38jili Privacy
Policy

This Privacy Policy applies to all personal data collected, processed, stored, or transferred by 38jili in connection with the operation of the 38jili platform at 38jili.cam, including all casino games, sports betting services, promotional activities, customer support interactions, and account management functions.

This Policy applies to all individuals who: (a) visit the 38jili website as guests; (b) register as Members on the 38jili platform; (c) participate in 38jili promotions; or (d) interact with 38jili customer support in any capacity.

This Privacy Policy is incorporated into and forms part of the 38jili Terms & Conditions. By using the 38jili platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

For the purposes of RA 10173 and this Privacy Policy, 38jili acts as the personal information controller in respect of all Member data. 38jili determines the purposes and means of processing personal data collected through the platform.

Where 38jili engages third-party service providers to process personal data on its behalf (such as KYC verification providers, payment processors, and game providers), such third parties act as personal information processors operating under contractual obligations to 38jili, and their processing of Member data is subject to 38jili's data protection requirements.

For data-related inquiries, requests, or complaints, Members may contact 38jili through the contact information provided in Section 16 of this Policy.

38jili collects the following categories of personal data from Members and platform visitors:

38jili does not collect sensitive personal information beyond what is strictly necessary for identity verification, regulatory compliance, and responsible gaming purposes. We do not collect biometric data beyond facial photographs used for one-time liveness checks during KYC, and these are processed by our certified KYC provider under data processing agreements.

38jili collects personal data through the following methods:

• Direct Submission: Information you actively provide during account registration, KYC verification, deposit and withdrawal requests, support interactions, and participation in promotions.
• Automated Technical Collection: Technical data collected automatically when you access the platform, including IP addresses, device identifiers, browser characteristics, and session data via server logs and cookies (see Section 8).
• Payment Processors: Transaction confirmation data received from GCash, Maya, BPI, BDO, Metrobank, and other payment partners when processing deposits and withdrawals.
• KYC Verification Partners: Identity verification results and flags returned by 38jili's certified KYC processing partner following document verification.
• Game Providers: Game session data generated when you play games on the 38jili platform, transmitted to 38jili by the respective game provider's systems.

38jili processes your personal data on the following legal bases under RA 10173:

• Contractual Necessity: Processing of identity, contact, financial, and gaming data is necessary for the performance of the contract between you and 38jili, specifically to provide account services, process transactions, and deliver gaming services.
• Legal Obligation: Processing of identity data for KYC verification, anti-money laundering compliance, and gaming tax reporting is required by PAGCOR regulations and applicable Philippine law, including RA 9160 (Anti-Money Laundering Act) and PAGCOR's operator compliance requirements.
• Legitimate Interests: Processing of technical data for fraud prevention, platform security, responsible gaming monitoring, and service improvement is based on 38jili's legitimate interests in maintaining a safe, secure, and fair gaming environment for all Members.
• Consent: Processing for direct marketing communications is based on your consent, which may be withdrawn at any time by contacting 38jili support or adjusting your account communication preferences.

38jili uses the personal data collected for the following purposes:

1. Account Management: Creating and maintaining your 38jili account, processing deposits and withdrawals, updating account details, and managing account status changes.
2. Identity Verification (KYC): Verifying your identity and age (21+ requirement) in compliance with PAGCOR licensing requirements and Philippine anti-money laundering obligations before activating real-money account features.
3. Service Delivery: Providing access to games, live dealer tables, sports betting, and all other platform features to which your account has access.
4. Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, bonus abuse, and other conduct prohibited under the 38jili Terms & Conditions.
5. Regulatory Compliance: Fulfilling PAGCOR reporting obligations, responding to law enforcement requests made with proper legal authority, and maintaining records required under applicable gaming and financial regulations.
6. Responsible Gaming: Monitoring gaming behavior for indicators of problem gambling, enforcing self-exclusion and account limit settings, and facilitating voluntary and mandatory responsible gaming interventions.
7. Customer Support: Responding to your support inquiries, managing dispute resolution processes, and maintaining communication records for quality assurance and compliance purposes.
8. Platform Improvement: Analyzing aggregated, anonymized usage data to improve platform performance, user experience, game offering, and operational efficiency.
9. Marketing Communications: Sending promotional offers, bonus notifications, and service updates to Members who have consented to receive such communications. These can be opted out at any time.

38jili does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the following limited circumstances:

• PAGCOR and Regulatory Authorities: 38jili is required to provide player data, transaction records, and compliance reports to PAGCOR as part of its licensing obligations. Regulatory reporting is a legal requirement and does not require Member consent.
• Law Enforcement: 38jili may disclose personal data to the Philippine National Police, the Anti-Money Laundering Council (AMLC), the National Bureau of Investigation, or other agencies with lawful authority upon receipt of a valid legal order, warrant, or regulatory directive.
• Payment Processors: Necessary financial information is shared with GCash, Maya, BPI, BDO, Metrobank, and other payment partners solely to process transactions. These parties handle financial data under their own privacy policies and applicable regulations.
• KYC Verification Providers: Identity documents and verification media are shared with 38jili's certified KYC verification partner for the sole purpose of identity verification. All KYC partners are bound by data processing agreements requiring compliance with RA 10173.
• Game Providers: Game session data is necessarily shared with game providers to facilitate gameplay. This data sharing is governed by data processing agreements between 38jili and each provider.
• Professional Advisors: 38jili may share personal data with legal counsel, auditors, or compliance consultants where strictly necessary for the provision of professional services, subject to professional secrecy obligations.

Any third party receiving 38jili Member data under the above categories is required to protect that data under terms no less protective than those described in this Privacy Policy.

The 38jili platform uses cookies and similar tracking technologies to operate the platform, maintain your session, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: These are essential for the platform to function. They include session authentication tokens, security cookies that protect against cross-site request forgery, and cookies that maintain your login state. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: These remember your preferences such as language, game display settings, and responsible gaming configurations. They improve your experience but are not essential to core functions.
• Analytics Cookies: These collect aggregated, anonymized data about how Members navigate the platform — which pages are visited most, session duration, and feature usage. This data is used solely for internal platform improvement.

38jili does not use third-party advertising cookies or cross-site tracking technologies that monitor your activity outside the 38jili platform. You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent you from accessing your account.

38jili retains personal data for the period necessary to fulfill the purposes described in this Privacy Policy and to comply with applicable legal and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents reconstruction of the original data. Where deletion is not immediately possible due to technical constraints (e.g., backup systems), data will be isolated and protected until it can be permanently deleted.

38jili implements technical and organizational security measures designed to protect Member data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and the 38jili platform is encrypted using industry-standard TLS (Transport Layer Security) protocols.
• Encryption at Rest: Sensitive data stored in 38jili's databases, including financial data and identity documents, is encrypted at rest using AES-256 or equivalent standard encryption.
• Access Controls: Access to Member personal data within 38jili's internal systems is restricted on a strict need-to-know basis. All staff with data access undergo background checks and data privacy training.
• Intrusion Detection: 38jili's infrastructure is monitored for unauthorized access attempts and anomalous activity through automated intrusion detection systems operating continuously.
• Security Testing: 38jili conducts regular security assessments of its platform and infrastructure to identify and address vulnerabilities before they can be exploited.

The 38jili platform is operated for the Philippine market, and the primary processing of Member data occurs within infrastructure serving the Philippines. However, certain service providers — including game providers, KYC verification partners, and payment processing infrastructure — may process Member data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, 38jili ensures that such transfers are conducted in compliance with the cross-border data transfer requirements of RA 10173, including through: (a) ensuring the receiving country has adequate data protection laws; (b) implementing standard contractual clauses in data processing agreements with international service providers; or (c) other lawful transfer mechanisms recognized by the National Privacy Commission.

Members may request information about the specific international transfers applicable to their data by contacting 38jili support using the details in Section 16.

Under the Philippine Data Privacy Act of 2012 (RA 10173), 38jili Members have the following rights with respect to their personal data. To exercise any of these rights, contact 38jili support as described in Section 16.

The 38jili platform is strictly for persons aged twenty-one (21) years and above. 38jili does not knowingly collect, process, or retain personal data from individuals below 21 years of age.

If 38jili becomes aware that personal data has been collected from a person below the required age, that data will be deleted immediately, the associated account will be permanently closed, and any funds held in that account will be handled in accordance with PAGCOR's guidelines on underage gambling enforcement.

If you believe that 38jili may have inadvertently collected data from a minor, please contact 38jili support immediately using the contact details in Section 16. We will investigate and act promptly.

The 38jili platform may contain references or links to third-party services in the context of payment methods and game providers. These third-party services operate under their own privacy policies, and 38jili is not responsible for the data practices of GCash (Globe Telecom / Mynt), Maya (PayMaya Philippines), BPI, BDO, Metrobank, or individual game software providers.

When you use GCash or another payment method to deposit into or withdraw from your 38jili account, your financial transaction data is subject to both 38jili's Privacy Policy and the payment provider's own privacy terms. 38jili recommends reviewing the privacy policy of your chosen payment provider for information on how they handle your data.

Game software on the 38jili platform is provided by licensed third-party studios. When you play a game, game session data (bets, outcomes, session duration) is processed by the provider's servers. This is governed by data processing agreements requiring the provider to handle this data in compliance with 38jili's instructions and applicable data protection law.

38jili reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, PAGCOR requirements, or National Privacy Commission guidelines. The effective date shown at the top of this Policy indicates the version currently in force.

Material changes to this Privacy Policy — particularly changes that affect how we use your personal data or your rights under RA 10173 — will be communicated to Members via their registered email address or through an in-platform notification at least fourteen (14) days before the amended Policy takes effect.

For non-material changes (such as clarifications, formatting updates, or changes to contact information), the Policy will be updated with a revised effective date without individual notification. We recommend reviewing this Policy periodically. The current version is always available at 38jili.cam/privacy-policy.

For all data privacy inquiries, requests to exercise your rights under RA 10173, or questions about this Privacy Policy, please contact the 38jili Data Protection function through the following channels:

• Live Chat: Available 24/7 at 38jili.cam. Average response time under 3 minutes.
• Email: [email protected] (plain text — not a clickable link). Reference "Data Privacy Request" in your subject line.

38jili will acknowledge all data privacy requests within five (5) business days. Requests to exercise data rights will be acted upon within the timeframes specified under RA 10173 and NPC regulations.

If you are not satisfied with 38jili's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the supervisory authority for the implementation of RA 10173 in the Philippines.