- 1. About This Policy
- 2. Data We Collect
- 3. How We Collect Data
- 4. How We Use Your Data
- 5. Legal Basis for Processing
- 6. Who We Share Data With
- 7. International Data Transfers
- 8. Data Retention
- 9. Cookies and Tracking
- 10. Your Rights Under RA 10173
- 11. Data Security Measures
- 12. Children's Privacy
- 13. Third-Party Services
- 14. Changes to This Policy
- 15. Contact Our DPO
1. About This Privacy Policy
This Privacy Policy applies to all personal data collected and processed by Link JILI through the website linkjili.net and any related services, mobile-optimised interfaces, promotional communications, and customer support interactions. It applies to all registered members, prospective members who visit the site, and any person whose data we receive in connection with the operation of our platform.
Link JILI acts as the personal information controller (PIC) for the data described in this policy, meaning we determine the purposes and means of processing your personal data. Where third-party processors are used — for example, payment processors or identity verification providers — they act only under our instruction and within the scope of their contractual obligations to us.
By registering an account at Link JILI or by continuing to use our services after this policy is published, you acknowledge that you have read and understood this Privacy Policy. This document should be read alongside our Terms and Conditions, which govern the overall use of the Link JILI platform.
2. Personal Data We Collect
Link JILI collects the minimum personal data necessary to operate the platform lawfully, verify member identities, process payments, and comply with applicable Philippine regulations. The categories of personal data we collect include:
2.1 Account Registration Data
- Full legal name (as it appears on your government-issued ID)
- Date of birth
- Philippine mobile number
- Email address
- Username and encrypted password
- Residential address (required for full KYC verification)
2.2 Identity Verification (KYC) Data
- Government-issued Philippine ID number and document type (e.g., PhilSys, passport, UMID, SSS/GSIS ID, driver's licence, voter's ID)
- ID document images (front and back)
- Selfie or liveness check photograph taken during verification
- Tax Identification Number (TIN) where required by Philippine tax regulations
2.3 Financial Data
- GCash or Maya mobile wallet number (registered name must match account name)
- Bank account details where bank transfer is used (account name, account number, bank name)
- Transaction history: deposit amounts, dates, methods, withdrawal amounts, and destinations
- Betting and gaming activity records
2.4 Technical and Device Data
- IP address and approximate geographic location derived from IP
- Device type, operating system, and browser information
- Session timestamps and duration
- Referring URL and pages visited within the platform
2.5 Communications Data
- Records of customer support interactions (chat transcripts, email correspondence)
- Feedback and survey responses you voluntarily submit
- Promotional communication preferences (opt-in/opt-out status)
3. How We Collect Your Data
Link JILI collects personal data through the following channels:
- Directly from you: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
- Automatically through platform use: Technical data such as IP addresses, device identifiers, session logs, and cookies collected automatically when you access and interact with the Link JILI website.
- From third-party verification providers: Where we use regulated KYC (Know Your Customer) service providers to assist with identity verification, those providers may return data confirming or supplementing the information you have provided — such as confirmation that an ID document is genuine and unaltered.
- From payment processors: When you use GCash, Maya, or bank transfer services, our payment processors provide confirmation of transaction completion, account names, and related payment metadata necessary to process your transaction correctly.
4. How We Use Your Personal Data
Link JILI uses your personal data only for specific, legitimate purposes. We do not use your data for any purpose that is incompatible with the reason it was originally collected. The primary purposes for which we process your data are:
| Purpose | Data Used | Why Necessary |
|---|---|---|
| Account creation and management | Registration data, login credentials | To operate your account and provide platform access |
| Identity verification (KYC) | KYC documents, ID images, selfie | Regulatory compliance and fraud prevention |
| Processing deposits and withdrawals | Financial data, payment method details | Contract performance — enabling transactions |
| Fraud and AML screening | Transaction data, IP, device, behavioural patterns | Legal obligation under Philippine AML regulations |
| Customer support | Communications data, account history | Contract performance — resolving member issues |
| Promotions and bonuses | Account data, betting history, contact details | Administering offers you have opted into |
| Responsible gaming | Activity patterns, self-exclusion requests | Regulatory obligation and member welfare |
| Platform improvement | Aggregated, anonymised usage data | Legitimate interest in improving services |
| Legal and regulatory reporting | Identity data, financial transaction records | Compliance with Philippine law and licensing obligations |
Link JILI does not use your personal data to build profiles for sale to third-party advertisers, and we do not engage in automated decision-making that produces significant legal effects on members without human review.
5. Legal Basis for Processing
Under the Philippine Data Privacy Act of 2012, we are required to have a lawful basis for each category of personal data processing. The legal bases on which Link JILI relies are:
- Contractual necessity: Processing required to fulfil our contract with you — including account management, bet settlement, and payment processing.
- Legal obligation: Processing required to comply with Philippine law — including AML/CFT reporting obligations, tax requirements, gaming regulatory obligations, and data retention mandates.
- Legitimate interests: Processing for purposes that serve our legitimate business interests and do not override your fundamental rights — including fraud detection, platform security, and anonymised analytics for service improvement.
- Consent: Where we send you optional promotional communications by email or SMS, we do so only with your explicit consent, which you may withdraw at any time by updating your communication preferences in your account settings or by contacting support@linkjili.net.
6. Who We Share Your Data With
Link JILI does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the following limited circumstances:
6.1 Service Providers (Data Processors)
We engage regulated third-party companies to perform specific services on our behalf. These processors are contractually bound to handle your data only as we instruct and in compliance with RA 10173. Categories of processors include:
- Payment processors: GCash (Mynt), Maya (PayMaya Philippines), BancNet, and card scheme partners — to process deposits and withdrawals.
- KYC/identity verification providers: To assist with document authentication and age verification.
- Cloud infrastructure providers: For secure data hosting and platform delivery.
- Customer support platforms: Live chat and helpdesk systems used to manage support interactions.
- Game content providers: JILI Games and other licensed game suppliers receive necessary session data to operate games correctly within your account.
6.2 Regulatory and Law Enforcement Authorities
Link JILI may disclose personal data to Philippine government authorities — including PAGCOR, AMLC (Anti-Money Laundering Council), the National Privacy Commission, and law enforcement agencies — where required by applicable law, court order, or legitimate regulatory request.
6.3 Business Transfers
In the event of a merger, acquisition, or sale of all or part of Link JILI's business, personal data may be transferred as part of that transaction. You will be notified of any such transfer and the privacy terms applicable to your data under the new entity before the transfer takes effect.
7. International Data Transfers
The primary data infrastructure for Link JILI is located within or close to the Philippines, consistent with our Philippine-first operational model. In some cases, data may be processed by service providers whose technical infrastructure is located in other countries — for example, certain cloud hosting or KYC verification services.
Where personal data is transferred outside the Philippines, Link JILI ensures that appropriate safeguards are in place in accordance with the requirements of the National Privacy Commission. These safeguards include contractual data processing agreements that impose equivalent data protection obligations on the receiving party, and — where available — transfers to countries the NPC has recognised as providing adequate levels of data protection.
You may request information about the specific safeguards applicable to any international transfer involving your data by contacting our Data Privacy Officer at support@linkjili.net.
8. Data Retention
Link JILI retains your personal data only for as long as is necessary for the purposes described in this policy and to meet our legal and regulatory obligations. The following retention periods apply as standard:
- Active account data: Retained for the duration of your active membership and for a minimum of 5 years following account closure, in accordance with Philippine AML regulations and gaming licensing requirements.
- KYC documentation: Retained for a minimum of 5 years after the end of the member relationship, as required by the Anti-Money Laundering Act (RA 9160, as amended).
- Transaction records: Retained for a minimum of 5 years following each transaction, for AML and tax compliance purposes.
- Customer support records: Retained for 3 years after the interaction, for quality assurance and dispute resolution purposes.
- Promotional communication records: Retained for 2 years following the last interaction or opt-out, for marketing compliance and legal evidence purposes.
- Technical logs (IP, session data): Retained for up to 12 months for security, fraud detection, and platform diagnostics.
Where data is no longer required under any of these criteria, it is securely deleted or anonymised in accordance with NPC-approved practices.
9. Cookies and Tracking Technologies
Link JILI uses cookies and similar tracking technologies to operate the platform, improve performance, and analyse usage patterns. A cookie is a small text file stored on your device by your browser when you visit our site.
9.1 Types of Cookies We Use
- Strictly necessary cookies: Required for the platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled without impairing your ability to use the platform.
- Functional cookies: Remember your preferences — such as language, display settings, and last viewed markets — to provide a more personalised experience.
- Analytics cookies: Collect anonymised data about how members use the platform — pages visited, features used, and session duration — to help us improve performance and content.
- Security cookies: Used to detect and prevent fraudulent activity, bot behaviour, and unauthorised access attempts.
9.2 Managing Cookies
You can control the use of non-essential cookies through your browser settings. Most browsers allow you to block or delete cookies. Note that disabling certain cookies may affect the functionality of the Link JILI platform — for example, you may need to log in again on each visit if session cookies are blocked. Link JILI does not use third-party advertising cookies or share cookie data with ad networks.
10. Your Rights Under the Philippine Data Privacy Act
As a data subject under Republic Act No. 10173, you have the following rights regarding your personal data held by Link JILI. To exercise any of these rights, contact our Data Privacy Officer at support@linkjili.net. We will respond within 15 business days of receiving a verified request.
Right to Access
You may request a copy of the personal data Link JILI holds about you, including information on how it is being used, where it came from, and with whom it has been shared.
Right to Correction
If any of your personal data is inaccurate or incomplete, you have the right to have it corrected. Some corrections (e.g., name changes) require supporting documentation.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purposes collected, where you withdraw consent, or where processing was unlawful — subject to our legal retention obligations.
Right to Object
You may object to the processing of your data for direct marketing purposes at any time. You may also object to processing based on our legitimate interests, subject to a balancing test.
Right to Data Portability
You may request a copy of your data in a structured, commonly used, and machine-readable format to transfer to another service, where technically feasible.
Right to Lodge a Complaint
If you believe your data rights have been violated, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.
11. Data Security Measures
Link JILI takes the security of your personal data seriously and has implemented technical and organisational measures appropriate to the nature of the data we handle. These measures include:
- Encryption in transit: All data transmitted between your browser or device and the Link JILI servers is encrypted using TLS 1.3. This applies to login, payment transactions, account management, and all other platform interactions.
- Encryption at rest: Sensitive personal data — including identity documents and financial records — is encrypted at rest using AES-256 standard encryption.
- Access controls: Personal data is accessible only to Link JILI personnel who have a legitimate operational need. Access is granted on a least-privilege basis and is subject to role-based access control policies.
- Two-factor authentication (2FA): Available to all members and recommended as a standard account security practice.
- Regular security assessments: Link JILI conducts regular internal security reviews and periodic third-party penetration testing of its platform infrastructure.
- Incident response: In the event of a personal data breach that poses a real risk of serious harm to data subjects, Link JILI will notify affected members and the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.
While Link JILI takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own account credentials. If you suspect your account has been compromised, contact our support team immediately.
12. Children's Privacy
Link JILI's services are intended exclusively for adults aged 21 years and above, in compliance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under 21 years of age. If we become aware that a person under 21 has registered an account, we will immediately suspend the account, delete any associated personal data to the extent not required for legal compliance purposes, and forfeit any balance in accordance with our Terms and Conditions.
If you are a parent or guardian and believe that your child may have provided personal data to Link JILI without your consent, please contact us at support@linkjili.net immediately so that we can take appropriate action.
13. Third-Party Services and Links
The Link JILI platform may reference or integrate with third-party services — such as payment gateways and game providers — which operate under their own privacy policies. Link JILI is not responsible for the privacy practices of these third parties once data leaves our direct control, except to the extent governed by our contractual data processing agreements with those parties.
Links to external websites or services are not present in the navigation or content of the Link JILI platform. If you encounter a link to an external site in any context related to Link JILI, exercise caution and verify its legitimacy before submitting any personal information.
14. Changes to This Privacy Policy
Link JILI may update this Privacy Policy from time to time to reflect changes in applicable law, our business practices, or the services we provide. When material changes are made, we will notify registered members by email to the address on file and by a prominent notice on the platform at least 7 days before the changes take effect.
The "Last updated" date at the top of this document reflects when the current version became effective. We encourage you to review this policy periodically. Previous versions are available on request by contacting our Data Privacy Officer.
Continued use of Link JILI after the effective date of any update to this policy constitutes your acceptance of the revised terms. If you do not agree with the updated policy, you should discontinue use of the platform and contact us to close your account.
15. Contact Our Data Privacy Officer
Link JILI has designated a Data Privacy Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests regarding your personal data, you can reach the DPO through the following channels: