phjill Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how phjill ("phjill," "we," "us," "our"), the operator of the online gaming platform at phjill.club, collects, uses, stores, and discloses personal data relating to users of the phjill platform ("you," "User," "Account Holder").

This Policy applies to all personal data collected through the phjill website, mobile browser experience, customer support channels, and any other touchpoint through which you interact with phjill. It should be read alongside phjill's Terms & Conditions and Responsible Gaming Policy.

phjill is committed to processing personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules and regulations, as well as any other applicable data protection laws of the Republic of the Philippines.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, the data controller in respect of your personal data is phjill, with principal operations based in Manila, Philippines.

If you have any questions or concerns regarding the processing of your personal data by phjill, you may contact our designated Data Protection Officer at: support@phjill.club

3. Personal Data We Collect

3.1 Identity and Contact Data

• Full legal name
• Date of birth
• Government-issued identification number (e.g., Philippine National ID, SSS, UMID, Passport, or Driver's Licence number)
• Mobile phone number (typically a +63 Philippine number)
• Email address
• Residential address (city, province, region within the Philippines)

3.2 Financial Data

• GCash account number or Maya account details registered to your phjill account
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where provided for withdrawal purposes
• Transaction history, including deposits, withdrawals, bets placed, and winnings received

3.3 Gaming and Platform Data

• Login timestamps and session duration
• Games played, bet amounts, and game outcomes
• Bonus and promotional activity
• Responsible gaming settings and self-exclusion records
• Customer support interaction records

3.4 Technical Data

• IP address
• Device type, operating system, and browser type
• Cookie identifiers and session tokens
• Geolocation data (country/region level, derived from IP address)

4. How We Collect Your Data

phjill collects personal data through the following means:

• Account Registration: You provide identity, contact, and payment information when creating your phjill account.
• Identity Verification (KYC): You upload identification documents when requested as part of our Know Your Customer process.
• Transactions: Financial data is generated automatically when you make deposits or withdrawals via GCash, Maya, or bank transfer.
• Platform Use: Technical and gaming data is collected automatically as you navigate and interact with the phjill platform.
• Customer Support: Data you provide when you contact our support team via live chat or email.
• Cookies and Tracking: As described in Section 8 of this Policy.

5. Legal Bases for Processing

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

• Contractual Necessity: Processing necessary to perform the contract between you and phjill (i.e., to operate your account, process bets, and facilitate withdrawals).
• Legal Obligation: Processing required to comply with Philippine law, including Anti-Money Laundering Act (AMLA) obligations, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, abuse detection, and responsible gaming monitoring, where these interests are not overridden by your rights.
• Consent: Processing for marketing communications, where you have provided explicit consent. You may withdraw consent at any time by updating your communication preferences in account settings.

6. How We Use Your Personal Data

phjill uses your personal data for the following purposes:

• Creating, verifying, and managing your phjill account;
• Processing deposits, withdrawals, and bet transactions;
• Verifying your age (21+) and identity in compliance with Philippine gaming regulations;
• Detecting and preventing fraud, money laundering, and other illegal activity;
• Providing customer support and resolving disputes;
• Administering bonuses, promotions, and loyalty programmes;
• Monitoring and enforcing responsible gaming limits, cooling-off periods, and self-exclusion;
• Sending transactional communications related to your account (e.g., deposit confirmations, withdrawal notifications);
• Sending promotional communications, where you have opted in;
• Complying with regulatory reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine authorities;
• Improving the phjill platform through analysis of aggregated, anonymised usage data.

7. Disclosure of Personal Data

phjill does not sell or rent your personal data to third parties. We may share your personal data with the following categories of recipients:

• Payment Processors: GCash (Mynt), Maya (PayMaya Philippines), and Philippine banks, for the purpose of processing deposits and withdrawals;
• Game Providers: Certified gaming software providers (e.g., JILI, PG Soft, Pragmatic Play) receive limited technical data necessary to deliver game content to your session;
• Identity Verification Providers: Third-party KYC and fraud prevention services that assist phjill in verifying account holder identities;
• IT and Cloud Service Providers: Infrastructure and cloud services that host and operate the phjill platform on phjill's behalf, subject to data processing agreements;
• Regulatory and Law Enforcement Authorities: PAGCOR, the AMLC, the National Privacy Commission, or other competent Philippine authorities where phjill is required by law to disclose information;
• Professional Advisers: Legal, audit, and compliance professionals where disclosure is necessary and subject to confidentiality obligations.

All third-party processors engaged by phjill are required to process personal data only on phjill's instructions and in accordance with applicable data protection law.

8. Cookies and Tracking Technologies

phjill uses cookies and similar technologies on the phjill.club platform for the following purposes:

• Essential Cookies: Required for the platform to function, including maintaining your logged-in session and security tokens. These cannot be disabled without impairing platform functionality.
• Analytics Cookies: Used to understand how users navigate the phjill platform in aggregate, enabling us to improve performance and usability. Data collected is anonymised where possible.
• Preference Cookies: Store your platform preferences, such as language and notification settings, between sessions.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will affect your ability to remain logged in to your phjill account.

9. Data Retention

phjill retains personal data for the following periods:

• Active Accounts: For the duration of your account relationship with phjill, plus any period required by law following account closure;
• Financial Transaction Records: A minimum of 5 years from the date of each transaction, in accordance with AMLA obligations;
• Identity Verification Documents: A minimum of 5 years from account closure or the date of the most recent transaction, whichever is later;
• Customer Support Records: Up to 3 years from the date of the interaction;
• Marketing Consent Records: Until consent is withdrawn, plus a reasonable period thereafter as evidence of consent.

After the applicable retention period expires, personal data is securely deleted or anonymised.

10. Security Measures

phjill implements technical and organisational security measures proportionate to the sensitivity of the personal data we hold. These measures include:

• TLS/SSL encryption for all data transmitted between your browser and phjill's servers;
• Encryption at rest for databases containing sensitive personal and financial data;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Multi-factor authentication for phjill internal systems handling personal data;
• Regular security assessments and penetration testing of the phjill platform;
• Staff training on data protection obligations and information security practices.

While phjill takes all reasonable precautions, no internet-based system can guarantee absolute security. You are encouraged to use a strong, unique password for your phjill account and to report any suspected unauthorised access immediately.

11. Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phjill:

• Right to be Informed: The right to be told how your personal data is collected and used — which this Policy fulfils;
• Right of Access: The right to request a copy of the personal data phjill holds about you;
• Right to Rectification: The right to have inaccurate personal data corrected. You can update most account details directly via your phjill account settings;
• Right to Erasure: The right to request deletion of your personal data where there is no longer a legal basis for its retention, subject to phjill's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to Data Portability: The right to receive a structured, machine-readable copy of your personal data;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe phjill has processed your personal data in breach of the Data Privacy Act.

To exercise any of these rights, please contact phjill's Data Protection Officer at support@phjill.club. We will respond to verifiable requests within 15 business days.

12. Children's Privacy

The phjill platform is strictly for adults aged 21 years and over. phjill does not knowingly collect personal data from persons under the age of 21. If phjill becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, all personal data will be deleted, and any funds held will be returned to the source of deposit.

If you believe a minor has created a phjill account, please contact our support team immediately so we can take appropriate action.

13. Changes to This Policy

phjill may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or platform features. Material changes will be communicated to registered users via the contact details on file and/or by a notice posted on the phjill platform, with a minimum of 7 days before the revised Policy takes effect.

Your continued use of the phjill platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

14. Contact and Complaints

For questions, data subject requests, or privacy complaints relating to phjill's handling of your personal data, please contact:

• Data Protection Officer — phjill
• Email: support@phjill.club
• Live Chat: Available 24/7 via the phjill platform
• Address: Manila, Philippines

If you are not satisfied with phjill's response to your privacy concern, you may escalate your complaint to the National Privacy Commission of the Philippines (privacy.gov.ph).