GemJili Privacy Policy

1. Introduction

GemJili ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all registered players and visitors to the GemJili platform. This Privacy Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and other applicable data protection legislation.

This policy describes the types of personal information we collect from you when you use GemJili, the purposes for which we use that information, the circumstances under which we may share it with third parties, and the rights you have in relation to your personal data. We encourage you to read this policy carefully and to contact us if you have any questions or concerns about how your data is handled.

GemJili serves Filipino players across the Philippines, including those based in Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond. We understand the importance of data privacy to our community and take our obligations under Philippine law seriously.

2. Personal Data We Collect

GemJili collects personal data that is necessary for the operation of our platform, the provision of our services, and compliance with our legal and regulatory obligations. The categories of personal data we collect include:

2.1 Identity and Contact Information

• Full legal name as it appears on your government-issued identification
• Date of birth (used to verify that you meet the 21+ age requirement)
• Residential address, including city, province, and postal code
• Email address and mobile phone number
• Government-issued identification number (e.g., Philippine National ID, passport, driver's license)

2.2 Financial Information

• GCash account number or registered mobile number
• PayMaya account details
• Bank account details for BPI, BDO, Metrobank, or other accepted banking institutions
• Transaction history, including deposits, withdrawals, wagers, and winnings
• Source of funds documentation where required for compliance purposes

2.3 Technical and Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Login timestamps and session duration data
• Game play history, including games played, wager amounts, and outcomes
• Platform navigation data and feature usage patterns

2.4 Communications Data

• Records of communications between you and GemJili customer support
• Feedback, complaints, and dispute records
• Responses to surveys or promotional communications where you have opted in

3. How We Collect Your Data

GemJili collects personal data through the following means:

• Direct collection: Information you provide when registering for an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access and use the GemJili platform, including through cookies, web beacons, and similar tracking technologies.
• Third-party sources: Information received from payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention agencies, and regulatory authorities where permitted by law.
• KYC verification providers: Data obtained through our Know Your Customer verification process, which may involve cross-referencing your submitted documents against third-party identity databases.

4. How We Use Your Personal Data

GemJili uses the personal data we collect for the following purposes:

GemJili 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 processing.

5. Legal Basis for Processing

GemJili processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you agreed to upon registration, including account management, payment processing, and service delivery.
• Legal obligation: Processing necessary to comply with applicable laws and regulations, including anti-money laundering requirements, gaming regulations, and tax reporting obligations.
• Legitimate interests: Processing carried out for GemJili's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Personal Data

GemJili does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only where necessary and in accordance with applicable law:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the GemJili platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, customer support platforms, and fraud detection services. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

GemJili may disclose personal data to the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and other competent authorities where required or permitted by law, including in connection with the investigation of fraud, money laundering, or other criminal activity.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of GemJili's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and of any material changes to this Privacy Policy that may result.

6.4 Professional Advisers

GemJili may share personal data with legal counsel, auditors, and other professional advisers where necessary for the conduct of our business, subject to appropriate confidentiality obligations.

7. Data Retention

GemJili retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• Identity verification documents: Retained for the duration of your account and for five (5) years following account closure.
• Customer support records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing consent records: Retained for the duration of your consent and for two (2) years following withdrawal of consent.

Where personal data is no longer required for any lawful purpose, GemJili will securely delete or anonymize it in accordance with our data retention and disposal procedures.

8. Cookies and Tracking Technologies

GemJili uses cookies and similar tracking technologies to enhance your experience on our platform, analyze usage patterns, and support our security and fraud prevention measures. The types of cookies we use include:

• Strictly necessary cookies: Essential for the operation of the GemJili platform, including session management, authentication, and security functions. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences and settings, such as language selection and display options, to provide a more personalized experience.
• Analytical cookies: Used to collect aggregated, anonymized data about how players use the GemJili platform, helping us identify areas for improvement and optimize performance.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns, where you have provided consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the GemJili platform. For strictly necessary cookies, no opt-out is available as they are essential to the operation of the service.

9. Your Data Rights

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

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data GemJili holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: 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 our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to request its transfer to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact GemJili's Data Protection Officer using the contact details provided in Section 14 of this policy. We will respond to all valid requests within thirty (30) days, or within such other timeframe as required by applicable law.

10. Children's Privacy

The GemJili platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. GemJili does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the GemJili platform or provided us with personal data, please contact us immediately at the details provided in Section 14 so that we can take appropriate action.

11. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the GemJili platform
• Encryption of sensitive data at rest, including payment information and identity documents
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Regular security audits, vulnerability assessments, and penetration testing
• Multi-factor authentication requirements for account access and administrative systems
• Incident response procedures for the detection, reporting, and management of personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, GemJili will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

While GemJili takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of data transmitted to or from the platform, and you use the platform at your own risk in this regard.

12. International Data Transfers

GemJili primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines — for example, in connection with cloud hosting or technical support services — GemJili will ensure that appropriate safeguards are in place to protect your data in accordance with the requirements of the Data Privacy Act of 2012.

Such safeguards may include contractual clauses approved by the National Privacy Commission, adequacy decisions, or other legally recognized transfer mechanisms. GemJili will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13. Changes to This Privacy Policy

GemJili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material, GemJili will notify registered players by email or through a prominent notice on the platform prior to the changes taking effect. Your continued use of the GemJili platform following the publication of any amendments constitutes your acknowledgment of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how GemJili is protecting your personal data. If you have any concerns about any changes to this policy, please contact our Data Protection Officer before continuing to use the platform.

14. Contact Us and Data Protection Officer

GemJili has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection law. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us using the details below.

You may reach the GemJili Data Protection Officer by email at: [email protected]

For general support queries, you may also contact our customer support team at: [email protected]

GemJili aims to respond to all privacy-related inquiries within fifteen (15) business days. For formal data rights requests, we will respond within thirty (30) days as required by the Data Privacy Act of 2012. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.