AMLA.
• Support Communications: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

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

8. Your Data Rights

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

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which this Privacy Policy fulfills.
• Right of Access: The right to request a copy of the personal data we hold about you and 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, subject to our legal retention obligations under Philippine law.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another 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 processing carried out prior to withdrawal.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14 of this policy. We will respond to all verified requests within fifteen (15) business days, as required by the Data Privacy Act.

9. Data Security

37 Jili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and the 37 Jili platform is protected using 256-bit SSL/TLS encryption. Sensitive data at rest, including financial information and identity documents, is encrypted using industry-standard algorithms.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All 37 Jili staff with access to personal data are subject to confidentiality obligations and regular security training.
• Infrastructure Security: Our platform is hosted on secure, audited infrastructure with firewalls, intrusion detection systems, and regular vulnerability assessments.
• Incident Response: We maintain a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected individuals within seventy-two (72) hours of becoming aware of the breach, as required by NPC regulations.

10. Children's Privacy

The 37 Jili platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. 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, we will immediately suspend the associated account, delete the data, and take appropriate action in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor has registered an account or provided personal data to 37 Jili, please contact our Data Protection Officer immediately using the contact details in Section 14.

11. Cross-Border Data Transfers

In certain circumstances, your personal data may be transferred to, stored in, or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or game software developers operating in other jurisdictions. When such transfers occur, 37 Jili ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under the Philippine Data Privacy Act of 2012.

By using the 37 Jili platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the delivery of our services, subject to the safeguards described above.

12. Third-Party Links

The 37 Jili platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 37 Jili platform and does not cover the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. 37 Jili accepts no responsibility or liability for the privacy practices or content of third-party websites.

13. Policy Updates

37 Jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, we will notify registered players via email or an in-platform notification prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Your continued use of the 37 Jili platform following any update constitutes your acceptance of the revised policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our designated Data Protection Officer (DPO):

• Data Protection Officer: 37 Jili Casino DPO
• Email: [email protected]
• Mailing Address: 37 Jili Casino, Philippines
• Response Time: Within 15 business days of receiving a verified request

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.