366jili Privacy Policy

1. Who We Are

This Privacy Policy is issued by 366jili ("366jili," "we," "us," or "our"), the operator of the online casino and sports betting platform accessible at https://366jili.app (the "Platform"). 366jili operates in alignment with the Philippine Amusement and Gaming Corporation (PAGCOR) online gaming framework and is committed to protecting the personal data of all users who access the Platform.

For the purposes of the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, 366jili acts as the personal information controller (PIC) for all personal data collected through the Platform.

2. Data We Collect

366jili collects personal data through various interactions on the Platform. The categories of data collected, and the context in which they are collected, are outlined in the table below.

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, or religious beliefs unless specifically required by law or with your explicit consent. We do not knowingly collect data from individuals under 21 years of age.

3. How We Use Your Data

366jili uses your personal data strictly for the purposes described in this section. We do not use your data for any purpose that is incompatible with the original collection purpose without your prior consent.

• Account Management: To create, maintain, and administer your 366jili player account, including identity verification, age verification (21+ requirement), and account security.
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, BDO, BPI, Metrobank, UnionBank, and other supported payment channels; to maintain accurate financial records; and to detect and prevent fraudulent transactions.
• Platform Delivery: To provide access to games, live dealer tables, sportsbook events, and all other features of the 366jili Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 live chat and email support channels.
• Regulatory Compliance: To comply with obligations under Philippine law, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and PAGCOR-aligned gaming regulations. This includes filing required reports with the Anti-Money Laundering Council (AMLC) where applicable.
• Responsible Gaming: To monitor gaming patterns, enforce deposit limits, process self-exclusion requests, and send responsible gaming reminders where our systems detect potentially concerning behavior.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only if you have opted in to receive such communications. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, test new features, improve game performance, and enhance the overall player experience through aggregated and anonymized analytics data.
• Security: To detect, investigate, and prevent fraud, cheating, multi-accounting, money laundering, and other prohibited activities that violate our Terms and Conditions.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 366jili processes your personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and 366jili — specifically, to operate your account, process bets and transactions, and provide the gaming services you have signed up for.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML reporting obligations, age verification requirements, and regulatory directives from PAGCOR or the National Privacy Commission (NPC).
• Legitimate Interests: Processing is necessary for 366jili's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service quality improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and any processing of sensitive personal information (where applicable), we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

5. Cookies & Tracking Technologies

366jili uses cookies and similar technologies to operate the Platform, remember your preferences, and analyze how players interact with our services. By continuing to use the Platform, you consent to the use of cookies as described below.

We use the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable core features such as session management, login state, and security verification. You cannot opt out of these cookies without disabling the Platform entirely.
• Functional Cookies: These remember your preferences such as language settings, display options, and game lobby configurations. Disabling them may affect your user experience.
• Analytical / Performance Cookies: We use anonymized analytics data to understand how players navigate the Platform, which games are most popular, and where technical issues occur. This data is aggregated and does not identify individual users.
• Responsible Gaming Cookies: These cookies track session duration and gaming frequency to support the responsible gaming tools we offer, including session time reminders and reality checks.

We do not use third-party advertising cookies or allow external advertisers to place tracking technologies on the 366jili Platform.

6. Data Sharing & Disclosure

366jili does not sell, rent, or share your personal data with third parties for their own commercial or marketing purposes. Your data may be shared in the following limited circumstances:

• Payment Processors: We share necessary financial data (such as account name, amount, and transaction reference) with payment partners including GCash, PayMaya, BDO, BPI, Metrobank, UnionBank, and cryptocurrency processing providers solely to facilitate your transactions.
• Identity Verification Providers: We work with third-party KYC/AML service providers to verify the identity and age of players. These providers process your ID documents under strict data processing agreements and are prohibited from using your data for any other purpose.
• Game Providers: Certain technical data (such as a pseudonymous player ID and bet results) may be shared with our game software providers to operate the games you play. These providers do not receive your full identity information.
• Regulatory Authorities: We are required by Philippine law to share data with authorities such as the AMLC, PAGCOR, and the National Privacy Commission in specific circumstances, including when investigating suspicious financial activity or responding to official requests.
• Legal Proceedings: We may disclose your personal data if required by a valid court order, subpoena, or other legal process under Philippine law.
• Business Transfers: In the unlikely event of a merger, acquisition, or sale of 366jili's business, your personal data may be transferred as part of that transaction. You will be notified via the Platform of any such change and the new entity's privacy terms.

7. International Data Transfers

Some of 366jili's service providers and game technology partners may be located outside the Philippines. Where personal data is transferred to a country that may not provide the same level of data protection as Philippine law, 366jili ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by the National Privacy Commission (NPC) or equivalent international frameworks.
• Data processing agreements that require the overseas recipient to apply security and confidentiality standards equivalent to those required under the Data Privacy Act of 2012.
• Binding corporate rules where applicable for intra-group transfers.

By using the 366jili Platform, you acknowledge that your personal data may be processed in other countries as part of the normal operation of our services. We take all reasonable steps to ensure your data remains protected regardless of where it is processed.

8. Data Retention

366jili retains personal data for as long as necessary to fulfil the purposes outlined in this Policy, and no longer. Specific retention periods are guided by legal obligations, regulatory requirements, and legitimate business needs.

• Active Account Data: Retained for the full duration of your active account relationship with 366jili, plus an additional period post-closure as required by law.
• Financial Transaction Records: Retained for a minimum of 5 years from the date of the transaction, in accordance with Philippine AML regulations and tax record-keeping requirements.
• KYC / Identity Documents: Retained for a minimum of 5 years from the date of verification or from account closure, whichever is later.
• Customer Support Communications: Retained for 3 years from the date of the final communication in each support case.
• Marketing Consent Records: Retained until consent is withdrawn and for a further 1 year thereafter to demonstrate prior consent compliance.
• Technical / Log Data: Retained for up to 12 months for security monitoring and platform performance purposes, then anonymized or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 366jili's data disposal procedures.

9. Your Data Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights as a data subject. 366jili is committed to honoring these rights within the timeframes prescribed by law.

To exercise any of these rights, contact our Data Protection Officer via the live chat on the Platform or at the email address listed in Section 14 of this Policy. We will acknowledge your request within 5 business days and respond fully within 15 business days. In complex cases, we may extend this period by a further 15 days with prior notice to you.

10. Children & Minors

The 366jili Platform is strictly intended for adults aged 21 years and older. This minimum age requirement applies to all users in the Philippines regardless of the type of game or activity on the Platform.

Parents and guardians who believe that a minor may have accessed the 366jili Platform or provided personal data to us are urged to contact our support team immediately via live chat. We take underage access concerns extremely seriously and will investigate and act on all such reports promptly.

366jili recommends that parents and guardians use parental control software to restrict minors' access to online gaming and gambling platforms. We support the responsible gaming mission of protecting young people from the potential harms of online gambling.

11. Data Security

366jili implements a comprehensive set of technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our security framework includes:

• Encryption: All data transmitted between your device and the 366jili Platform is protected using TLS 1.3 (Transport Layer Security). Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within 366jili's systems is restricted on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular security training.
• Two-Factor Authentication: 366jili supports and encourages the use of two-factor authentication (2FA) for all player accounts. Enabling 2FA significantly reduces the risk of unauthorized access to your account.
• Penetration Testing: Our Platform undergoes regular third-party security assessments, including penetration testing and vulnerability scanning, to identify and remediate potential security risks.
• Fraud Detection Systems: Automated systems monitor for suspicious login activity, unusual transaction patterns, and other indicators of account compromise in real time.
• Incident Response: 366jili maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) within 72 hours and affected individuals without undue delay, as required by law.

While 366jili takes all reasonable precautions to protect your data, no internet-based platform can guarantee absolute security. You play an important role in keeping your account secure by using a strong, unique password and not sharing your login credentials with anyone.

12. Third-Party Services

The 366jili Platform may contain links to third-party content or integrate with third-party services, including payment gateways such as GCash and PayMaya. This Privacy Policy applies solely to data processed by 366jili. We are not responsible for the privacy practices or content of any third-party services.

When you interact with a third-party service through the Platform — for example, when completing a GCash payment — that interaction is governed by the third party's own privacy policy. We encourage you to review the privacy policies of any third-party service you use in connection with your 366jili account.

All third-party service providers engaged by 366jili as data processors are required to sign data processing agreements that ensure compliance with the Data Privacy Act of 2012 and restrict their use of your data to the purposes for which it was shared.

13. Changes to This Policy

366jili reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or Platform features. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Display a prominent notice on the Platform notifying users of the update.
• Where practicable, send a notification to your registered email address summarizing the key changes.

Your continued use of the 366jili Platform following the effective date of a revised Privacy Policy constitutes your acknowledgment of and agreement to the updated terms. If you do not agree with the revised Policy, you should discontinue use of the Platform and contact us to close your account.

We recommend reviewing this Privacy Policy at least once every three months to stay informed of how we handle your personal data. All previous versions of this Policy are available upon request from our Data Protection Officer.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 366jili handles your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 through the chat interface on the 366jili Platform. Our support team is staffed by Filipino-English professionals who can assist with privacy-related concerns during Philippine peak hours with an average response time of under 2 minutes.
• Data Protection Officer (Email): [email protected] — please include "Privacy Request" in the subject line of your message. Plain text address only — not a clickable link.

When submitting a data rights request, please include your registered account username, a clear description of your request or concern, and any relevant reference numbers or screenshots. This will help our DPO process your request as efficiently as possible within the 15-business-day response window.