jiluka Privacy Policy

1 Introduction

jiluka ("jiluka," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the jiluka online gaming platform at jiluka.app (the "Platform"). This Privacy Policy ("Policy") explains how we collect, use, store, share, and protect your personal information when you access or use the Platform and all associated services.

This Policy applies to all users of the jiluka Platform, including registered players, visitors who browse the Platform without registering, and individuals who contact our customer support team. It should be read together with our Terms and Conditions and Responsible Gaming Policy.

jiluka processes personal data in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. We are committed to upholding the principles of transparency, legitimate purpose, and proportionality in all data processing activities.

2 Data Controller

jiluka is the data controller responsible for the personal information collected through the Platform. As data controller, jiluka determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable data protection laws.

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

3 Personal Data We Collect

jiluka collects the following categories of personal data from players and Platform users:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (for age verification – players must be 21 years or older)
• Nationality and country of residence
• Registered email address
• Philippine mobile number
• Residential address

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or live photo for identity matching purposes
• Source of funds documentation where required by anti-money laundering regulations

3.3 Financial and Transaction Data

• GCash account details, PayMaya account details, or bank account information (BPI, BDO, Metrobank) used for deposits and withdrawals
• Credit and debit card details (card number is masked; we do not store full card numbers)
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Wagering history and game activity records

3.4 Technical and Usage Data

• IP address and approximate geolocation data
• Device type, operating system, and browser information
• Session duration, pages visited, and features used on the Platform
• Login timestamps and access logs

3.5 Communications Data

• Records of communications between you and jiluka customer support
• Feedback, complaints, and survey responses submitted to jiluka
• Marketing preferences and communication opt-in or opt-out records

4 How We Collect Your Data

jiluka collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from GCash, PayMaya, BPI, BDO, Metrobank, and card payment processors.
• Publicly available sources: Information from public databases used to verify identity or comply with anti-money laundering obligations.

5 How We Use Your Personal Data

jiluka uses your personal data for the following purposes:

6 Legal Basis for Processing

jiluka processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you agreed to when registering your jiluka account, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax obligations.
• Legitimate interests: Processing carried out for jiluka's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications. You may withdraw your consent at any time by contacting us or updating your account preferences.

7 Sharing Your Personal Data

jiluka does not sell, rent, or trade your personal data to third parties. We may share your personal information with the following categories of recipients only where necessary and on a strictly need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and card payment networks, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist jiluka in verifying player identities and complying with age verification and anti-money laundering requirements.
• Game software providers: Licensed game developers whose titles are available on the jiluka Platform may receive limited technical data necessary to deliver their games.
• Fraud prevention and security partners: Services that help jiluka detect and prevent fraudulent activity, account takeovers, and bonus abuse.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or court order.
• Professional advisers: Legal counsel, auditors, and accountants who are bound by professional confidentiality obligations.

8 Data Retention

jiluka retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Active account data: Retained for the duration of your account relationship with jiluka.
• Transaction and wagering records: Retained for a minimum of five (5) years following the date of the transaction, in accordance with Philippine anti-money laundering regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the last transaction, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the interaction.
• Marketing preferences: Retained until you withdraw your consent or close your account.

Upon expiry of the applicable retention period, jiluka will securely delete or anonymise your personal data in accordance with our internal data disposal procedures.

9 Data Security

jiluka implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the jiluka Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls ensuring that only authorised jiluka personnel can access personal data on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Two-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Staff training on data protection obligations and secure data handling practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jiluka will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

10 Cookies and Tracking Technologies

jiluka uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver relevant content. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Performance and analytics cookies: Help us understand how players interact with the Platform so we can improve its performance and usability.
• Functional cookies: Remember your preferences, such as language settings and display options, to personalise your experience.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These are only set with your consent.

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the jiluka Platform. For more information on managing cookies, refer to your browser's help documentation.

11 Your Data Protection Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by jiluka:

• Right to be informed: The right to know whether jiluka holds personal data about you and how it is being processed.
• Right of access: The right to request a copy of the personal data jiluka holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal and regulatory retention obligations.
• 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 data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• 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) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within thirty (30) days. We may need to verify your identity before processing your request.

12 Minors and Age Restriction

The jiluka Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. jiluka does not knowingly collect personal data from individuals under the age of 21.

If jiluka becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the jiluka Platform, please contact us immediately at [email protected].

13 Changes to This Privacy Policy

jiluka reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. The date of the most recent revision is indicated at the top of this page.

Where changes are material, jiluka will notify registered players via the email address on file or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the jiluka Platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Policy periodically to stay informed about how jiluka protects your personal data.

14 Contact Us

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

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have not been respected. For more information about your rights and jiluka's responsible gaming commitments, please visit our Responsible Gaming page or review our Terms & Conditions.