phjill Privacy Policy

1. Introduction

1.1 phjill is committed to protecting the privacy and personal data of all users of the phjill Platform. We understand that Filipino players trust us with sensitive personal and financial information, and we take that responsibility seriously.

1.2 This Privacy Policy has been prepared in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. It also reflects best practices under internationally recognised data protection frameworks.

1.3 phjill acts as the Personal Information Controller in respect of the personal data you provide to us. This means phjill determines the purposes and means of processing your personal data.

1.4 If you have any questions about how phjill handles your personal data, please contact our Data Protection Officer using the details provided in Section 13 of this Policy.

2. Personal Data We Collect

2.1 phjill collects the following categories of personal data from users of the Platform:

2.1 Identity & Contact Data

Full legal name (first name, middle name, last name);
Date of birth;
Gender;
Residential address (including barangay, city/municipality, province);
Email address;
Mobile phone number.

2.2 Identity Verification Data (KYC)

Government-issued photo ID (e.g., Philippine passport, driver's licence, PhilSys National ID, SSS/GSIS ID);
Proof of address documents (e.g., utility bill, bank statement);
Selfie or facial image for identity verification purposes;
Tax Identification Number (TIN) where required by applicable regulations.

2.3 Financial Data

GCash account details (registered mobile number and name);
PayMaya / Maya account details;
Bank account details (account name, account number, bank name) for bank transfer transactions;
Debit card details (card number masked, expiry date, cardholder name);
Transaction history (deposits, withdrawals, wagers, winnings).

2.4 Gaming & Behavioural Data

Game play history, bet amounts, game preferences;
Bonus and promotion usage history;
Session duration and frequency of play;
Responsible gaming tool usage (deposit limits, self-exclusion requests, etc.).

2.5 Technical & Device Data

IP address and approximate geolocation;
Device type, operating system, and browser type;
Unique device identifiers;
Log data (access times, pages visited, errors encountered).

2.6 Communications Data

Records of communications with phjill customer support (live chat transcripts, email correspondence);
Survey responses and feedback submitted to phjill.

Sensitive Personal Information: Certain data we collect — such as government ID numbers and financial account details — constitutes sensitive personal information under the Data Privacy Act of 2012. phjill applies heightened security measures to the processing of such data and collects it only to the extent strictly necessary for regulatory compliance and service delivery.

3. How We Collect Your Data

3.1 phjill collects personal data through the following means:

Direct collection: Data you provide when registering a phjill account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
Automated collection: Data collected automatically when you access the phjill Platform, including through cookies, web beacons, and server logs (see Section 7);
Third-party sources: Data received from identity verification service providers, payment processors (e.g., GCash, PayMaya, banks), fraud prevention services, and analytics providers, where permitted by applicable law.

4. How We Use Your Personal Data

4.1 phjill uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, and login data
Identity verification (KYC) and age verification	Identity verification documents, date of birth
Processing deposits and withdrawals	Financial data, identity data
Providing gaming services and personalising your experience	Gaming and behavioural data, technical data
Fraud prevention, security monitoring, and anti-money laundering compliance	All categories as necessary
Responsible gaming monitoring and intervention	Gaming data, behavioural data, communications data
Customer support and dispute resolution	Identity, contact, and communications data
Marketing and promotional communications (with consent)	Contact data, gaming preferences
Legal and regulatory compliance	All categories as required by law
Platform improvement and analytics	Technical data, gaming data (aggregated/anonymised where possible)

4.2 phjill will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5. Legal Basis for Processing

5.1 phjill processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

Contractual necessity: Processing required to perform our contract with you (i.e., to provide the phjill gaming services you have registered for);
Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, KYC requirements, and PAGCOR regulatory requirements;
Legitimate interests: Processing necessary for phjill's legitimate interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests;
Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

6.1 phjill does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

Payment processors: GCash, PayMaya, banks, and other payment service providers, for the purpose of processing your deposits and withdrawals;
Identity verification providers: Third-party KYC and age verification service providers engaged by phjill;
Game software providers: Game developers and live casino operators whose games are available on the phjill Platform, to the extent necessary for game delivery and fairness auditing;
Fraud prevention and security services: Third-party providers engaged to detect and prevent fraud, money laundering, and other illegal activity;
Analytics providers: Service providers that help phjill understand Platform usage and improve the player experience (data is shared in aggregated or pseudonymised form where possible);
Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent authorities, where required by law or court order;
Professional advisers: Lawyers, auditors, and other professional advisers engaged by phjill, subject to professional confidentiality obligations.

6.2 All third parties with whom phjill shares personal data are required to process such data in accordance with applicable data protection laws and phjill's data processing requirements.

Cross-Border Transfers: Some of phjill's service providers may be located outside the Philippines. Where personal data is transferred internationally, phjill ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012 and NPC regulations.

7. Cookies & Tracking Technologies

7.1 phjill uses cookies and similar tracking technologies on the phjill Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and improve your experience.

7.2 phjill uses the following types of cookies:

Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled. They include session cookies that keep you logged in to your phjill account.
Functional cookies: Remember your preferences (e.g., language, game lobby layout) to personalise your experience.
Analytics cookies: Help phjill understand how players use the Platform so we can improve it. Data collected is aggregated and does not identify individual players.
Security cookies: Used to detect and prevent fraudulent activity and protect your phjill account.

7.3 You can control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the phjill Platform.

8. Data Retention

8.1 phjill retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

8.2 As a general guide, phjill applies the following retention periods:

Account and KYC data: Retained for the duration of your account and for a minimum of 5 years after account closure, in compliance with AML and PAGCOR record-keeping requirements;
Transaction records: Retained for a minimum of 5 years from the date of the transaction;
Customer support communications: Retained for 3 years from the date of the communication;
Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter as evidence of consent;
Technical and log data: Typically retained for 12 months, unless required for longer for security or legal purposes.

8.3 When personal data is no longer required, phjill will securely delete or anonymise it in accordance with our data disposal procedures.

9. Data Security

Security Commitment: phjill implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure.

9.1 The security measures phjill employs include, but are not limited to:

256-bit SSL/TLS encryption for all data transmitted between your device and the phjill Platform;
Encryption at rest for sensitive personal and financial data stored on phjill servers;
Multi-factor authentication (MFA) options for player account access;
Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
Regular security audits and penetration testing conducted by independent security specialists;
Intrusion detection and prevention systems monitoring the Platform 24/7;
Staff training on data protection obligations and secure data handling practices.

9.2 While phjill takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phjill will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

9.3 You are responsible for keeping your phjill login credentials confidential. If you suspect that your account has been accessed without your authorisation, please contact phjill customer support immediately.

10. Your Data Privacy Rights

10.1 Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by phjill:

Right to be informed: You have the right to be informed of how your personal data is being collected and processed, which this Privacy Policy fulfils;
Right of access: You have the right to request a copy of the personal data phjill holds about you and information about how it is processed;
Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data phjill holds about you;
Right to erasure or blocking: You have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phjill's legal retention obligations;
Right to object: You have the right to object to the processing of your personal data, including for direct marketing purposes. Where processing is based on legitimate interests, phjill will cease processing unless compelling legitimate grounds exist;
Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible;
Right to withdraw consent: Where processing is based on your consent, you have 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: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe phjill has violated your data privacy rights.

10.2 To exercise any of the above rights, please submit a written request to phjill's Data Protection Officer using the contact details in Section 13. phjill will respond to all verified requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 30 days, and you will be notified accordingly.

10.3 phjill may need to verify your identity before processing a data rights request to ensure that personal data is not disclosed to an unauthorised person.

Opting Out of Marketing: If you no longer wish to receive promotional emails or SMS messages from phjill, you can unsubscribe at any time by clicking the unsubscribe link in any marketing email, by adjusting your communication preferences in your phjill account settings, or by contacting customer support directly.

11. Children's Privacy

21+ Only: The phjill Platform is strictly intended for individuals who are at least 21 years of age. phjill does not knowingly collect personal data from individuals under 21. If phjill becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed.

11.1 If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to phjill, please contact us immediately at the details provided in Section 13 so that we can take appropriate action.

11.2 phjill conducts age verification checks on all new accounts and may request documentary proof of age at any time. Any winnings accrued by an underage player will be forfeited in accordance with phjill's Terms and Conditions.

12. Changes to This Privacy Policy

12.1 phjill may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The updated Policy will be posted on phjill.net with a revised effective date.

12.2 Where changes are material, phjill will notify registered players via email or in-platform notification prior to the changes taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how phjill protects your personal data.

12.3 Your continued use of the phjill Platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the revised Policy, you should cease using the Platform and may request account closure in accordance with phjill's Terms and Conditions.

13. Contact Our Data Protection Officer

13.1 If you have any questions, concerns, or requests relating to this Privacy Policy or phjill's handling of your personal data, please contact our Data Protection Officer:

phjill Data Protection Officer
Email: [email protected]
General Support: [email protected]
Available: Monday to Friday, 9:00 AM – 6:00 PM (Philippine Standard Time)
Response time: Within 5 business days for DPO enquiries; within 24 hours for general support.

13.2 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 is the government body responsible for administering and implementing the Data Privacy Act of 2012.

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