37jili Privacy Policy

37jili ("we", "us", "our") is committed to protecting the privacy and personal data of all users of the 37jili online gaming platform (the "Platform"). This Privacy Policy describes how 37jili collects, uses, stores, shares, and protects personal data in connection with your use of the Platform.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. It applies to all personal data processed by 37jili in connection with the Platform, regardless of whether such data is collected online, by telephone, or through any other means.

Please read this Privacy Policy carefully. If you do not agree with the practices described in this Policy, you should not use the 37jili Platform. For questions about this Policy or your personal data, please refer to the contact details in Section 14.

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, 37jili acts as the personal information controller in respect of the personal data collected through the Platform. This means that 37jili determines the purposes and means of processing your personal data.

Where 37jili engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, or customer support platforms — those providers act as personal information processors and are contractually bound to process data only in accordance with 37jili's instructions and applicable data protection law.

37jili has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the DPA and this Privacy Policy. You may contact the DPO through the contact details provided in Section 14 of this Policy.

37jili collects the following categories of personal data in connection with your use of the Platform:

37jili does not collect sensitive personal information as defined under the DPA (such as health data, political opinions, or religious beliefs) unless specifically required by law or with your explicit consent.

37jili collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access or use the Platform.
• Third-party sources: Identity and fraud-check data received from identity verification providers, payment processors (such as GCash and PayMaya), and fraud prevention agencies where necessary to comply with our legal obligations.
• Publicly available sources: In limited circumstances, 37jili may verify information against publicly available records to comply with anti-money laundering obligations.

37jili uses the personal data we collect for the following purposes:

• To create, manage, and maintain your 37jili account, including verifying your identity and age (21+ requirement) in accordance with Philippine gaming regulations.
• To process deposits and withdrawals via GCash, PayMaya, debit card, and Philippine bank transfers, and to maintain accurate transaction records in PHP.
• To provide customer support and respond to your enquiries, complaints, and feedback.
• To detect, investigate, and prevent fraud, money laundering, cheating, and other prohibited conduct on the Platform.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements, know-your-customer (KYC) obligations, and reporting obligations to relevant Philippine authorities.
• To personalise your experience on the Platform, including recommending games and promotions that may be relevant to you.
• To send you service-related communications, such as transaction confirmations, security alerts, and policy updates.
• To send you marketing communications about 37jili promotions, bonuses, and new games, where you have opted in to receive such communications.
• To monitor and analyse Platform usage for the purposes of improving our services, fixing technical issues, and developing new features.
• To support responsible gaming obligations, including monitoring gaming patterns that may indicate problem gambling behaviour and facilitating self-exclusion requests.

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

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine law, including AML regulations, KYC requirements, and regulatory reporting obligations.
• Legitimate interests: Processing necessary for 37jili's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

37jili does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya / Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions.
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and satisfy our regulatory obligations.
• Fraud prevention agencies: Organisations that assist 37jili in detecting and preventing fraudulent activity, money laundering, and other illegal conduct.
• IT and platform service providers: Cloud hosting, data storage, customer support software, and analytics providers who process data on 37jili's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Philippine government agencies, PAGCOR, the National Privacy Commission, and law enforcement bodies where disclosure is required by law or court order.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 37jili's business, your personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

All third-party processors engaged by 37jili are contractually required to implement appropriate technical and organisational security measures and to process personal data only in accordance with 37jili's documented instructions.

37jili retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and KYC record-keeping requirements under Philippine law.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by applicable financial regulations.
• Communications and support records: Retained for up to three (3) years from the date of the communication, unless a longer period is required for the resolution of a dispute or legal claim.
• Technical and usage data: Retained for up to twenty-four (24) months from collection, after which it is anonymised or deleted.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given.

When personal data is no longer required, 37jili will securely delete or anonymise it in accordance with our internal data disposal procedures.

37jili uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. Cookies are small text files placed on your device when you visit the Platform.

We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in to your 37jili account. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Analytics cookies: Collect anonymised data about how users interact with the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Security cookies: Help detect and prevent fraudulent activity, including bot traffic and account takeover attempts.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform, including your ability to stay logged in to your 37jili account. Refer to your browser's help documentation for instructions on managing cookie preferences.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 37jili:

• Right to be informed: The right to be told how your personal data is being collected and used, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data 37jili holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held about you.
• 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 retention obligations.
• Right to object: The right to object to 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, machine-readable format where processing is based on consent or contract.
• 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 prior processing.
• 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 37jili's Data Protection Officer using the contact details in Section 14. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

37jili implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 37jili Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls ensuring that only authorised 37jili personnel can access personal data, and only to the extent necessary for their role.
• Regular security assessments, vulnerability scanning, and penetration testing of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While 37jili takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your 37jili login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

The 37jili Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 37jili does not knowingly collect personal data from individuals under the age of 21.

If 37jili becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact 37jili support immediately so that we can investigate and take appropriate action.

Parents and guardians are encouraged to monitor the online activities of minors in their care and to make use of available parental control tools to prevent access to online gaming platforms.

37jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. The date at the top of this page indicates when the Policy was last revised.

Where changes are material, 37jili will provide reasonable advance notice by posting a prominent notice on the Platform or by sending a notification to your registered contact details. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

We encourage you to review this Privacy Policy periodically to stay informed about how 37jili protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 37jili, please contact our Data Protection Officer through any of the following channels:

Email: [email protected]

Support: [email protected]

Our Data Protection Officer will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.

For responsible gaming concerns, including self-exclusion requests and deposit limit adjustments, please visit our Responsible Gaming page or contact support directly.