120jili Privacy Policy

1 Introduction

120jili is committed to protecting the privacy and personal data of every player on our platform. We understand that trust is the foundation of any relationship between a player and an online gaming platform, and we take our data protection obligations seriously.

This Policy has been prepared in accordance with the Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines and its Implementing Rules and Regulations, as well as other applicable data protection laws. By registering an account on 120jili or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

If you have any questions about this Policy or how 120jili handles your personal data, please contact us using the details provided in Section 15.

2 Data Controller

For the purposes of applicable data protection law, 120jili acts as the data controller in respect of the personal data collected through the Platform. As data controller, 120jili determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable law.

120jili operates in compliance with Philippine gaming regulations and processes personal data within the framework established by the National Privacy Commission (NPC) of the Philippines.

3 Personal Data We Collect

120jili collects personal data from you in the following categories, depending on how you interact with the Platform:

120jili does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, unless specifically required for regulatory compliance purposes (for example, problem gambling self-exclusion records).

4 How We Use Your Personal Data

120jili uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your 120jili account, including verifying your identity and age (21+) as required by Philippine gaming regulations.
• Service Delivery: To provide you with access to games, process deposits and withdrawals via GCash, PayMaya, and other Philippine payment channels, and deliver the core features of the Platform.
• Regulatory Compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and reporting obligations under Philippine gaming and financial regulations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other security threats to the Platform and its users.
• Customer Support: To respond to your enquiries, resolve disputes, and provide assistance through our 24/7 Filipino support team.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer self-exclusion, deposit limits, and other responsible gaming tools.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the performance, features, and user experience of the 120jili Platform.
• Marketing Communications: To send you account notifications, promotional offers, and platform updates where you have consented to receive such communications. You may opt out of marketing communications at any time.

5 Legal Basis for Processing

120jili processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and 120jili (i.e., the Terms & Conditions), including account creation, game access, and payment processing.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, KYC requirements, and gaming regulatory obligations.
• Legitimate Interests: Processing is necessary for 120jili's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, processing is based on your explicit consent, which you may withdraw at any time.

6 Data Sharing and Disclosure

120jili does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other Philippine payment service providers, solely to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification services used to confirm your identity and eligibility to use the Platform.
• Game Providers: Software providers whose games are hosted on the 120jili Platform may receive anonymised or pseudonymised usage data for game performance purposes.
• Regulatory Authorities: Philippine government agencies, including PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by law.
• Legal and Professional Advisers: Lawyers, auditors, and other professional advisers engaged by 120jili, subject to confidentiality obligations.
• Law Enforcement: Where required by a valid court order, subpoena, or other legal process under Philippine law.

All third parties with whom 120jili shares personal data are required to handle such data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

7 Payment Data

120jili takes the security of your financial data extremely seriously. When you make a deposit or withdrawal using GCash, PayMaya, BPI, BDO, Metrobank, or InstaPay, your payment credentials are transmitted directly to the relevant payment processor using encrypted connections. 120jili does not store your full payment account credentials, card numbers, or banking passwords on its servers.

Transaction records (amounts, dates, reference numbers) are retained as part of your account history for regulatory compliance and dispute resolution purposes. These records are stored securely and are accessible only to authorised 120jili personnel and relevant regulatory authorities.

8 Cookies and Tracking Technologies

120jili uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how the Platform is used.

We use the following types of cookies:

• Essential Cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Performance Cookies: Collect anonymised data about how players use the Platform to help us identify and fix issues and improve performance.
• Functional Cookies: Remember your preferences such as language settings and display options to personalise your experience.
• Analytics Cookies: Help us understand player behaviour in aggregate to improve game offerings and platform features.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

9 Data Retention

120jili retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by Philippine AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction.
• Support Communications: Retained for three (3) years from the date of the last communication.
• Marketing Consent Records: Retained until you withdraw consent, plus one (1) year for compliance documentation purposes.

When personal data is no longer required, 120jili will securely delete or anonymise it in accordance with our internal data disposal procedures.

10 Data Security

120jili implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 120jili Platform.
• Two-factor authentication (2FA) available for all player accounts.
• Encrypted storage of sensitive data at rest using industry-standard encryption protocols.
• Strict access controls ensuring that personal data is accessible only to authorised personnel on a need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent security professionals.
• Incident response procedures to detect, contain, and notify affected parties of any data breach in accordance with NPC requirements.

While 120jili takes all reasonable steps to protect your data, no system is completely immune to security risks. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

11 Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 120jili:

• Right to be Informed: The right to know what personal data 120jili collects and how it is used — which is the purpose of this Policy.
• Right of Access: The right to request a copy of the personal data 120jili holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to 120jili's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact the 120jili Data Protection Officer using the contact details in Section 15. We will respond to all verified requests within thirty (30) calendar days.

12 Children's Privacy

The 120jili Platform is strictly intended for persons aged 21 years and above, in accordance with Philippine gaming regulations. 120jili does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account and delete the data.

If you believe that a minor has registered on the 120jili Platform, please contact us immediately at [email protected] so that we can take appropriate action.

13 International Data Transfers

120jili primarily processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, for example, cloud infrastructure providers or international game software vendors.

Where such transfers occur, 120jili ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012 and NPC guidelines. By using the Platform, you consent to such transfers where they are necessary for the provision of the 120jili service.

14 Updates to This Policy

120jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. When material changes are made, we will notify registered players via email or an in-platform notification, and the updated Policy will be posted on this page with a revised "Last Updated" date.

Your continued use of the 120jili Platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how we protect your data.

15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 120jili handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 through the 120jili Platform
• Response Time: We aim to respond to all written privacy enquiries within 30 calendar days.

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with our response to your privacy concern.