jilbay Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how jilbay ("jilbay," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal information of users ("you," "your," or "User") who access or use the jilbay online gaming platform, website, mobile applications, and related services (collectively, the "Platform").

This Policy applies to all personal information collected by jilbay through any means, including information provided directly by you during account registration, information collected automatically through your use of the Platform, and information obtained from third-party sources such as payment processors and identity verification services.

By accessing or using the jilbay platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with any part of this Policy, you must immediately discontinue use of the Platform.

2. Data Controller Information

For purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), jilbay is the data controller responsible for the collection, processing, storage, and protection of your personal information. jilbay is registered and operates in accordance with Philippine laws and regulations.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer at:

• Email: [email protected]
• Support Contact: Available through the jilbay platform's live chat feature (24/7)

3. Personal Information We Collect

jilbay collects various types of personal information to provide, maintain, improve, and secure our services. The categories of personal information we collect include:

3.1 Information You Provide Directly

When you register for a jilbay account or use our services, you provide the following information:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification documents (e.g., passport, driver's license, Philippine National ID, or other valid IDs);
• Contact Information: Email address, mobile phone number, residential address, postal code;
• Account Credentials: Username, password, security questions and answers, two-factor authentication details;
• Financial Information: Payment method details (e.g., GCash account information, Maya account, bank account numbers, cryptocurrency wallet addresses), transaction history, deposit and withdrawal records;
• Verification Documents: Proof of identity (ID scans, selfies), proof of address (utility bills, bank statements), proof of payment method ownership;
• Communication Data: Messages sent to customer support, chat transcripts, emails, feedback, and survey responses.

3.2 Information Collected Automatically

When you access or use the jilbay platform, we automatically collect certain information through cookies, web beacons, and similar technologies:

• Device Information: Device type, operating system, browser type and version, unique device identifiers, mobile network information;
• Usage Information: Pages visited, games played, bet amounts, win/loss records, session duration, click patterns, referral sources;
• Technical Data: IP address, geolocation data, time zone settings, connection type, internet service provider;
• Performance Data: Application crashes, error logs, performance metrics, load times.

3.3 Information from Third-Party Sources

jilbay may receive personal information about you from third-party sources, including:

• Payment Processors: Transaction status, payment verification, fraud risk scores from GCash, Maya, banks, and other payment providers;
• Identity Verification Services: Age verification results, identity authentication data, watchlist screening results;
• Marketing Partners: Referral source information, campaign tracking data (when you click on jilbay advertisements or promotions);
• Social Media Platforms: If you link your jilbay account to social media, we may receive basic profile information (name, email, profile picture) with your consent.

4. How We Use Your Personal Information

jilbay processes your personal information for the following purposes:

Purpose	Legal Basis
Account registration, authentication, and management	Contract performance, consent
Processing deposits, withdrawals, and financial transactions	Contract performance, legal obligation
Providing access to games, betting services, and platform features	Contract performance
Verifying your identity and age (21+ requirement)	Legal obligation, contract performance
Detecting, preventing, and investigating fraud, money laundering, and other illegal activities	Legal obligation, legitimate interest
Complying with anti-money laundering (AML) and counter-terrorism financing (CTF) laws	Legal obligation
Enforcing Terms & Conditions and preventing terms violations	Contract performance, legitimate interest
Providing customer support and responding to inquiries	Contract performance, legitimate interest
Sending account-related notifications, security alerts, and service updates	Contract performance, legal obligation
Sending promotional offers, bonuses, and marketing communications (with your consent)	Consent
Analyzing platform usage, improving user experience, and developing new features	Legitimate interest
Implementing responsible gaming tools and identifying problem gambling behavior	Legal obligation, legitimate interest
Complying with court orders, government requests, and regulatory obligations	Legal obligation

4.1 Marketing Communications

With your consent, jilbay may send you promotional emails, SMS messages, push notifications, and in-app messages about new games, bonuses, special offers, and other marketing content. You have the right to opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in promotional emails;
• Replying "STOP" to SMS marketing messages;
• Adjusting notification preferences in your account settings;
• Contacting customer support to request removal from marketing lists.

Opting out of marketing communications will not affect transactional or service-related messages (e.g., account notifications, security alerts, withdrawal confirmations).

5. Disclosure of Personal Information

jilbay may disclose your personal information to the following categories of recipients:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment Processors: GCash, Maya, banks, cryptocurrency payment gateways, and other financial service providers that process deposits and withdrawals;
• Identity Verification Services: Third-party providers that verify user identity, age, and address;
• Cloud Hosting and IT Services: Providers that host our platform infrastructure, databases, and backup systems;
• Customer Support Platforms: Live chat software, email service providers, and CRM systems;
• Analytics and Marketing Tools: Services that help us understand platform usage and deliver targeted marketing (e.g., Google Analytics, Facebook Pixel, subject to your cookie preferences);
• Fraud Prevention and Security Services: Companies that help detect suspicious activity, prevent fraud, and secure the platform.

All service providers are contractually obligated to protect your personal information and use it only for the purposes specified by jilbay.

5.2 Legal and Regulatory Authorities

jilbay may disclose your personal information to government agencies, regulatory bodies, law enforcement, and courts when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, including anti-money laundering (AML) reporting requirements;
• Respond to lawful court orders, subpoenas, or government requests;
• Detect, prevent, or investigate fraud, illegal activity, or violations of our Terms & Conditions;
• Protect the rights, property, and safety of jilbay, our users, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor company. You will be notified of any such change via email or prominent notice on the Platform.

5.4 Affiliate Companies

jilbay may share your personal information with affiliated companies within our corporate group for internal administrative purposes, fraud prevention, and to provide integrated services. All affiliates are bound by the same data protection obligations as jilbay.

5.5 No Sale of Personal Data

jilbay does not sell, rent, or trade your personal information to third parties for their independent marketing purposes.

6. International Data Transfers

jilbay primarily stores and processes your personal information within the Republic of the Philippines. However, in certain circumstances, your personal information may be transferred to, stored in, or accessed from jurisdictions outside the Philippines, including:

• Service providers and data centers located in other countries;
• Cloud hosting infrastructure operated by international providers (e.g., Amazon Web Services, Google Cloud Platform, Microsoft Azure);
• Payment processors and financial institutions with international operations.

When personal information is transferred internationally, jilbay ensures that appropriate safeguards are in place to protect your data, including:

• Contractual obligations requiring third parties to comply with Philippine data protection standards;
• Use of Standard Contractual Clauses approved by recognized data protection authorities;
• Ensuring that recipients are located in jurisdictions with adequate data protection laws.

7. Data Security Measures

jilbay implements robust technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• Encryption: All data transmitted between your device and jilbay servers is encrypted using 256-bit SSL/TLS encryption;
• Secure Storage: Personal information is stored in encrypted databases with access controls and regular security audits;
• Access Controls: Only authorized jilbay personnel with a legitimate business need can access personal information, and all access is logged and monitored;
• Two-Factor Authentication (2FA): Users are encouraged to enable 2FA to add an extra layer of account security;
• Regular Security Audits: jilbay conducts periodic security assessments, penetration testing, and vulnerability scans;
• Employee Training: All jilbay employees with access to personal information undergo data protection and security awareness training;
• Incident Response Plan: jilbay maintains a data breach response plan to quickly address and mitigate security incidents.

Despite these measures, no method of electronic storage or transmission 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.

8. Data Retention

jilbay retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Retention periods vary depending on the type of information and the purpose for which it was collected:

• Active Accounts: Personal information for active accounts is retained for the duration of your account relationship with jilbay;
• Closed Accounts: After account closure, personal information is retained for a minimum of five (5) years to comply with anti-money laundering (AML) and financial record-keeping obligations;
• Transaction Records: Financial transaction data is retained for at least ten (10) years as required by Philippine law;
• Marketing Data: If you opt out of marketing communications, your contact information is retained on a suppression list to ensure we do not contact you again;
• Legal Claims: Information relevant to legal disputes or regulatory investigations is retained until the matter is fully resolved.

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

9. Your Data Protection Rights

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, you have the following rights regarding your personal information:

9.1 Right to Access

You have the right to request access to the personal information jilbay holds about you. You may request a copy of your data by contacting our Data Protection Officer. We will provide the information in a commonly used electronic format.

9.2 Right to Rectification

If your personal information is inaccurate, incomplete, or outdated, you have the right to request correction or update of your data. You can update most information directly through your account settings, or you may contact customer support for assistance.

9.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal information under certain circumstances, including:

• The data is no longer necessary for the purposes for which it was collected;
• You withdraw your consent and there is no other legal basis for processing;
• The data was unlawfully processed;
• Erasure is required to comply with a legal obligation.

Note that jilbay may be legally required to retain certain information (e.g., transaction records, compliance data) even after a deletion request.

9.4 Right to Object

You have the right to object to the processing of your personal information for direct marketing purposes or when processing is based on legitimate interests. jilbay will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

9.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider, where technically feasible.

9.6 Right to Restrict Processing

You have the right to request restriction of processing of your personal information in certain situations, such as when you contest the accuracy of the data or object to processing.

9.7 Right to Lodge a Complaint

If you believe jilbay has violated your data protection rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC)
• Website: www.privacy.gov.ph
• Email: [email protected]
• Hotline: (+63) 2-8234-2228

9.8 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected] or through the customer support chat on the jilbay platform. We will respond to your request within thirty (30) days of receipt. We may ask you to verify your identity before processing your request to ensure the security of your personal information.

10. Cookies and Tracking Technologies

jilbay uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content and advertisements.

10.1 What Are Cookies?

Cookies are small text files stored on your device when you visit the jilbay platform. Cookies help us recognize your device, remember your preferences, and improve platform functionality.

10.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly (e.g., session management, authentication, security);
• Performance Cookies: Collect information about how users interact with the Platform (e.g., pages visited, error messages);
• Functional Cookies: Remember your preferences and settings (e.g., language selection, game favorites);
• Advertising and Marketing Cookies: Deliver targeted advertisements based on your interests and track the effectiveness of marketing campaigns.

10.3 Third-Party Cookies

jilbay may allow third-party service providers (e.g., Google Analytics, Facebook Pixel) to place cookies on your device for analytics and advertising purposes. These third parties have their own privacy policies governing their use of your information.

10.4 Managing Cookies

You can control and delete cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. However, disabling essential cookies may affect your ability to use certain features of the jilbay platform. You can also manage cookie preferences through the cookie consent banner displayed when you first visit the Platform.

11. Children's Privacy

jilbay services are intended exclusively for individuals who are at least twenty-one (21) years of age. We do not knowingly collect, use, or disclose personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal information from a person under 21, we will take immediate steps to delete that information and terminate the associated account. If you believe we have collected information from a minor, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

jilbay reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will:

• Update the "Effective Date" at the top of this Policy;
• Notify you via email to the address associated with your account;
• Display a prominent notice on the jilbay platform.

Your continued use of the Platform after the updated Privacy Policy has been posted constitutes your acceptance of the changes. If you do not agree with the revised Policy, you must discontinue use of the Platform and close your account.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact us:

• Data Protection Officer Email: [email protected]
• Customer Support: Available 24/7 via live chat on the jilbay platform
• General Inquiries: [email protected]

We will make reasonable efforts to respond to all inquiries within thirty (30) days of receipt.

By using the jilbay platform, you acknowledge that you have read, understood, and agree to the collection, use, disclosure, and processing of your personal information as described in this Privacy Policy.