jill4 Privacy Policy

1. Who We Are — Data Controller

jill4 ("jill4," "we," "us," or "our") is the data controller responsible for the personal data collected through the jill4 platform accessible at jill4.org. As data controller, jill4 determines the purposes for which and the means by which personal data is processed, in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

For all data privacy matters, including the exercise of your rights under the DPA, you may contact jill4 at [email protected].

2. Scope of This Policy

This Privacy Policy applies to all personal data collected by jill4 through:

• The jill4 website at jill4.org and all associated subdomains;
• The jill4 mobile web application and any Progressive Web App (PWA) version of the platform;
• Communications between you and jill4 via live chat, email, SMS, or any other channel;
• The account registration, KYC verification, deposit, withdrawal, and gaming processes.

This Policy does not apply to third-party websites, payment processors, game providers, or other third-party services that may be linked to or integrated with jill4. You are encouraged to review the privacy policies of those third parties independently.

3. Personal Data We Collect

jill4 collects the following categories of personal data, depending on the nature of your interaction with the platform:

4. How We Collect Your Data

jill4 collects personal data through the following methods:

4.1 Direct Collection

Data you provide directly when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting support, updating your account profile, or opting into a promotion.

4.2 Automated Collection

Data collected automatically when you access the jill4 platform — including IP address, device identifiers, browser information, session logs, cookie identifiers, and clickstream data. This data is collected through standard web server logs and first-party cookies.

4.3 Third-Party Sources

jill4 may receive data about you from third-party identity verification providers (for KYC purposes), payment processors (for transaction verification), and anti-fraud service providers. This data is used solely to verify your identity, process transactions, and comply with applicable legal and regulatory obligations.

5. Purposes and Legal Bases for Processing

jill4 processes your personal data for the following purposes, each supported by a lawful basis under the DPA:

• Account Creation and Management — Necessary for the performance of the contract between you and jill4 (your Account Terms). We process Identity and Contact Data to create and maintain your jill4 Account.
• Age and Identity Verification (KYC) — Legal obligation under PAGCOR regulations and applicable anti-money-laundering laws. We process Identity Data and Financial Data to comply with these obligations before allowing withdrawals and as an ongoing compliance requirement.
• Payment Processing — Necessary for the performance of the contract. We process Financial Data to process deposits and withdrawals via your chosen Philippine payment method.
• Platform Operation and Security — Legitimate interests of jill4 in maintaining a secure, fair, and functional gaming environment. Technical Data and Gaming Activity Data are processed to detect fraud, prevent abuse, and ensure platform integrity.
• Responsible Gaming Compliance — Legal obligation and legitimate interest. Gaming Activity Data and Preference Data are used to monitor player behaviour, apply responsible gaming tools, and comply with PAGCOR requirements on player protection.
• Customer Support — Legitimate interest in providing effective support. Communications Data is processed to handle and resolve support requests and complaints.
• Marketing and Promotions — Consent. Where you have opted in to receive marketing communications, Contact Data and Preference Data are used to send relevant promotional offers. You may withdraw consent at any time.
• Legal and Regulatory Compliance — Legal obligation. All categories of data may be processed as required by applicable Philippine law, PAGCOR directives, court orders, or law enforcement requests.

6. Sharing of Personal Data

jill4 does not sell, rent, or trade your personal data. We share personal data only in the following limited circumstances:

• Payment Processors: GCash (GXI), Maya (Voyager Innovations), BPI, BDO, Metrobank, and other payment service providers receive transaction-level data necessary to process deposits and withdrawals. These providers operate under their own privacy frameworks and applicable Philippine financial regulations.
• Identity Verification Providers: Third-party KYC service providers may receive your Identity Data for the sole purpose of verifying your identity and age as required by PAGCOR and anti-money-laundering obligations. These providers are contractually bound to process data only for the stated purpose.
• Game Providers: Certain game session data (e.g., anonymised player identifiers and bet data) may be shared with third-party game providers (e.g., PG Soft, Pragmatic Play) to facilitate game functionality and audit game outcomes. Personal identity data is not routinely shared with game providers.
• Anti-Fraud and Security Providers: Technical Data and, where necessary, Identity Data may be shared with fraud detection and security services to protect the platform and all players from fraudulent activity.
• Regulators and Authorities: jill4 may disclose personal data to PAGCOR, AMLC (Anti-Money Laundering Council), law enforcement agencies, courts, or other public authorities where required by law, regulation, or valid legal process.
• Corporate Transactions: In the event of a merger, acquisition, or sale of jill4's business or assets, personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

7. International Data Transfers

Some of jill4's third-party service providers — including certain game providers and cloud infrastructure providers — may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that of the Philippines under the DPA, jill4 implements appropriate safeguards, which may include standard contractual clauses approved by the National Privacy Commission of the Philippines or equivalent contractual protections.

By using jill4 and agreeing to this Privacy Policy, you consent to the transfer of your personal data to jurisdictions outside the Philippines where necessary for the provision of the jill4 service, subject to the safeguards described above.

8. Data Retention

jill4 retains personal data for no longer than necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• KYC and Identity Documents: Minimum five (5) years from the date of account closure, as required by Philippine anti-money-laundering regulations.
• Transaction Records (Deposits and Withdrawals): Minimum five (5) years from the date of the transaction.
• Gaming Activity Logs: Minimum three (3) years from the date of the session, for audit and responsible gaming monitoring purposes.
• Support Communications: Three (3) years from the date of the last communication in a given thread, unless the matter involves an unresolved legal claim.
• Marketing Consent Records: Retained for as long as you hold a jill4 Account and for one (1) year after Account closure, as evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jill4's internal data lifecycle management procedures.

9. Security Measures

jill4 implements the following technical and organisational security measures to protect your personal data:

• TLS/SSL encryption for all data transmitted between your device and jill4's servers.
• AES-256 encryption for sensitive personal data stored at rest in jill4's databases.
• Password hashing using industry-standard algorithms (bcrypt or equivalent). Plaintext passwords are never stored.
• Multi-factor authentication options for player accounts, including OTP via SMS.
• Access controls limiting internal access to personal data to authorised personnel on a need-to-know basis.
• Regular security assessments and penetration testing of the jill4 platform.
• Incident response procedures including notification obligations in the event of a data breach, as required by the DPA and its Implementing Rules and Regulations.

Notwithstanding the above, no method of electronic transmission or storage is completely secure. jill4 cannot guarantee the absolute security of your personal data, and you transmit data to jill4 at your own risk. You are responsible for maintaining the security of your jill4 Account credentials.

10. Cookies and Tracking Technologies

jill4 uses first-party cookies and similar tracking technologies to operate the platform. These include:

• Strictly Necessary Cookies: Required for the platform to function — session management, authentication tokens, CSRF protection. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences (e.g., language, display settings) to personalise your jill4 experience across sessions.
• Analytics Cookies: Used to understand aggregated usage patterns — which pages are visited most, session durations, navigation flows. This data is used in anonymised form to improve the platform. You may opt out of analytics cookies through your browser settings.

jill4 does not use third-party advertising or tracking cookies. You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the jill4 platform.

11. Your Rights Under Philippine Law

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by jill4:

• Right to Be Informed: The right to be informed of what personal data jill4 collects and how it is processed — as set out in this Privacy Policy.
• Right to Access: The right to obtain a copy of the personal data jill4 holds about you, information on the sources of that data, and the purposes for which it is processed.
• Right to Correction: The right to request correction of inaccurate, outdated, or incomplete personal data in your jill4 Account.
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and no overriding legal obligation requires its retention.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. Upon receipt of an objection, jill4 will cease processing your data for that purpose.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe jill4 has violated your data privacy rights.

To exercise any of the above rights, contact jill4 at [email protected]. jill4 will respond to all valid rights requests within thirty (30) days of receipt, in accordance with the DPA and its Implementing Rules and Regulations.

12. Children and Minors

jill4 is strictly prohibited to persons under twenty-one (21) years of age under Philippine gaming regulations. jill4 does not knowingly collect personal data from individuals under the age of 21. If jill4 discovers that an Account has been created by a person under 21, the Account will be immediately suspended, all funds will be handled in accordance with jill4's minor protection procedures, and the relevant personal data will be deleted except where retention is required by law.

If you believe a minor has accessed or registered on jill4, please contact jill4 support immediately at [email protected].

13. Third-Party Services

The jill4 platform may integrate with or reference third-party services including game providers, payment processors, and analytics tools. These third parties have their own privacy policies and data practices, which are independent of jill4's. jill4 is not responsible for the privacy practices of third-party services.

jill4 conducts due diligence on third-party service providers before engagement, including assessment of their data protection standards and their compliance with applicable law. Data Processing Agreements are in place with all third-party processors where required under the DPA.

14. Changes to This Policy

jill4 may update this Privacy Policy from time to time to reflect changes in legal requirements, regulatory guidance, platform functionality, or our data processing practices. Material changes will be communicated to registered players via the email address on file and/or through a prominent notice on the jill4 platform prior to the changes taking effect.

The effective date of the current version of this Privacy Policy is stated at the top of this document. The most current version will always be accessible at jill4.org/privacy-policy. Continued use of the jill4 platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

15. Contact — Data Protection

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jill4, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 from the jill4 platform — average first response under 5 minutes.

jill4 takes all data privacy requests and concerns seriously. You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are unsatisfied with jill4's response to your data privacy concern.