32jili Privacy Policy

1. Introduction & Scope

32jili Gaming Corporation ("32jili," "we," "us," "our") is committed to protecting the privacy and personal data of all users who access our online casino and sports betting services through our website at https://32jili.cam and related mobile applications (collectively, "Platform," "Services"). This Privacy Policy ("Policy") explains our practices regarding the collection, use, disclosure, storage, and protection of personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, implementing rules and regulations issued by the National Privacy Commission (NPC), and relevant PAGCOR data protection requirements.

This Privacy Policy applies to all users of 32jili Services, including visitors, registered players, and former account holders. By accessing our Platform, creating an account, or using our Services, you acknowledge that you have read and understood this Privacy Policy and consent to our collection, processing, and use of your personal information as described herein.

This Privacy Policy should be read in conjunction with our Terms and Conditions, Responsible Gaming Policy, and Cookie Policy, which together form the complete legal framework governing your use of 32jili Services. If you do not agree with the terms of this Privacy Policy, you should immediately discontinue use of our Services and refrain from providing any personal information.

2. Data Controller Information

2.1 Identity of Data Controller

32jili Gaming Corporation is the data controller responsible for the processing of personal data collected through our Platform. As data controller, we determine the purposes and means of processing your personal information and are accountable for compliance with Philippine data protection laws.

Registered Business Information:
Legal Name: 32jili Gaming Corporation
Business Registration Number: CS201912345
PAGCOR License Number: PH-2019-0842
Principal Office: Metro Manila, Philippines
Email: [email protected]
Data Protection Officer: [email protected]

2.2 Data Protection Officer (DPO)

We have appointed a dedicated Data Protection Officer responsible for overseeing our data protection strategy, ensuring compliance with the Data Privacy Act, handling privacy inquiries, and coordinating with the National Privacy Commission. You may contact our DPO at:

Data Protection Officer
Email: [email protected]
Subject Line: "Data Privacy Inquiry"
Response Time: Within 5 business days

3. Information We Collect

3.1 Personal Information Provided by You

When you register for a 32jili account, use our Services, or contact customer support, we collect personal information that you voluntarily provide, including but not limited to:

• Identity Information: Full legal name, date of birth, nationality, gender, government-issued identification numbers (passport, driver's license, UMID, or national ID)
• Contact Information: Email address, mobile phone number, residential address, postal code
• Financial Information: Payment method details (GCash account number, bank account information, e-wallet details), transaction history, deposit and withdrawal records
• Account Credentials: Username, password (stored in encrypted form), security questions and answers
• Verification Documents: Copies of government-issued identification, proof of address documents (utility bills, bank statements), selfie photographs for identity verification
• Communication Records: Chat transcripts, emails, phone call records with customer support, survey responses, feedback submissions

3.2 Information Automatically Collected

When you access our Platform, we automatically collect certain technical and usage information through cookies, log files, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address, advertising ID)
• Connection Information: IP address, geographic location (country, city, region based on IP), internet service provider
• Usage Data: Pages visited, games played, betting history, session duration, click patterns, navigation paths, referral sources
• Performance Data: Website loading times, error reports, technical issues encountered

3.3 Information from Third-Party Sources

We may receive additional information about you from third-party sources to verify your identity, prevent fraud, and comply with legal obligations:

• Identity verification services and KYC providers
• Payment processors (GCash, banks, cryptocurrency exchanges)
• Credit reference agencies and fraud prevention databases
• Publicly available sources (social media profiles if you choose to link accounts)
• PAGCOR and other regulatory authorities for compliance verification

4. How We Use Your Information

4.1 Primary Purposes of Data Processing

32jili processes your personal information for the following legitimate business purposes:

Account Management & Service Delivery

• Creating and maintaining your player account
• Processing your deposits, bets, and withdrawal requests
• Providing access to games, live casino, sports betting, and other Services
• Managing bonuses, promotions, and loyalty rewards
• Sending transactional notifications (deposit confirmations, withdrawal updates, bonus credits)

Identity Verification & Compliance

• Verifying your identity and age (21+ requirement) to comply with PAGCOR regulations
• Conducting Know Your Customer (KYC) and Enhanced Due Diligence (EDD) procedures
• Preventing fraud, money laundering, and other illegal activities
• Complying with Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) laws
• Fulfilling regulatory reporting obligations to PAGCOR and other authorities

Customer Support & Communication

• Responding to your inquiries, complaints, and support requests
• Providing technical assistance and troubleshooting issues
• Sending important account updates, policy changes, and security alerts
• Conducting customer satisfaction surveys and collecting feedback

Marketing & Personalization (with your consent)

• Sending promotional offers, bonus notifications, and new game announcements
• Personalizing your gaming experience based on play history and preferences
• Conducting market research and analyzing customer behavior
• Sending birthday greetings and special occasion promotions

Security & Risk Management

• Detecting and preventing fraudulent activities, multi-accounting, and bonus abuse
• Monitoring for suspicious betting patterns and collusion
• Protecting against hacking attempts, DDoS attacks, and security threats
• Enforcing our Terms and Conditions and Responsible Gaming policies

Legal Obligations & Dispute Resolution

• Complying with court orders, subpoenas, and legal process
• Responding to regulatory inquiries from PAGCOR and other authorities
• Investigating and resolving disputes between players or with 32jili
• Maintaining records as required by Philippine gambling laws

4.2 Automated Decision-Making and Profiling

32jili uses automated systems to enhance security and personalize Services. This includes:

• Automated fraud detection algorithms that analyze betting patterns and flag suspicious activity
• Risk assessment systems that evaluate account behavior for compliance purposes
• Personalized game recommendations based on play history and preferences
• Automated bonus eligibility determinations based on player status and activity

You have the right to request human review of any automated decision that significantly affects you. Contact our Data Protection Officer if you wish to challenge an automated decision.

5. Legal Basis for Processing

5.1 Grounds for Processing Personal Data

Under the Data Privacy Act of 2012, we process your personal information based on one or more of the following legal grounds:

Legal Basis	Processing Purpose
Contract Performance	Processing necessary to provide Services, manage your account, process transactions, and fulfill our Terms and Conditions
Legal Obligation	Compliance with PAGCOR regulations, AML/CFT laws, tax reporting, court orders, and Philippine gambling legislation
Consent	Marketing communications, optional data collection, cookies and tracking (where required), social media integration
Legitimate Interest	Fraud prevention, security measures, improving Services, customer support, dispute resolution, business analytics
Vital Interest	Emergency situations requiring disclosure to protect life or prevent serious harm

5.2 Consent Withdrawal

Where we rely on your consent as the legal basis for processing (e.g., marketing communications), you have the right to withdraw consent at any time. Withdrawal of consent will not affect the lawfulness of processing conducted prior to withdrawal. To withdraw consent, adjust your communication preferences in account settings or contact [email protected].

6. Data Sharing & Third Parties

6.1 Third-Party Service Providers

32jili engages trusted third-party service providers to support our operations. We share personal information with these providers only to the extent necessary for them to perform their functions:

• Payment Processors: GCash, Maya, banks, cryptocurrency payment gateways, and other financial institutions to process deposits and withdrawals
• KYC Verification Providers: Identity verification services that confirm your identity documents and perform background checks
• Game Providers: Third-party software developers (e.g., Evolution Gaming, Pragmatic Play, Microgaming) whose games you play on our Platform
• Cloud Hosting Services: Secure servers and data storage providers that host our Platform infrastructure
• Customer Support Tools: Live chat software, ticketing systems, and communication platforms used by our support team
• Analytics Services: Google Analytics and similar tools to analyze website usage and improve user experience
• Email Service Providers: Platforms used to send transactional and promotional emails

All third-party service providers are contractually bound to protect your data, use it only for specified purposes, and comply with Philippine data protection standards.

6.2 Regulatory and Legal Disclosures

We may disclose your personal information to regulatory authorities, law enforcement, and government agencies when required by law or necessary to:

• Comply with PAGCOR reporting and audit requirements
• Respond to court orders, subpoenas, or legal process
• Assist law enforcement investigations into fraud, money laundering, or criminal activity
• Comply with Anti-Money Laundering Council (AMLC) reporting obligations
• Fulfill tax reporting requirements to the Bureau of Internal Revenue (BIR)

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and provide an opportunity to delete your account before any such transfer occurs.

6.4 No Sale of Personal Data

32jili does not sell, rent, or trade your personal information to third parties for their marketing purposes. Your data is shared only as described in this Privacy Policy and never for commercial gain unrelated to providing you with our Services.

7. Data Security Measures

7.1 Technical Security Controls

32jili implements industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All sensitive data transmitted between your device and our servers is protected using 256-bit SSL/TLS encryption. Stored passwords are encrypted using bcrypt hashing algorithms.
• Firewall Protection: Multi-layered firewalls protect our servers from external threats and unauthorized access attempts.
• Access Controls: Strict role-based access controls ensure that only authorized personnel can access personal data, and only to the extent necessary for their job functions.
• Two-Factor Authentication (2FA): Optional 2FA available for player accounts to add an extra layer of login security.
• Intrusion Detection Systems: Continuous monitoring for suspicious activity, hacking attempts, and security breaches.
• Regular Security Audits: Quarterly penetration testing and vulnerability assessments conducted by independent security firms.
• Secure Data Centers: Personal data stored in ISO 27001-certified data centers with physical security controls and redundant backup systems.

7.2 Organizational Security Measures

In addition to technical controls, we maintain organizational safeguards including:

• Comprehensive data protection training for all employees handling personal information
• Confidentiality agreements binding all staff and contractors
• Background checks for employees with access to sensitive data
• Incident response procedures for data breaches and security incidents
• Regular review and updating of security policies and procedures

7.3 Data Breach Notification

In the unlikely event of a data breach that compromises your personal information, 32jili will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by the Data Privacy Act. The notification will include details of the breach, affected data, potential consequences, and remedial actions taken.

8. Data Retention Periods

8.1 Retention Policy

32jili retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

Data Category	Retention Period	Reason
Account Registration Data	Duration of account + 5 years	PAGCOR regulatory requirements, AML compliance
Transaction Records	7 years from transaction date	Tax law requirements, financial audits
KYC Verification Documents	5 years after account closure	Anti-Money Laundering regulations
Betting History	5 years from bet settlement	Dispute resolution, regulatory audits
Chat & Support Logs	3 years from conversation date	Quality assurance, dispute resolution
Marketing Consent Records	Duration of consent + 2 years	Consent management, audit trail
Website Usage Analytics	26 months	Business analytics, service improvement

8.2 Account Closure and Data Deletion

When you close your 32jili account, we will deactivate it immediately. However, certain personal information will be retained for the periods specified above to comply with legal obligations. After the retention period expires, your personal data will be securely deleted or anonymized so it can no longer be associated with you.

To request account closure and data deletion, contact our Data Protection Officer at [email protected]. We will process your request within 30 days, subject to our legal retention obligations.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. They help us recognize your device, remember your preferences, analyze how you use our Platform, and provide a personalized gaming experience. 32jili uses both first-party cookies (set by our website) and third-party cookies (set by external services like Google Analytics).

9.2 Types of Cookies We Use

Essential Cookies (Strictly Necessary)

These cookies are required for the Platform to function properly. They enable core functionality such as account login, transaction processing, and security features. Essential cookies cannot be disabled without impairing your ability to use our Services.

Performance & Analytics Cookies

These cookies collect information about how visitors use our Platform, such as which pages are most popular, how long users spend on each page, and error messages encountered. Data collected is aggregated and anonymous. We use Google Analytics and similar tools for this purpose.

Functionality Cookies

These cookies remember your preferences and choices (e.g., language selection, favorite games) to provide enhanced, personalized features. They may also be used to provide services you've requested, such as watching a video or commenting on a blog.

Advertising & Marketing Cookies

These cookies track your browsing activity across websites to deliver targeted advertisements. We work with advertising partners who may place cookies on your device to show you relevant ads on other websites. You can opt out of targeted advertising through your cookie settings.

9.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies, though this may affect your ability to use certain features of our Platform. To opt out of Google Analytics tracking, install the Google Analytics Opt-out Browser Add-on.

For detailed information on how we use cookies and how to manage them, please refer to our separate Cookie Policy available on our website.

10. Your Privacy Rights

10.1 Rights Under Philippine Data Privacy Law

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

Right to Be Informed

You have the right to know how your personal data is collected, used, shared, and stored. This Privacy Policy fulfills our obligation to inform you about our data processing activities.

Right to Access

You have the right to request a copy of the personal information we hold about you. This includes account details, transaction history, verification documents, and communication records. Requests will be fulfilled within 30 days.

Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings, or contact customer support for assistance.

Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or when you withdraw consent (where consent was the basis for processing). This right is subject to our legal retention obligations under PAGCOR regulations and Philippine law.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format (e.g., CSV, JSON) and to transmit that data to another service provider. This applies to data you provided to us based on consent or contract performance.

Right to Object

You have the right to object to processing of your personal data for direct marketing purposes, including profiling related to marketing. You may also object to processing based on legitimate interests by demonstrating compelling legitimate grounds relating to your particular situation.

Right to Restrict Processing

You have the right to request restriction of processing in certain circumstances, such as when you contest the accuracy of data, when processing is unlawful but you prefer restriction over deletion, or when data is needed for legal claims.

Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before consent was withdrawn.

10.2 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer at:

Email: [email protected]
Subject Line: "Data Subject Rights Request"
Include: Your full name, registered email address, and description of your request

We will verify your identity before processing requests and respond within the timeframe required by law (typically 30 days). There is no fee for exercising these rights unless requests are manifestly unfounded or excessive.

10.3 Complaints to Regulatory Authority

If you believe your privacy rights have been violated or you are unsatisfied with how we handle your data, you have the right to file a complaint with the National Privacy Commission (NPC):

National Privacy Commission
5th Floor, Philippines Postal Corporation Building
Liwasang Bonifacio, Manila 1000, Philippines
Email: [email protected]
Hotline: (02) 8234-2228

11. International Data Transfers

11.1 Cross-Border Data Transfers

32jili primarily stores and processes personal data within the Philippines. However, some of our third-party service providers (e.g., cloud hosting, analytics, game providers) may be located outside the Philippines, which may result in cross-border data transfers.

When we transfer personal data internationally, we ensure that:

• The receiving country has adequate data protection laws as determined by the National Privacy Commission
• Appropriate safeguards are in place, such as Standard Contractual Clauses or Binding Corporate Rules
• The transfer is necessary for contract performance, legal obligations, or your explicit consent

11.2 Data Security During Transfer

All international data transfers are encrypted during transmission using secure protocols (TLS 1.2 or higher). We conduct due diligence on all international service providers to ensure they maintain security standards equivalent to Philippine requirements.

12. Protection of Minors

12.1 Age Restriction Policy

32jili Services are strictly intended for individuals aged 21 years and above, as required by Philippine gambling laws. We do not knowingly collect personal information from individuals under the age of 21. If you are under 21, you are prohibited from accessing our Platform, creating an account, or providing any personal information.

12.2 Parental Notification

If we discover that we have inadvertently collected personal information from an individual under the age of 21, we will immediately delete that information from our systems and terminate the associated account. Parents or guardians who believe their child has provided personal information to 32jili should contact us immediately at [email protected].

12.3 Age Verification Procedures

As part of our KYC verification process, all users must provide government-issued identification that confirms they are 21 years of age or older. Accounts will remain restricted until age verification is completed.

13. Changes to This Privacy Policy

13.1 Policy Updates

32jili reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or operational needs. Updates may be necessary due to:

• Changes in Philippine data protection laws or PAGCOR regulations
• Introduction of new Services or features
• Changes in data processing technologies or security measures
• Feedback from the National Privacy Commission or data protection audits

13.2 Notification of Material Changes

When we make material changes to this Privacy Policy that significantly affect how we process your personal information, we will notify you by:

• Email notification to your registered email address
• Prominent notice on the 32jili homepage or login screen
• In-platform notification when you next access your account

The updated Privacy Policy will display a new "Last Updated" date at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

13.3 Continued Use After Changes

Your continued use of 32jili Services after the effective date of any Privacy Policy changes constitutes acceptance of those changes. If you do not agree with the updated Privacy Policy, you must stop using our Services and contact us to close your account.

14. Contact & Data Protection Officer

14.1 Privacy Inquiries

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us through:

Data Protection Officer
32jili Gaming Corporation
Email: [email protected]
Subject Line: "Privacy Inquiry"
Response Time: Within 5 business days

Customer Support (General Inquiries)
Email: [email protected]
Live Chat: Available 24/7 through our website
Phone: Available 9:00 AM - 9:00 PM Manila time

14.2 Mailing Address

For formal written correspondence regarding data protection matters, you may send mail to:

Data Protection Officer
32jili Gaming Corporation
Metro Manila, Philippines