phjill Privacy Policy

1 Who We Are – Data Controller

phjill ("phjill," "we," "us," "our") is the data controller responsible for the personal information collected through the phjill Platform. phjill operates as a PAGCOR-regulated online casino and sports betting platform serving eligible Filipino players. As data controller, phjill determines the purposes and means by which personal data is processed.

phjill has designated a Data Protection Officer (DPO) as required by the Data Privacy Act of 2012. Contact details for the DPO are provided in Section 12 of this Policy. All data subject requests and privacy-related inquiries should be directed to the DPO in the first instance.

2 Personal Data We Collect

phjill collects personal data through multiple channels, including account registration forms, payment processing, identity verification procedures, platform usage, and communications with our support team. The categories of personal data collected are as follows:

phjill does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and AML compliance. phjill does not collect data relating to race, religion, health status, or political affiliation, except where required to verify eligibility under PAGCOR regulations.

3 How We Use Your Personal Data

phjill processes personal data for the following purposes:

• Account Registration and Management. To create, maintain, and manage your phjill account, including authentication, profile updates, and session management.
• Payment Processing. To process deposits and withdrawals via GCash, Maya, BPI, BDO, UnionBank, and other payment methods; to verify payment ownership; and to maintain transaction records as required by Philippine financial regulations.
• Identity Verification (KYC/AML). To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and Philippine Anti-Money Laundering Act obligations. phjill is legally required to collect and retain KYC documentation.
• Platform Operation and Game Delivery. To provide, maintain, and improve the phjill Platform, including game delivery, live dealer streaming, real-time odds calculations, and technical support.
• Regulatory Compliance and Reporting. To fulfill mandatory reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities as required by applicable law.
• Responsible Gaming. To monitor player behavior for indicators of problem gambling; to enforce self-exclusion requests; and to provide deposit limit, session alert, and cool-off period functionality.
• Security and Fraud Prevention. To detect, investigate, and prevent unauthorized access, fraudulent transactions, collusion, and other prohibited conduct, including coordination with PAGCOR and law enforcement where required.
• Marketing Communications. To send promotional offers, bonus notifications, and platform updates to players who have opted in to marketing communications. Players may opt out of marketing at any time through account settings or by contacting support.
• Customer Support. To process and respond to player inquiries, complaints, and dispute escalations.
• Analytics and Platform Improvement. To analyse aggregated and anonymised usage data for the purpose of improving Platform features, game selection, and user experience.

4 Legal Basis for Processing

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

• Contractual Necessity. Processing required to perform the contract between phjill and the Player (the Terms and Conditions), including account creation, payment processing, and game delivery.
• Legal Obligation. Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and other applicable Philippine laws and regulations.
• Legitimate Interest. Processing for fraud prevention, platform security, dispute resolution, and internal analytics, where phjill's legitimate business interests are not overridden by the Player's fundamental rights and freedoms.
• Consent. Processing of personal data for marketing communications, where phjill has obtained your explicit opt-in consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5 Data Sharing and Disclosure

5.1 Service Providers. phjill shares personal data with carefully selected third-party service providers who process data on phjill's behalf under contractual data processing agreements. These include: payment processors (GCash/Mynt, Maya/PayMaya, BancNet); KYC/identity verification providers; game software providers (Pragmatic Play, PG Soft, Jili, and others) where account-level data sharing is technically required for game delivery; cloud infrastructure providers; customer support platform operators; and analytics tool providers. All third-party processors are contractually bound to process data only as instructed by phjill and to maintain appropriate security standards.

5.2 Regulatory Authorities. phjill is legally obligated to disclose personal data and transaction records to PAGCOR as part of its licensing compliance obligations, and to the Anti-Money Laundering Council (AMLC) in connection with covered and suspicious transaction reporting under RA 9160. phjill may also disclose personal data to law enforcement authorities in response to a valid court order, subpoena, or other legally binding legal process issued by a Philippine court or competent authority.

5.3 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of phjill's assets, personal data held by phjill may be transferred to the acquiring entity as part of the transaction. Players will be notified of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

5.4 No Sale of Data. phjill does not sell, rent, or trade personal data to third parties for their independent marketing or commercial purposes. This is an absolute restriction.

6 Data Retention

phjill retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods mandated by Philippine law:

• KYC and identity verification documents: Minimum of five (5) years from account closure, as required by PAGCOR and the Anti-Money Laundering Act.
• Financial transaction records: Minimum of five (5) years from the date of the transaction, as required by AML regulations and PAGCOR's record-keeping requirements.
• Gameplay and wagering records: Minimum of three (3) years from the date of the gaming session, or longer if required by PAGCOR audit requirements.
• Marketing and communications data: Until opt-out or account closure, whichever occurs first, subject to a maximum retention period of three (3) years after last interaction.
• Technical and log data: Twelve (12) months from collection, unless retained longer for fraud investigation or legal proceedings.

Following expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be linked to any identifiable individual.

7 Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by phjill:

To exercise any of these rights, submit a written request to phjill's Data Protection Officer at [email protected]. phjill will respond within thirty (30) days. If you are unsatisfied with phjill's response, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

8 Cookies and Tracking Technologies

phjill uses the following types of cookies and tracking technologies on the Platform:

• Strictly Necessary Cookies: Required for core Platform functionality, including login session management, security tokens, and load balancing. These cannot be disabled without affecting your ability to use the Platform.
• Functional Cookies: Remember your preferences such as language settings, game lobby filters, and notification preferences to improve your Platform experience.
• Analytics Cookies: Collect anonymised data about how players interact with the phjill Platform, including pages visited, time on page, and error occurrences. This data is used to improve Platform performance and user experience.
• Marketing Cookies: Used to track whether players have clicked on phjill promotional campaigns, for attribution purposes only. phjill does not use marketing cookies to build advertising profiles for third-party ad networks.

You may manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Note that blocking strictly necessary cookies will impair your ability to log in and use the Platform. phjill does not currently operate a cookie consent management layer for strictly necessary cookies, as these are required for contractual service delivery.

9 Security Measures

phjill implements the following technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction:

• Transport Layer Security (TLS 1.3) on all data transmitted between player devices and phjill servers.
• AES-256 encryption for data at rest, including stored KYC documents and financial records.
• Role-based access control (RBAC) ensuring phjill staff access only the personal data necessary for their specific function.
• Multi-factor authentication required for all phjill internal system access by staff and contractors.
• Regular third-party penetration testing and vulnerability assessments of the Platform.
• Intrusion detection systems and 24/7 security monitoring of Platform infrastructure.
• Formal data breach response procedures with designated incident response team and NPC notification protocols.
• Staff data privacy training conducted regularly and upon onboarding.

While phjill takes all reasonable precautions, no system is entirely immune to security threats. Players are encouraged to use strong, unique passwords and to enable two-factor authentication on their phjill accounts.

10 Children's Privacy and Age Restriction

The phjill Platform is strictly prohibited for use by persons under the age of twenty-one (21) years, in compliance with PAGCOR's regulations for online casino services in the Philippines. phjill does not knowingly collect personal data from individuals under 21. If phjill becomes aware that personal data has been collected from a person under the minimum age, phjill will immediately close the associated account, void all associated balances and transactions, and securely delete the personal data in question, subject to any mandatory legal retention requirements.

Parents and guardians who believe a minor may have registered a phjill account are requested to contact phjill's support team immediately for account review and closure.

11 Changes to This Privacy Policy

phjill reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or Platform features. The effective date at the top of this document indicates when the current version came into force.

Where changes are material – meaning they significantly affect how phjill processes your personal data or your rights as a data subject – phjill will notify registered players by email and/or in-Platform notification at least fourteen (14) days before the changes take effect. Continued use of the Platform following the effective date of updated Terms constitutes acknowledgement of the revised Policy. If you do not agree with material changes, you have the right to close your account before the revised Policy takes effect.

12 Contact Us & Data Protection Officer

For all data privacy inquiries, data subject access requests, or complaints related to the processing of your personal data by phjill, please contact:

If you are not satisfied with phjill's response to your data privacy request, you may file a complaint with the National Privacy Commission (NPC) of the Philippines. Information on filing complaints with the NPC is available on the NPC's official website.