Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes the privacy practices of jilicr ("jilicr," "we," "us," "our") with respect to personal information collected from users ("Player," "User," "you") of the online gaming platform operated at jilicr.cam (the "Platform").

jilicr operates in the Republic of the Philippines and is committed to full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and applicable issuances of the National Privacy Commission (NPC). This Policy is intended to be read alongside jilicr's Terms and Conditions, which are available at jilicr.cam/terms-conditions.

By registering for a jilicr account, accessing the Platform, or using any of its services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal information as described herein. If you do not agree to this Policy, you must not use the Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, jilicr acts as the Personal Information Controller (PIC) in respect of all personal data collected through the Platform. As PIC, jilicr determines the purposes and means of processing personal information and is responsible for ensuring that all processing activities comply with applicable Philippine privacy law.

Where jilicr engages third-party service providers to process personal data on its behalf — such as payment processors, KYC verification services, and cloud infrastructure providers — those entities act as Personal Information Processors (PIP) and are contractually bound by data processing agreements that impose security and confidentiality obligations consistent with this Policy and the requirements of the DPA.

jilicr has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the DPA. The DPO may be contacted through the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

jilicr collects the following categories of personal information from players on the Platform:

jilicr does not knowingly collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance purposes. Sensitive data — such as government ID numbers and biometric identifiers contained in identity documents — is processed solely for KYC purposes and is subject to enhanced security controls.

4. How We Collect Personal Data

jilicr collects personal information through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in a promotion, or update your account settings.
• Automatically through the Platform: Technical and usage data is collected automatically when you access the Platform via browser or mobile device, using cookies, server logs, and similar tracking technologies as described in Section 10.
• From third-party identity verification providers: Where jilicr uses licensed KYC and AML screening services, those providers may supply supplementary identity data obtained from their own databases (e.g., sanctions list screening results, PEP status checks) as part of the verification process.
• From payment processors: Payment service providers confirm transaction status and may supply anonymized transaction metadata required for reconciliation and fraud monitoring.

5. Purpose & Legal Basis for Processing

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

5.1 Contractual Necessity

Processing is necessary for the performance of the contract between you and jilicr (your account agreement and Terms and Conditions), specifically to: create and manage your account; process deposits and withdrawals; provide access to games and betting services; enforce bonus terms; and communicate account-related updates.

5.2 Legal Obligation

jilicr is required by Philippine law to collect and retain certain personal data, including for: identity verification under PAGCOR licensing conditions; Anti-Money Laundering Act (R.A. 9160, as amended) compliance; age verification (21+ requirement); financial transaction record-keeping; and tax reporting obligations.

5.3 Legitimate Interests

jilicr processes certain data on the basis of its legitimate interests, where those interests are not overridden by your fundamental privacy rights. These legitimate interests include: fraud detection and prevention; platform security and abuse prevention; responsible gaming monitoring; service improvement through aggregated analytics; and marketing of jilicr's own services to existing players.

5.4 Consent

Where processing is not covered by the bases above — for example, certain optional personalization features or third-party marketing partnerships — jilicr will seek your explicit consent before processing. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

jilicr does not sell your personal information. We share personal data only in the following strictly defined circumstances:

6.1 Service Providers (Personal Information Processors)

jilicr engages trusted third-party providers who process personal data exclusively on our behalf and under our instruction. Categories of such providers include: payment gateway operators (GCash, PayMaya, bank partners); KYC and AML verification service providers; cloud hosting and data centre infrastructure providers; fraud prevention and cybersecurity services; and customer support platform operators. All such providers are bound by data processing agreements requiring compliance with the DPA.

6.2 Regulatory Authorities

jilicr will disclose personal information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue, or any other competent Philippine authority where required to do so by law, regulation, court order, or legal process.

6.3 Business Transfers

In the event of a merger, acquisition, asset sale, or reorganization of jilicr's business, personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material changes to how your data is processed as a result.

6.4 Protection of Rights

jilicr may disclose personal information where we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of jilicr, its players, or the public — for example, in connection with fraud investigation, cheating enforcement, or legal claims.

7. International Data Transfers

Some of jilicr's third-party service providers — including cloud infrastructure providers and game software licensors — may process personal data outside of the Philippines. Where such international transfers occur, jilicr ensures that appropriate safeguards are in place in accordance with Section 21 of the Data Privacy Act of 2012 and NPC implementing regulations, including: contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law; assessments of the recipient country's data protection framework; and, where required, registration of the cross-border transfer arrangement with the NPC.

jilicr does not transfer personal data to jurisdictions that have not demonstrated adequate levels of data protection without implementing supplementary safeguards approved by the NPC.

8. Data Retention

jilicr retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to applicable legal retention requirements. Key retention periods are as follows:

• Account and identity data: Retained for the duration of your account plus five (5) years after account closure, as required by PAGCOR licensing conditions and AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years following the transaction date, in compliance with the Anti-Money Laundering Act of the Philippines.
• KYC documentation: Retained for five (5) years following the completion of the business relationship (account closure), per AMLC requirements.
• Customer support records: Retained for three (3) years following resolution of the relevant support interaction.
• Technical and usage data: Aggregated analytics data is retained for up to two (2) years; individual-level session logs are retained for twelve (12) months.
• Marketing consent records: Retained until consent is withdrawn, plus twelve (12) months thereafter as evidence of prior consent status.

Upon expiry of the applicable retention period, personal data is securely deleted using industry-standard data destruction methods, or anonymised such that it can no longer be linked to any identifiable individual.

9. Security Measures

jilicr implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption: All data in transit between your device and jilicr's servers is encrypted using TLS 1.2 or higher. Sensitive data at rest — including payment credentials and identity document data — is encrypted using AES-256 encryption.
• Access controls: Access to personal data within jilicr's systems is restricted to authorised personnel on a need-to-know basis, enforced through role-based access controls and multi-factor authentication requirements for all internal system access.
• Infrastructure security: jilicr's Platform is hosted on enterprise-grade cloud infrastructure with continuous uptime monitoring, DDoS protection, web application firewall (WAF) coverage, and regular security vulnerability assessments.
• Incident response: jilicr maintains a documented data breach response plan. In the event of a personal data breach that is likely to harm your rights and interests, jilicr will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by the DPA.
• Staff training: All jilicr personnel who handle personal data undergo regular data privacy training and are subject to contractual confidentiality obligations.

While jilicr takes every reasonable precaution to protect your personal data, no system can be completely impervious to all potential threats. We encourage you to also take your own security precautions — including using a strong, unique password for your jilicr account and enabling two-factor authentication.

10. Cookies & Tracking Technologies

The jilicr Platform uses cookies and similar tracking technologies to enable essential functionality, remember your preferences, analyse usage patterns, and improve the overall player experience. The following types of cookies are used on the Platform:

10.1 Strictly Necessary Cookies

These cookies are essential to the operation of the Platform and cannot be disabled. They include session management cookies that keep you logged in during your gaming session, security cookies that help detect and prevent fraud, and cookies that remember your language and region preferences.

10.2 Performance & Analytics Cookies

These cookies collect aggregated, anonymised information about how players use the Platform — such as which pages are most visited, how long sessions last, and where users tend to leave the site. This data is used exclusively to improve Platform performance and usability. No individually identifiable information is shared with third-party analytics providers.

10.3 Functional Cookies

Functional cookies remember choices you make — such as your preferred game lobby layout, notification settings, or responsible gaming limits — to personalise your jilicr experience across sessions.

10.4 Cookie Management

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality — in particular, disabling strictly necessary cookies will prevent you from maintaining an active login session. A cookie preference centre is accessible through the Platform settings upon login.

11. Minors

If jilicr becomes aware that personal data has been collected from an individual who is under 21 years of age, that data will be immediately and permanently deleted and the associated account will be suspended. Parents or guardians who believe a minor has registered on the jilicr Platform should contact our Data Protection Officer immediately using the contact details in Section 15.

jilicr employs age verification checks as part of the KYC process and monitors account behaviour for indicators of underage access. Any suspicion of underage play is treated as a high-priority compliance matter and investigated without delay.

12. Exercising Your Data Rights

To exercise any of the data rights described in this Policy and under the Data Privacy Act of 2012, you may submit a formal request to jilicr's Data Protection Officer using the contact details in Section 15. All data rights requests must be submitted by the account holder and will require identity verification before processing to ensure your data is not disclosed to, corrected by, or deleted at the request of an unauthorised party.

jilicr will respond to all valid data rights requests within fifteen (15) business days of receipt and verification. Where a request is complex or voluminous, we may extend this period by a further fifteen business days and will inform you of the extension within the initial period. jilicr does not charge a fee for data rights requests unless they are manifestly unfounded, excessive, or repetitive, in which case a reasonable administrative fee may apply.

Where a request cannot be fulfilled — for example, because retention of the data is required by law — jilicr will explain the basis for declining the request and inform you of your right to escalate the matter to the National Privacy Commission.

13. Privacy Complaints

If you believe that jilicr has handled your personal data in a manner that is inconsistent with this Policy or with your rights under the Data Privacy Act of 2012, you are entitled to lodge a formal complaint. The process is as follows:

1. Internal complaint: Submit your complaint in writing to jilicr's Data Protection Officer (contact details in Section 15). jilicr will acknowledge receipt within 3 business days and provide a substantive response within 15 business days.
2. Escalation to NPC: If you are not satisfied with jilicr's response, or if jilicr fails to respond within the required timeframe, you have the right to file a complaint directly with the National Privacy Commission of the Philippines through its official channels. The NPC is the independent authority responsible for enforcing the Data Privacy Act.

jilicr takes all privacy complaints seriously and is committed to resolving them fairly and transparently in accordance with NPC-prescribed complaint handling standards.

14. Changes to This Policy

jilicr reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, business practices, or Platform features. When material changes are made — meaning changes that significantly affect how your personal data is processed or your rights in relation to it — jilicr will provide advance notice of at least seven (7) days via email to your registered address and by posting a prominent notice on the Platform.

Minor updates, such as typographical corrections or clarifications that do not affect the substance of the Policy, will be posted with an updated effective date. The most current version of this Policy is always accessible at jilicr.cam/privacy-policy. Continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Policy.

15. Contact Our Data Protection Officer

For all privacy-related enquiries, data rights requests, and formal complaints, you may contact jilicr's designated Data Protection Officer through the following channels:

• Email: [email protected] — Please use the subject line "Data Privacy Request" for faster routing to the DPO team.
• Live Chat: 24/7 live chat support is available directly on the jilicr Platform. For privacy-specific matters, state "Data Protection" at the start of your chat to be connected with a privacy-trained agent.
• Response time: The DPO team acknowledges all privacy enquiries within 3 business days and aims to fully resolve them within 15 business days.

jilicr's customer service team serves Filipino players across all regions of the Philippines — Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond — in English, around the clock, 365 days per year. Your privacy questions will always be taken seriously and answered honestly.