jilno Privacy Policy

1 Introduction

1.1 jilno operates the online gaming platform accessible at jilno.app, offering casino games, sports betting, bingo, slots, and related services to players in the Philippines. In the course of providing these services, jilno necessarily collects and processes personal data about its players, visitors, and prospective users.

1.2 jilno takes its data protection obligations seriously. We are committed to handling your personal data with transparency, integrity, and in full compliance with applicable Philippine law — principally the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC).

1.3 This Privacy Policy applies to all personal data collected through the jilno website, mobile-optimized interfaces, customer support channels, and any other touchpoint through which you interact with jilno. It does not apply to third-party websites or services that may be referenced on the platform.

1.4 If you have questions about this Privacy Policy or how jilno handles your personal data, please refer to Section 16 for contact details including our Data Protection Officer (DPO).

2 Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, jilno is the personal information controller in respect of the personal data it collects and processes through the jilno platform.

2.2 As the personal information controller, jilno determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

2.3 jilno has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with data protection obligations and serving as the primary point of contact for data subjects exercising their rights. Contact details for the DPO are provided in Section 16.

3 Personal Data We Collect

3.1 jilno collects the following categories of personal data, depending on how you interact with the platform:

3.2 jilno does not collect sensitive personal information (as defined under RA 10173) unless strictly necessary for legal compliance purposes, such as government ID numbers required for KYC verification under PAGCOR-regulated framework requirements.

3.3 You are not required to provide all categories of data to browse the jilno website. However, certain data — particularly identity, contact, and financial data — is required to register an account, make deposits, and process withdrawals.

4 How We Collect Your Data

4.1 Directly from you. jilno collects data that you provide directly when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in promotions, or submit feedback.

4.2 Automatically. When you access the jilno platform, certain technical and usage data is collected automatically through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, browser type, and gameplay activity.

4.3 From third parties. jilno may receive data about you from third-party service providers, including:

• Identity verification and KYC service providers;
• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank) for transaction confirmation;
• Fraud detection and anti-money laundering screening services;
• Analytics providers that help jilno understand platform usage patterns.

4.4 All third-party providers engaged by jilno are contractually required to handle your personal data in accordance with applicable Philippine data protection law and jilno's data protection standards.

5 How We Use Your Personal Data

5.1 jilno uses your personal data for the following purposes:

• Account management: To register, maintain, and administer your jilno account, including verifying your identity and age (21+ requirement) in compliance with Philippine gaming regulations;
• Service delivery: To provide access to casino games, sports betting, bingo, slots, and all other features of the jilno platform;
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels in Philippine Peso (₱ PHP);
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Legal compliance: To comply with PAGCOR-regulated framework requirements, Anti-Money Laundering Act (AMLA) obligations, tax reporting requirements, and other applicable Philippine laws;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats;
• Responsible gaming: To monitor gameplay patterns for signs of problem gambling and to administer self-exclusion, deposit limits, and other responsible gaming tools;
• Marketing and promotions: To send you information about jilno promotions, bonuses, and new features — but only where you have given your consent or where jilno has a legitimate interest in doing so;
• Platform improvement: To analyze usage data and improve the performance, design, and features of the jilno platform;
• Dispute resolution: To investigate and resolve complaints, including those escalated to regulatory authorities.

5.2 jilno will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for the new processing activity.

6 Legal Basis for Processing

6.1 Under the Data Privacy Act of 2012, jilno must have a lawful basis for each category of personal data processing. The following table summarizes the lawful bases jilno relies upon:

6.2 Where jilno relies on your consent as the lawful basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6.3 Where jilno relies on legitimate interest as the lawful basis, jilno has conducted a balancing test to ensure that its interests do not override your fundamental rights and freedoms as a data subject.

7 Data Sharing & Disclosure

7.1 jilno does not sell, rent, or trade your personal data to third parties for their own marketing purposes. jilno may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and card networks, for the purpose of processing your financial transactions;
• Identity verification providers: Third-party KYC and age verification services engaged to confirm your identity and eligibility to use the platform;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government agencies, where disclosure is required by law;
• Fraud prevention and security services: Providers of fraud detection, cybersecurity, and risk management services that help protect the platform and its players;
• IT and infrastructure providers: Cloud hosting, data storage, and platform infrastructure providers who process data on jilno's behalf under strict data processing agreements;
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by jilno, subject to professional confidentiality obligations;
• Law enforcement: Philippine law enforcement agencies, where jilno is legally required or permitted to disclose data in connection with a criminal investigation or legal proceeding.

7.2 All third parties with whom jilno shares personal data are required to maintain appropriate technical and organizational security measures and to process data only in accordance with jilno's instructions and applicable Philippine law.

8 International Data Transfers

8.1 jilno primarily stores and processes personal data within the Philippines. However, some of jilno's third-party service providers — including cloud infrastructure and fraud prevention providers — may process data in jurisdictions outside the Philippines.

8.2 Where personal data is transferred outside the Philippines, jilno ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses approved by the National Privacy Commission, adequacy decisions, or binding corporate rules.

8.3 By using the jilno platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described in this section.

9 Data Retention

9.1 jilno retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply as a general guide:

9.2 When personal data is no longer required, jilno will securely delete or anonymize it in accordance with industry best practices. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

10 Cookies & Tracking Technologies

10.1 jilno uses cookies and similar tracking technologies (including web beacons and local storage) to operate the platform, remember your preferences, analyze usage patterns, and deliver relevant content.

10.2 The following categories of cookies are used on the jilno platform:

• Strictly necessary cookies: Essential for the platform to function. These cannot be disabled as they are required for login sessions, security, and core functionality.
• Performance and analytics cookies: Help jilno understand how players use the platform, which pages are most visited, and where technical issues occur. Data collected is aggregated and anonymized.
• Functional cookies: Remember your preferences such as language settings, display options, and game history to provide a more personalized experience.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of jilno's marketing campaigns. These are only set with your consent.

10.3 You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the jilno platform.

10.4 jilno does not use cookies to collect sensitive personal information or to track your activity on third-party websites outside of the jilno platform.

11 Security Measures

11.1 jilno implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jilno's servers;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Multi-factor authentication options for player accounts, including SMS OTP;
• Regular security audits, penetration testing, and vulnerability assessments;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Comprehensive staff training on data protection and information security;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

11.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jilno will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act of 2012. Affected individuals will be notified without undue delay where the breach is likely to result in a high risk to their rights.

12 Your Rights as a Data Subject

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

• Right to be informed: You have the right to be informed about how jilno collects and uses your personal data — which is the purpose of this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data jilno holds about you, along with information about how it is being processed;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data jilno holds about you;
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jilno's legal retention obligations;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible;
• Right to object: You have the right to object to the processing of your personal data where jilno relies on legitimate interest as the lawful basis, including for direct marketing purposes;
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe jilno has violated your data protection rights.

12.2 To exercise any of these rights, please contact jilno's Data Protection Officer using the contact details in Section 16. jilno will respond to all data subject requests within thirty (30) days of receipt, as required by the Data Privacy Act of 2012.

12.3 jilno may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties.

13 Children's Privacy

13.1 The jilno platform is strictly intended for adults aged 21 years and above. jilno does not knowingly collect personal data from individuals under the age of 21. This age restriction is a legal requirement under Philippine gaming regulations.

13.2 jilno employs age verification procedures during account registration to prevent underage access. If jilno discovers that personal data has been collected from a person under 21 years of age, the account will be immediately closed, all funds will be returned to the payment source, and the personal data will be securely deleted.

13.3 If you are a parent or guardian and believe that your child has registered a jilno account, please contact jilno's support team immediately so that the account can be closed and the data removed.

14 Third-Party Links & Services

14.1 The jilno platform may contain references to third-party services, such as payment providers and game software developers. jilno is not responsible for the privacy practices of these third parties and this Privacy Policy does not apply to their data collection activities.

14.2 jilno encourages you to review the privacy policies of any third-party services you interact with in connection with your use of the jilno platform, particularly payment providers such as GCash and PayMaya, which have their own privacy policies governing the data they collect.

15 Updates to This Privacy Policy

15.1 jilno reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, jilno will notify registered players via email or via a prominent notice on the platform.

15.2 The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised. jilno recommends that you review this Privacy Policy periodically to stay informed of any changes.

15.3 Your continued use of the jilno platform after the effective date of any update constitutes your acknowledgment of the revised Privacy Policy. If you do not agree with the updated policy, you may request account closure in accordance with jilno's Terms & Conditions.

16 Contact & Data Protection Officer

16.1 If you have any questions, concerns, or requests relating to this Privacy Policy or jilno's data processing practices, please contact jilno's Data Protection Officer through the following channels:

16.2 For formal data subject requests — including access, rectification, erasure, or portability requests — please contact the DPO via email with the subject line "Data Subject Request" and include your registered jilno account email address and a description of your request. jilno may request proof of identity before processing your request.

16.3 This Privacy Policy was last reviewed and updated on January 1, 2026 and is effective as of that date.