328jili Privacy Policy

328jili ("328jili", "we", "us", "our") is the operator of the online gaming and sports betting platform accessible at 328jili.ws ("Platform"). We serve Filipino players across the Philippines — from Metro Manila and Quezon City to Cebu, Davao, and beyond — offering a wide range of casino games, crash games, bingo rooms, and sports betting markets.

328jili operates in compliance with the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR) and in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission (NPC).

For all data privacy matters, 328jili acts as the Personal Information Controller (PIC) — the entity that determines the purposes and means of processing your personal data. Where we engage third-party service providers to process data on our behalf, those providers act as Personal Information Processors (PIPs) and are contractually bound to process your data only on our documented instructions and in accordance with applicable Philippine data protection law.

328jili collects the following categories of personal data from players and visitors to the Platform. We collect only what is necessary for the specific purposes described in Section 4 of this policy.

We do not collect sensitive personal information (as defined under RA 10173) such as health data, political affiliations, or religious beliefs unless a specific legal obligation requires it (for example, in connection with a court order or a PAGCOR regulatory directive). We also do not collect data from individuals who are under 21 years of age — if we discover that a minor has provided personal data, that account will be closed and the data promptly deleted.

328jili collects personal data through the following channels and mechanisms:

• Direct registration: Information you provide when creating your 328jili account, including your name, date of birth, email address, and Philippine mobile number.
• Identity verification (KYC): Documents you upload during the Know Your Customer verification process, such as a scanned or photographed government-issued ID and a proof-of-address document.
• Deposits and withdrawals: Payment details and transaction records generated when you fund your account via GCash, Maya, BPI, BDO, Metrobank, GrabPay, QR Ph, InstaPay, PesoNet, or 7-Eleven CLiQQ.
• Platform activity: Automatically collected data generated by your use of the Platform, including game sessions, betting history, login timestamps, and device/browser information.
• Customer support interactions: Information you provide when contacting our support team via live chat, email, or any other communication channel available on the Platform.
• Cookies and similar technologies: Data collected automatically through cookies, pixel tags, and local storage as described in Section 6 of this policy.
• Third-party sources: In certain circumstances — particularly for fraud prevention and AML compliance — we may receive or verify data about you from third-party identity verification providers, payment processors, or regulatory databases, strictly as permitted by Philippine law.

Under the Data Privacy Act of 2012, every processing activity must have a lawful basis. The table below sets out the primary purposes for which 328jili processes your personal data and the corresponding legal basis for each.

Where we rely on your consent as the legal basis for processing (for example, for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal. To withdraw consent, update your notification preferences in your 328jili account settings or contact our support team.

328jili does not sell your personal data. We share your data only in the limited circumstances described below, and always subject to appropriate contractual safeguards or legal authority:

• Payment processors and e-wallet providers: To process your deposits and withdrawals, we share necessary financial and identity data with payment service providers such as GCash, Maya, BPI, BDO, Metrobank, and GrabPay. These providers are bound by their own data protection obligations and applicable Philippine financial regulations.
• Game and platform technology providers: Some games on the 328jili Platform are provided by third-party game studios and software developers. These providers may receive anonymised session and activity data necessary to deliver their games. They do not receive your full identity profile.
• Identity verification (KYC) providers: We engage accredited third-party KYC service providers to assist with document verification and age confirmation. These providers act as Personal Information Processors under written agreements with 328jili.
• Regulatory and law enforcement authorities: We are legally required to share certain data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities upon lawful request or as mandated by applicable regulations.
• Fraud prevention and security service providers: We may share technical and identity data with fraud prevention services to protect the Platform and all its players from abuse, cheating, and illegal activity.
• Professional advisers: Our lawyers, accountants, and auditors may have access to personal data as strictly necessary in the course of providing professional services to 328jili, subject to duties of confidentiality.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all of 328jili's business assets, your personal data may be transferred to the acquirer as part of the transaction. You will be notified of any such transfer and your rights under the Data Privacy Act will be preserved.

328jili uses cookies and similar tracking technologies (such as pixel tags and local storage) on its Platform to provide a functional, secure, and personalised experience. Below is an overview of the categories of cookies we use:

• Strictly necessary cookies: These cookies are required for the Platform to function. They enable core features such as session management, login authentication, and security. You cannot opt out of strictly necessary cookies while using the Platform.
• Functional cookies: These cookies remember your preferences — such as your preferred language, last visited game category, and responsible gaming settings — so you do not have to reconfigure them each time you visit.
• Analytics cookies: We use privacy-respecting analytics tools to understand how players interact with the Platform — which pages are most visited, where users encounter difficulties, and how game navigation flows can be improved. Data collected is aggregated and does not identify you personally where avoidable.
• Security and fraud prevention cookies: These cookies help us detect and prevent fraudulent activity, bot access, and account takeover attempts on the Platform.

You can control cookie preferences through your browser settings. Most modern browsers allow you to refuse, delete, or receive notifications before cookies are set. Please note that disabling certain cookies may affect the functionality of the 328jili Platform — for example, you may need to log in again on each visit if session cookies are disabled.

328jili does not use third-party advertising or retargeting cookies that track your browsing activity across unrelated websites.

Protecting the personal data of our Filipino players is a top operational priority at 328jili. We implement a comprehensive set of technical and organisational security measures to protect your data against unauthorised access, loss, destruction, alteration, and disclosure:

• TLS/SSL encryption: All data transmitted between your device and our servers is encrypted using Transport Layer Security (TLS) protocols.
• Data encryption at rest: Sensitive data stored in our databases — including identity documents and financial records — is encrypted using strong cryptographic algorithms.
• Access controls: Access to personal data within 328jili's systems is restricted on a strict need-to-know basis. Staff with access to player data are subject to confidentiality obligations and undergo regular data privacy training.
• Two-factor authentication: 2FA is available for player accounts and is required for all privileged internal systems that process personal data.
• Regular security audits: We conduct periodic security assessments and penetration testing to identify and remediate vulnerabilities in our Platform infrastructure.
• Incident response: 328jili maintains a documented data breach response procedure that ensures swift containment, assessment, and notification in the event of any security incident.

While we take all reasonable steps to protect your data, no method of transmission over the internet or method of electronic storage is 100% secure. You also have a responsibility to keep your account credentials secure — please review Section 3 of our Terms & Conditions for guidance on account security best practices.

328jili retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulatory obligations. The following retention guidelines apply:

• Active account data: Retained for the duration of your account relationship with 328jili, plus a post-closure retention period as required by PAGCOR and AML regulations.
• KYC and identity documents: Retained for a minimum of five (5) years following account closure, in compliance with Philippine AML law (RA 9160 as amended by RA 10167) and PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AML obligations.
• Gaming activity logs: Retained for a minimum of three (3) years for dispute resolution purposes and regulatory compliance.
• Customer support communications: Retained for two (2) years following the resolution of the relevant support interaction, unless the matter relates to an unresolved dispute or legal proceeding.
• Marketing preference records: Retained for the duration of the account relationship and for one (1) year following account closure as evidence of consent or opt-out.

Upon expiry of the applicable retention period — and provided no legal hold, regulatory requirement, or unresolved dispute requires further retention — 328jili will securely delete or irreversibly anonymise your personal data.

Under the Philippine Data Privacy Act of 2012 and its IRR, you are entitled to exercise the following rights with respect to your personal data held by 328jili:

• Right to be informed: You have the right to know whether 328jili holds personal data about you, and to receive clear information about how that data is processed — which is the primary purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data 328jili holds about you, along with information about the purposes for which it is processed and the parties with whom it is shared.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You can update many details directly through your 328jili account settings.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been unlawfully processed. This right is subject to 328jili's legal retention obligations.
• Right to object: You may object to the processing of your personal data where 328jili relies on its legitimate interests as the legal basis — for example, certain types of analytics processing. You may also object to direct marketing at any time with no need to give a reason.
• Right to data portability: Where technically feasible and legally permitted, you may request a machine-readable copy of personal data you have provided to 328jili, for the purpose of transferring it to another controller.
• Right to lodge a complaint: If you believe 328jili has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details in Section 13. We will respond to all valid data subject requests within fifteen (15) working days of receipt, as required by NPC guidelines. In complex cases, we may extend this period by a further fifteen (15) working days, with written notification to you explaining the reason for the extension.

We may need to verify your identity before processing a data subject request to ensure we do not disclose or modify another person's data. Identity verification is a security measure, not a barrier to exercising your rights.

The 328jili Platform is strictly intended for adults aged 21 years and older. This is the minimum legal age for casino-style gambling in the Philippines as prescribed by applicable law and PAGCOR regulations. The Platform is not directed at, and does not knowingly collect personal data from, any individual under the age of 21.

Age verification is a mandatory step in the 328jili registration process. All players are required to confirm their age during sign-up and to submit valid government-issued identity documents as part of the KYC process. Any account found to belong to a person under the age of 21 will be immediately closed, all winnings forfeited in accordance with applicable regulations, and any deposited funds that are eligible for return will be refunded via the original payment method.

If you are a parent or guardian and have reason to believe that a minor in your care has accessed the 328jili Platform or provided personal data to us, please contact our support team immediately at [email protected]. We will investigate promptly and take appropriate action, including the deletion of any personal data belonging to a minor.

As an online gaming platform, some of 328jili's technology partners, game providers, and service providers may be located outside the Philippines. In the course of providing our services, your personal data may be transferred to and processed in countries other than the Philippines.

Whenever 328jili transfers personal data outside the Philippines, we ensure that appropriate safeguards are in place to protect your data in a manner consistent with the Data Privacy Act of 2012 and NPC guidelines. These safeguards may include:

• Contractual provisions with the recipient entity that impose data protection obligations equivalent to those required under Philippine law.
• Transfers to countries or jurisdictions that have been assessed as providing an adequate level of data protection.
• Specific derogations permitted under the Data Privacy Act, such as where the transfer is necessary for the performance of your contract with 328jili (for example, processing a payment through an international payment network).

If you would like more information about the specific safeguards applied to any particular cross-border data transfer involving your personal data, you may contact our Data Protection Officer at the contact details provided in Section 13.

328jili reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or NPC guidance. All revisions will be published on this page with an updated effective date at the top of the policy.

Where a proposed change is material — meaning it significantly affects how we process your personal data or reduces your rights — we will provide you with advance notice via email to your registered 328jili address or via a prominent notice on the Platform, at least fourteen (14) days before the change takes effect. This gives you the opportunity to review the changes and, if you do not agree with them, to close your account before they become effective.

Your continued use of the 328jili Platform after any updated Privacy Policy has been published and the notice period has expired constitutes your acknowledgement of the updated policy. We encourage you to review this page periodically to stay informed about how we protect your personal data.

In compliance with the Data Privacy Act of 2012 and NPC Circular No. 17-01, 328jili has designated a Data Protection Officer (DPO) who is responsible for overseeing our data protection compliance programme and serving as the primary point of contact for all data privacy matters.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact us through the following channels:

• Email (DPO): [email protected] — please include "Data Privacy Request" in the subject line
• Live Chat: Available 24/7 directly through the 328jili Platform
• Response Time: We aim to acknowledge all data privacy enquiries within two (2) business days and to provide a substantive response within fifteen (15) working days

If you are not satisfied with our response, you have the right to escalate your concern to the National Privacy Commission (NPC), the government authority responsible for administering and implementing the Data Privacy Act of 2012 in the Philippines.

For responsible gaming concerns or to request self-exclusion, please visit our dedicated Responsible Gaming page or contact our support team directly via live chat.