1
Introduction
This Privacy Policy describes how 108jili ("we," "our," or "the Company") collects, uses, stores, and protects the personal data of players and visitors who use the 108jili online gaming platform at 108jili.net.
108jili is committed to protecting your privacy in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC). We also align our practices with internationally recognised data protection standards.
By registering for and using 108jili, you acknowledge that you have read, understood, and agreed to the collection and use of your information as described in this Privacy Policy. If you do not agree, please do not register or use the platform.
Plain language note: This policy tells you exactly what information 108jili holds about you, why we hold it, and what you can do about it. We've tried to keep things clear and in plain English — no paragraph-long sentences designed to obscure meaning. If anything here is unclear, contact us at support@108jili.net and we'll explain it personally.
2
Who We Are
108jili operates as a licensed online gaming platform serving players in the Philippines. For the purposes of the Philippine Data Privacy Act, 108jili acts as the Personal Information Controller (PIC) with respect to data collected through the 108jili platform.
Our designated Data Protection Officer (DPO) can be reached at support@108jili.net. All data-related requests, concerns, and complaints should be directed to the DPO in the first instance.
Where 108jili engages third-party service providers to process data on our behalf — such as payment processors and KYC verification services — those providers act as Personal Information Processors (PIPs) and are bound by contractual obligations to handle your data in compliance with the Data Privacy Act.
3
Personal Data We Collect
108jili collects the following categories of personal data from players and platform visitors:
3.1 Registration and Identity Data
- Full legal name (as it appears on a Philippine government-issued ID)
- Date of birth
- Email address
- Mobile phone number
- Username and account password (stored in hashed form — never as plain text)
- Nationality and country of residence
3.2 Identity Verification (KYC) Data
- Copies of government-issued identification (e.g., PhilSys ID, UMID, passport, driver's licence)
- Proof of address documents
- Selfie or facial verification images (where required by our KYC provider)
- Source of funds declarations for high-value accounts
3.3 Financial Data
- GCash or Maya mobile number linked to your account
- Bank account name and account number (for withdrawal processing)
- Transaction history: deposit amounts, withdrawal amounts, dates, and payment references
- Bonus and promotional credit history
108jili does not store full card numbers, card CVV codes, or complete banking credentials. Card payments are processed by PCI-DSS compliant payment gateways. We only receive tokenised payment references and basic transaction metadata.
3.4 Gaming and Behavioural Data
- Bet history: games played, stake amounts, outcomes, and timestamps
- Session duration, login frequency, and in-game activity logs
- Responsible gaming tool usage (e.g., deposit limits set, cool-off periods taken)
- Support ticket history and communications with our support team
3.5 Technical and Device Data
- IP address at time of registration and login
- Device type, operating system, and browser type
- Cookies and session tokens (see Section 10)
- Geolocation data (city/region level, where permitted by device settings)
3.6 Marketing Preferences
- Whether you have opted in to receive promotional communications via email or SMS
- Interaction data with marketing emails (open rates, link clicks) for players who have opted in
4
How We Collect Your Data
108jili collects your personal data through the following means:
- Directly from you: When you register an account, complete the KYC process, make a deposit or withdrawal, contact support, or submit a form on the platform.
- Automatically: When you use the 108jili platform, we automatically collect technical and behavioural data through server logs, cookies, and analytics tools.
- From third parties: We may receive identity verification results from licensed KYC providers, fraud detection signals from payment processors, and compliance information from regulatory authorities.
We do not purchase personal data lists from data brokers or third-party marketing companies and we do not collect data from Filipino players through social media platforms without your direct engagement.
5
How We Use Your Personal Data
108jili uses the personal data we collect for the following purposes:
| Purpose | Data Used | Legal Basis |
|---|
| Create and manage your player account | Registration data, contact details | Contract performance |
| Process deposits and withdrawals | Financial data, identity data | Contract performance |
| Verify your identity (KYC) | Identity documents, facial verification | Legal obligation (AML law) |
| Detect and prevent fraud | Technical data, transaction history | Legitimate interest |
| Provide customer support | Contact details, account data | Contract performance |
| Responsible gaming monitoring | Gaming history, behavioural data | Legal obligation / legitimate interest |
| Send promotional communications | Email, SMS, preferences | Consent (opt-in only) |
| Regulatory reporting | Transaction data, identity data | Legal obligation |
| Improve the platform | Usage data, device data (anonymised) | Legitimate interest |
We do not use your personal data for automated decision-making that would produce legal or similarly significant effects on you without human review, except for standard fraud scoring which can be reviewed by our compliance team upon request.
6
Legal Basis for Processing
Under the Philippine Data Privacy Act, 108jili processes your personal data based on the following lawful grounds:
- Consent: For optional purposes such as sending promotional emails and SMS — which you can withdraw at any time.
- Contract performance: For running your account, processing your bets, and handling deposits and withdrawals.
- Legal obligation: For KYC and anti-money laundering (AML) compliance under Philippine law, and for reporting to regulatory authorities.
- Legitimate interest: For fraud detection, platform security, and improving user experience — provided these interests do not override your fundamental privacy rights.
Where we rely on your consent to process data, you can withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent for marketing communications, click the unsubscribe link in any email or contact support.
7
Who We Share Your Data With
108jili does not sell, rent, or trade your personal information to any third party for their own commercial use. We share data only where necessary and only with the following categories of recipients:
7.1 Payment Processors
GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, and Visa/Mastercard processing partners. These processors receive only the transaction data required to complete payments and are contractually bound to handle your data in compliance with Philippine data privacy standards.
7.2 KYC and Identity Verification Providers
Licensed third-party KYC providers who verify identity documents and perform facial matching where required. These providers are certified and operate under data processing agreements with 108jili.
7.3 Regulatory Authorities
We may be required to disclose personal and financial data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies where legally compelled to do so. 108jili will not notify a player before such disclosure if doing so would compromise a regulatory investigation.
7.4 Technology and Platform Providers
Game content providers, live dealer streaming providers, and cloud infrastructure services that operate parts of the 108jili platform under strict data processing agreements. These providers access only the minimum data required to deliver their services.
7.5 Professional Advisers
Lawyers, auditors, and compliance consultants engaged by 108jili who are bound by professional confidentiality obligations.
108jili does not share your personal data with any third-party advertisers, data brokers, or social media platforms for marketing profiling purposes. Any sharing of data is limited to what is necessary for the specific purpose described above.
8
Data Retention
108jili retains your personal data for as long as your account is active and for a period thereafter as required by Philippine law and our regulatory obligations. Specific retention periods are as follows:
- Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with Philippine AML regulations.
- Transaction and betting records: Retained for a minimum of five (5) years from the date of each transaction.
- KYC documents: Retained for the duration of the account and for five (5) years post-closure.
- Support communications: Retained for three (3) years.
- Marketing preferences and communications: Retained until you withdraw consent, after which marketing data is deleted within 30 days.
- Technical logs and cookies: Session cookies are deleted when you close your browser. Analytics data is retained in anonymised form for up to two (2) years.
When data is no longer required and the retention period has expired, it is securely deleted or anonymised in a manner that prevents recovery.
9
How We Protect Your Data
108jili implements industry-standard technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Our security measures include:
- 256-bit SSL/TLS encryption on all data in transit between your device and the 108jili platform
- AES-256 encryption for sensitive data at rest in our databases
- Hashed and salted passwords — we never store your password in readable form
- Role-based access controls — staff access to personal data is strictly limited to what their role requires
- Regular penetration testing and vulnerability assessments by independent security firms
- Two-factor authentication (2FA) available for all player accounts
- Real-time fraud monitoring systems that flag unusual account activity for review
While no online system can guarantee absolute security, 108jili takes its security obligations seriously and continuously reviews and improves its security posture. In the event of a data breach that poses a risk to your rights or freedoms, we will notify the National Privacy Commission and affected players within the timeframe required by Philippine law.
10
Cookies and Tracking Technologies
108jili uses cookies and similar technologies to operate the platform, maintain your session, and understand how players use our services. The table below explains the types of cookies we use:
| Cookie Type |
Purpose |
Duration |
Can Opt Out? |
| Essential |
Keep you logged in, maintain your session and security tokens |
Session |
No — required to use the platform |
| Functional |
Remember your language, display preferences, and bet slip settings |
1 year |
Yes (affects personalisation) |
| Analytics |
Understand how players navigate the platform to improve it (anonymised) |
2 years |
Yes |
| Security |
Detect fraud, bots, and suspicious login patterns |
Session / 30 days |
No — required for account security |
To manage cookies, you can adjust your browser settings to refuse or delete cookies. Note that disabling essential cookies will prevent you from logging in to your 108jili account. We do not use advertising or retargeting cookies on the 108jili platform.
11
Your Data Rights
Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 108jili:
Right to Access
You can request a copy of the personal data 108jili holds about you, including how it is being used. We will respond within 15 business days.
Right to Rectification
If any personal data we hold is inaccurate or out of date, you can request that we correct it. Basic account details can be updated from your account settings.
Right to Erasure
You can request deletion of your personal data where it is no longer necessary for the purpose it was collected. Note that we are required by Philippine AML law to retain certain records for five (5) years even after account closure.
Right to Object
You can object to processing based on legitimate interest, including direct marketing. We will stop processing for that purpose unless we have compelling legitimate grounds that override your rights.
Right to Data Portability
You can request that we provide a copy of your personal data in a structured, machine-readable format so you can transfer it to another service.
Right to Withdraw Consent
Where processing is based on consent (e.g., marketing emails), you can withdraw consent at any time by clicking the unsubscribe link or contacting support. Withdrawal does not affect prior processing.
To exercise any of these rights, contact our Data Protection Officer at support@108jili.net with the subject line "Data Privacy Request." We will acknowledge your request within 3 business days and respond fully within 15 business days. There is no charge for exercising your rights.
12
Children's Privacy
108jili is an adults-only platform. We do not knowingly collect personal data from persons under the age of 18. If we become aware that a person under 18 has registered an account or provided personal data, we will immediately suspend the account, delete the data, and return any deposited funds in accordance with applicable regulations.
If you are a parent or guardian and believe that a minor has registered on 108jili, please contact us immediately at support@108jili.net and we will take prompt action.
13
Updates to This Privacy Policy
108jili may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable law. When we make material changes, we will notify registered players via email and/or a prominent notice on the platform at least 14 days before the changes take effect.
The "Last Updated" date at the top of this page always reflects the current version. We encourage you to review this policy periodically. Your continued use of 108jili after any updates constitutes acceptance of the revised policy.
Previous versions of this policy are available upon request — contact our DPO if you need to reference an earlier version.
14
Contact and Complaints
For any privacy-related questions, requests, or concerns, please contact the 108jili Data Protection Officer:
DPO Email
support@108jili.net
Subject: Data Privacy Request
Live Chat
24/7 Support
Filipino-speaking agents
NPC Complaints
National Privacy Commission
If unresolved after 30 days
If you are not satisfied with our response to a privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.
