jilko Privacy Policy

1. Scope and Application

This Privacy Policy applies to all personal information collected by jilko through our website (https://jilko.cam), mobile applications, customer support channels, and any other digital platforms or services operated by jilko. This policy covers both registered users and visitors to our Platform.

By creating a jilko account, accessing our Platform, or using our gaming services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with any aspect of this policy, you should not use jilko services.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of jilko services. In the event of any conflict between this Privacy Policy and the Terms & Conditions, the Terms & Conditions shall prevail to the extent of the conflict.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012, jilko is the data controller responsible for your personal information. We determine the purposes and means of processing your personal data in accordance with this Privacy Policy and applicable Philippine law.

2.1 Contact Details

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, you may contact our Data Protection Officer at:

• Email: [email protected]
• Customer Support: [email protected]
• Postal Address: Available upon request for formal data subject requests

2.2 Regulatory Oversight

jilko operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and complies with data security requirements established by PAGCOR for licensed gaming operators. Our data practices are also subject to the jurisdiction of the National Privacy Commission of the Philippines.

3. Information We Collect

jilko collects various types of personal information to provide, maintain, protect, and improve our gaming services. The information we collect falls into several categories:

3.1 Account Registration Information

When you create a jilko account, we collect the following information:

• Full legal name (as it appears on your government-issued identification)
• Date of birth (to verify you are at least 21 years of age)
• Email address
• Mobile phone number
• Residential address (street, city, province, postal code)
• Username and password (password is stored in encrypted form)
• Preferred language and currency settings

3.2 Identity Verification Information

To comply with Philippine anti-money laundering (AML) regulations, PAGCOR "Know Your Customer" (KYC) requirements, and to prevent fraud, we collect identity verification documents including:

• Government-issued photo identification (Philippine passport, driver's license, national ID, or postal ID)
• Proof of address documents (utility bills, bank statements, or government correspondence dated within the last three months)
• Selfie photographs holding identification documents (for facial verification purposes)
• Additional documentation as required for enhanced due diligence or large withdrawal requests

3.3 Financial and Transaction Information

When you deposit funds or request withdrawals, we collect:

• Payment method information (e-wallet account names, bank account details, cryptocurrency wallet addresses)
• Transaction history (deposits, withdrawals, wagers, winnings, bonuses claimed)
• Payment gateway transaction identifiers and timestamps
• Source of funds documentation for large transactions (as required by AML regulations)

Note that jilko does not store complete credit card numbers or CVV codes. Payment card information is processed through PCI-DSS compliant third-party payment processors.

3.4 Gaming Activity and Preferences

To personalize your experience and ensure responsible gaming, we collect information about your gaming behavior:

• Games played, betting patterns, win/loss records
• Session duration and frequency of play
• Favorite games and saved preferences
• Bonus and promotion participation
• Responsible gaming settings (deposit limits, session limits, self-exclusion periods)
• Communication preferences and marketing opt-in status

3.5 Technical and Device Information

When you access the jilko Platform, we automatically collect certain technical information:

• IP address and geolocation data (to verify you are physically located in the Philippines)
• Device type, operating system, browser type and version
• Screen resolution, device identifiers, and mobile network information
• Referring URLs, pages viewed, and navigation paths through the Platform
• Date and time stamps of access, session duration
• Error reports and performance data

3.6 Customer Support and Communications

When you contact jilko customer support or communicate with us, we collect:

• Content of your messages, emails, and live chat conversations
• Call recordings of telephone support interactions (with prior notice and consent)
• Support ticket history and resolution records
• Feedback, reviews, and survey responses

4. How We Use Your Information

jilko uses your personal information for the following purposes:

4.1 Service Provision and Account Management

• Create, maintain, and authenticate your jilko account
• Process deposits, withdrawals, and other financial transactions
• Provide access to gaming products (slots, casino games, sports betting, bingo, sabong)
• Track gaming activity, account balances, and transaction history
• Administer bonuses, promotions, and loyalty programs
• Provide customer support and respond to your inquiries

4.2 Compliance and Security

• Verify your identity and age to comply with legal age restrictions (21+)
• Conduct KYC and AML checks as required by Philippine law and PAGCOR regulations
• Detect and prevent fraud, money laundering, problem gambling, and prohibited activities
• Enforce our Terms & Conditions and investigate Terms violations
• Comply with legal obligations, regulatory requests, and court orders
• Maintain audit trails and records as required by PAGCOR

4.3 Platform Improvement and Personalization

• Analyze usage patterns to improve Platform performance and user experience
• Personalize game recommendations and promotional offers based on your preferences
• Develop and test new features, products, and services
• Conduct research and analytics to understand player behavior and preferences

4.4 Marketing and Communications

• Send promotional emails, SMS messages, and push notifications about bonuses, new games, and special offers (only with your consent)
• Provide updates about changes to our services, policies, or terms
• Send transactional communications related to your account (deposits, withdrawals, security alerts)
• Conduct customer satisfaction surveys and request feedback

You may opt out of marketing communications at any time by clicking "unsubscribe" in our emails, adjusting your account preferences, or contacting customer support. Please note that even if you opt out of marketing, you will still receive essential transactional and account-related communications.

4.5 Responsible Gaming

• Monitor gaming behavior for signs of problem gambling
• Implement and enforce responsible gaming tools (deposit limits, session reminders, self-exclusion)
• Provide access to responsible gaming resources and support organizations
• Comply with PAGCOR responsible gaming requirements

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, jilko processes your personal information based on the following legal grounds:

5.1 Contractual Necessity

Processing is necessary to fulfill our contractual obligations under the Terms & Conditions, including providing gaming services, processing transactions, and managing your account.

5.2 Legal Obligation

Processing is required to comply with Philippine laws and regulations, including:

• Philippine Data Privacy Act of 2012 (Republic Act 10173)
• Anti-Money Laundering Act (Republic Act 9160) as amended
• PAGCOR licensing requirements and regulatory directives
• National Privacy Commission issuances and circulars
• Tax reporting and financial documentation requirements

5.3 Legitimate Interests

Processing is necessary for our legitimate business interests, including:

• Fraud prevention and security monitoring
• Platform improvement and service optimization
• Business analytics and operational efficiency
• Protection of our rights, property, and safety

We balance these legitimate interests against your privacy rights and will not process data in ways that are disproportionate or unexpected.

5.4 Consent

For certain processing activities, particularly marketing communications and non-essential cookies, we obtain your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

6. Information Sharing and Disclosure

jilko does not sell or rent your personal information to third parties for their marketing purposes. We share your information only in the following limited circumstances:

6.1 Service Providers and Business Partners

We share information with trusted third-party service providers who perform services on our behalf, including:

• Payment processors: GCash, PayMaya, bank payment gateways, cryptocurrency payment providers
• Identity verification services: KYC/AML compliance vendors, document verification providers
• Gaming platform providers: Game developers, RNG testing laboratories, live dealer studios
• Technology infrastructure: Cloud hosting providers, content delivery networks, email service providers
• Customer support tools: Help desk software, live chat platforms, communication tools
• Analytics and marketing: Web analytics providers, marketing automation platforms

All service providers are bound by confidentiality obligations and are permitted to use your information only for the specific services they provide to jilko. We conduct due diligence to ensure service providers maintain adequate data security measures.

6.2 Regulatory and Legal Authorities

We may disclose your information to government authorities, regulators, and law enforcement agencies when required by law or when we believe disclosure is necessary to:

• Comply with PAGCOR audits, investigations, or regulatory requests
• Respond to court orders, subpoenas, or legal process
• Cooperate with law enforcement investigations
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Comply with tax reporting obligations to the Bureau of Internal Revenue (BIR)
• Respond to National Privacy Commission inquiries or investigations

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring or successor entity. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

6.4 Fraud Prevention and Security

We may share information with fraud prevention services, security vendors, and industry databases to detect and prevent fraudulent transactions, account takeovers, bonus abuse, and other prohibited activities. This sharing is necessary to protect jilko, our users, and the integrity of our gaming platform.

6.5 With Your Consent

We may share your information with third parties for purposes not described in this policy when we have obtained your explicit consent to do so.

7. Data Security Measures

jilko takes data security seriously and implements comprehensive technical and organizational measures to protect your personal information:

7.1 Technical Safeguards

• Encryption: All data transmitted between your device and jilko servers is encrypted using industry-standard TLS/SSL protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Secure servers: Our infrastructure is hosted in secure, certified data centers with physical access controls, environmental safeguards, and redundancy systems.
• Firewalls and intrusion detection: We employ enterprise-grade firewalls, intrusion detection systems, and continuous security monitoring.
• Access controls: Personal information is accessible only to authorized personnel on a need-to-know basis, with role-based access controls and multi-factor authentication.
• Secure development practices: Our software development follows secure coding standards and undergoes regular security testing and vulnerability assessments.

7.2 Organizational Safeguards

• Employee training on data privacy, security, and handling of personal information
• Confidentiality agreements and non-disclosure obligations for all staff
• Data protection impact assessments for new processing activities
• Incident response and breach notification procedures
• Regular security audits and compliance reviews
• Third-party security certifications and compliance validations

7.3 Account Security Recommendations

While we implement robust security measures, you also play a critical role in protecting your jilko account:

• Use a strong, unique password that combines letters, numbers, and special characters
• Never share your password or login credentials with anyone
• Enable two-factor authentication if available
• Log out of your account after each session, especially on shared devices
• Keep your contact information current to receive security alerts
• Be cautious of phishing attempts and only access jilko through our official website or app
• Report any suspicious activity or unauthorized access immediately

7.4 Data Breach Notification

In the unlikely event of a data breach that poses a risk to your rights and freedoms, jilko will notify affected users and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with Philippine Data Privacy Act requirements. Notifications will include the nature of the breach, data affected, and steps being taken to mitigate harm.

8. Data Retention and Deletion

8.1 Retention Periods

jilko retains your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Specific retention periods include:

Data Category	Retention Period	Legal Basis
Account and registration data	Duration of account + 5 years	PAGCOR regulatory requirements, AML compliance
Transaction records	5 years from transaction date	Anti-Money Laundering Act, BIR tax requirements
Identity verification documents	5 years after account closure	KYC/AML record-keeping obligations
Gaming activity logs	5 years	PAGCOR licensing requirements, dispute resolution
Customer support records	3 years	Quality assurance, dispute resolution
Marketing consent records	Duration of consent + 2 years	Evidence of consent, regulatory compliance
Technical and analytics data	12-24 months	Platform improvement, security monitoring

8.2 Account Closure and Data Deletion

When you close your jilko account, we will:

• Immediately disable your login access and cease marketing communications
• Process any pending withdrawals according to standard procedures
• Retain transaction records and identity verification documents for the legally required periods
• Delete or anonymize account data not subject to legal retention requirements within ninety (90) days

Please note that even after account closure, we must retain certain information to comply with Philippine regulatory requirements, particularly those related to anti-money laundering, tax reporting, and PAGCOR licensing.

8.3 Inactive Accounts

Accounts with no login activity for twelve (12) consecutive months are considered inactive. Inactive accounts may be subject to administrative fees and eventual closure. After closure of an inactive account, data retention follows the same schedule as voluntary account closures.

9. Your Privacy Rights

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

9.1 Right to Access

You have the right to request access to the personal information we hold about you. You may request a copy of your data, which we will provide in a commonly used electronic format within thirty (30) days. The first copy is provided free of charge; subsequent copies may incur a reasonable administrative fee.

9.2 Right to Rectification

If your personal information is inaccurate, incomplete, or out of date, you have the right to request correction. You can update most information directly through your jilko account settings. For changes requiring verification (such as legal name or date of birth), contact our Data Protection Officer with supporting documentation.

9.3 Right to Erasure

You may request deletion of your personal information in certain circumstances, including when:

• The information is no longer necessary for the purposes for which it was collected
• You withdraw consent on which processing is based (and no other legal ground applies)
• You object to processing and there are no overriding legitimate grounds
• The information was unlawfully processed

This right is not absolute. We may decline deletion requests when retention is necessary for legal compliance, establishment or defense of legal claims, or other legally recognized grounds.

9.4 Right to Object

You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary for legal claims.

9.5 Right to Restrict Processing

You may request restriction of processing in specific situations, such as when:

• You contest the accuracy of your personal information (during the verification period)
• Processing is unlawful but you prefer restriction rather than erasure
• We no longer need the data but you require it for legal claims
• You have objected to processing and await verification of grounds

9.6 Right to Data Portability

You have the right to receive personal information you provided to jilko in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.

9.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal. You can withdraw marketing consent by clicking "unsubscribe" in emails or adjusting account preferences.

9.8 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected] with your request. We will respond within thirty (30) days and may request additional information to verify your identity before processing requests. All requests are handled in accordance with Philippine Data Privacy Act requirements.

10. Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files stored on your device when you visit the jilko Platform. Cookies help us recognize your device, remember your preferences, and provide a better user experience. We also use similar tracking technologies such as web beacons, pixel tags, and local storage.

10.2 Types of Cookies We Use

Essential Cookies: Necessary for the Platform to function properly. These cookies enable core features like account login, session management, security, and payment processing. You cannot opt out of essential cookies.

Functional Cookies: Remember your preferences and choices (such as language, currency, and game favorites) to provide a personalized experience.

Analytics Cookies: Help us understand how users interact with the Platform by collecting aggregated usage statistics. We use this information to improve performance and user experience.

Marketing Cookies: Track your activity across websites to deliver targeted advertising and measure campaign effectiveness. These cookies are used only with your consent.

10.3 Third-Party Cookies

Some cookies are placed by third-party services that appear on our Platform, including:

• Google Analytics (website traffic analysis)
• Payment gateway providers (transaction processing)
• Customer support platforms (live chat functionality)
• Advertising networks (if you have consented to marketing cookies)

10.4 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling essential cookies may impair Platform functionality and prevent you from accessing certain features. Consult your browser's help documentation for instructions on managing cookies.

11. Protection of Minors

jilko services are strictly intended for adults aged twenty-one (21) years or older. We do not knowingly collect personal information from individuals under the legal gaming age. Our age verification processes include:

• Date of birth validation during account registration
• Government-issued identification verification before first withdrawal
• Ongoing monitoring for signs of underage access

If we become aware that we have collected personal information from a minor, we will immediately delete the account, erase the associated data, and forfeit any account balance in accordance with PAGCOR responsible gaming protocols.

Parents and guardians are encouraged to monitor and supervise their children's internet usage. If you believe a minor has accessed jilko services, please contact us immediately at [email protected].

12. International Data Transfers

jilko primarily operates within the Philippines and stores data on servers located in the Philippines or in secure data centers in jurisdictions with adequate data protection standards. However, some of our service providers and technology partners may be located outside the Philippines.

When we transfer personal information internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by the National Privacy Commission
• Transfers to jurisdictions recognized by the NPC as providing adequate protection
• Data processing agreements with security and confidentiality obligations
• Technical measures such as encryption and pseudonymization

We do not transfer personal information to jurisdictions with inadequate data protection laws unless legally required or with your explicit consent and appropriate safeguards.

13. Policy Updates

jilko may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or operational procedures. We will notify you of material changes through one or more of the following methods:

• Prominent notice on the jilko Platform
• Email notification to your registered email address
• Pop-up notification upon next login
• Push notification through the mobile app (if installed)

The "Last Updated" date at the top of this policy indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Your continued use of jilko services after policy updates constitutes acceptance of the revised Privacy Policy.

For minor updates that do not materially affect your rights, we may update this policy without individual notification, though the "Last Updated" date will always reflect the most recent changes.

14. Contact and Complaints

14.1 Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: "Data Privacy Inquiry" (for faster routing)
• Response Time: We aim to respond to all privacy inquiries within 5 business days

14.2 Customer Support

For general account or service questions, contact our customer support team:

• Email: [email protected]
• Live Chat: Available through the jilko Platform
• Hours: 8:00 AM – 12:00 MN PHT, 7 days a week

14.3 Filing Complaints

If you believe jilko has violated your privacy rights or failed to comply with the Philippine Data Privacy Act, you have the right to file a complaint with:

National Privacy Commission (NPC)
5th Floor, Philippine International Convention Center (PICC)
Vicente Sotto Street, Pasay City, Metro Manila 1307
Email: [email protected]
Complaints Hotline: (+63 2) 8234-2228
Website: https://www.privacy.gov.ph

You may also file complaints with PAGCOR regarding data security or privacy issues specific to gaming operations. We encourage you to contact us first to resolve concerns, but you have the right to approach regulatory authorities at any time.

14.4 Dispute Resolution

We are committed to resolving privacy-related disputes fairly and promptly. If you contact us with a complaint, we will:

• Acknowledge receipt within two (2) business days
• Investigate the matter thoroughly and impartially
• Provide a substantive response within thirty (30) days
• Take corrective action if a violation is confirmed
• Cooperate fully with regulatory investigations