phjill Privacy Policy

This Privacy Policy (hereinafter, "the Policy" or "this Policy") is published by phjill (hereinafter, "phjill," "we," "us," or "our"), the operator of the online gaming platform accessible at https://phjill.org and any associated mobile-optimized versions thereof.

This Policy governs the collection, use, storage, disclosure, and protection of Personal Data provided by or collected from individuals (hereinafter, "you," "the User," or "Data Subject") who access, register on, or interact with the phjill platform. It applies to all phjill Members located in the Republic of the Philippines and to all Personal Data processed in connection with the phjill platform, regardless of the channel through which it is collected.

This Policy should be read in conjunction with the phjill Terms and Conditions and the phjill Responsible Gaming Policy, both of which are accessible via links at the bottom of this page and in the site footer. By registering an account or using the phjill platform, you acknowledge that you have read, understood, and agree to the data handling practices described in this Policy.

phjill collects Personal Data through your direct interactions with the platform, through automated technical processes, and — where legally required — through third-party verification services. The categories of Personal Data we collect are summarized in the table below.

phjill processes your Personal Data on the following legal bases under RA 10173:

• Performance of a Contract: Processing necessary to create and manage your Account, execute deposits and withdrawals, and deliver gaming services you have requested.
• Legal Obligation: Processing required to comply with applicable Philippine law, including anti-money laundering regulations, PAGCOR-aligned gaming compliance requirements, and tax obligations.
• Legitimate Interest: Processing necessary for phjill's legitimate business interests, including fraud detection, platform security, responsible gaming monitoring, and improving platform features — provided such interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes for which you have provided explicit, informed consent, including promotional communications and optional analytics participation.

Where processing is based on your consent, you retain the right to withdraw that consent at any time. Withdrawal of consent for an optional processing purpose does not affect the lawfulness of processing conducted prior to withdrawal, and does not prevent phjill from continuing to process your data on other applicable legal bases.

phjill uses the Personal Data it collects for the following specific purposes:

To create and maintain your phjill Account; to verify your identity and eligibility; to process deposits, gameplay, and withdrawals; to credit bonuses and administer promotions; to manage your responsible gaming settings; and to provide customer support.

To detect, investigate, and prevent fraudulent transactions, unauthorized account access, money laundering, collusion, and other prohibited activities. This includes automated analysis of account activity patterns against known fraud indicators and, where applicable, referral of suspicious activity to relevant Philippine authorities.

To comply with applicable Philippine laws and regulations, including anti-money laundering record-keeping requirements, tax reporting obligations, PAGCOR compliance, and responses to lawful requests from courts, regulators, or law enforcement agencies.

To monitor gameplay patterns for indicators of problem gambling behavior, to administer self-exclusion and deposit limit settings, and to fulfill phjill's obligations under responsible gaming standards. This processing is conducted in your interest as well as for legal compliance purposes.

To analyze aggregated, de-identified usage data for the purpose of improving platform features, game selection, payment processing efficiency, and user experience. Individual-level data used for this purpose is anonymized prior to analysis wherever technically feasible.

To send you promotional offers, game updates, and platform news — only where you have provided explicit consent to receive such communications. You may withdraw consent at any time from your Account settings.

phjill does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. phjill may share your Personal Data with the following categories of recipients, and only to the extent necessary for each stated purpose:

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, and other approved payment service providers — to process your deposits and withdrawals. These processors receive only the minimum data necessary to execute the transaction.
• KYC and Identity Verification Providers: Third-party identity verification services used to fulfill age verification and anti-money laundering obligations. These providers process your identity documents under strict data processing agreements.
• Technology and Hosting Providers: Cloud infrastructure and software service providers who host and operate the phjill platform on our behalf. These providers operate as Data Processors and are contractually bound to process your data only on phjill's instructions.
• Regulatory and Law Enforcement Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council, Philippine law enforcement agencies, or courts — where phjill is legally required or compelled to disclose your data by applicable law or lawful order.
• Game Content Providers: Third-party game software providers may receive anonymized or aggregated gameplay data for the purpose of game performance analysis. Individual player identity data is not shared with game providers.

phjill uses cookies and similar tracking technologies on the platform to enable core functionality, enhance your experience, and support security operations. The following categories of cookies are used:

• Essential Cookies: Required for the platform to function. These include session management cookies that keep you logged in during an active session and security cookies that protect against cross-site request forgery. These cannot be disabled without impairing the platform's core functionality.
• Functional Cookies: Store your preferences — such as language settings, game display preferences, and responsible gaming notification settings — so these are retained across sessions without requiring re-entry.
• Analytics Cookies: Collect anonymized data about how the phjill platform is used — including which game categories are most visited, page load performance, and session duration — to support platform improvement. Analytics data is aggregated and de-identified.
• Security Cookies: Support fraud detection by tracking login patterns, device fingerprints, and session anomalies that may indicate unauthorized account access or automated bot activity.

You may configure your browser to refuse or delete cookies; however, disabling essential cookies will prevent you from logging in to your phjill Account. phjill does not use third-party advertising cookies or behavioral targeting cookies that track your activity across other websites.

phjill implements a range of technical and organizational security measures designed to protect your Personal Data against unauthorized access, accidental loss, alteration, or disclosure. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and phjill servers is encrypted in transit using SSL/TLS protocols.
• Password Hashing: Account passwords are stored exclusively as one-way cryptographic hashes. The plain-text password is never stored, logged, or accessible to phjill personnel.
• Access Controls: Access to systems containing Personal Data is restricted to phjill personnel with a legitimate operational need. Access is governed by role-based access controls and reviewed periodically.
• Session Security: User sessions expire automatically after a period of inactivity. Multiple concurrent sessions from different devices may trigger additional verification steps.
• Penetration Testing and Security Audits: The phjill platform undergoes periodic security assessments to identify and remediate vulnerabilities.

Notwithstanding the above, no data transmission over the internet or storage system can be guaranteed as completely secure. phjill will notify affected Members and the National Privacy Commission in the event of a Personal Data breach in accordance with applicable legal requirements under RA 10173.

phjill retains your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal retention obligations. The principal retention periods are as follows:

• Active Account Data: Retained for the duration of your active membership and for a period of five (5) years following voluntary account closure or last account activity, whichever is later.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act (AMLA) and applicable PAGCOR record-keeping requirements. This retention obligation applies regardless of account status or closure requests.
• KYC and Identity Verification Documents: Retained for the period required by applicable AML regulations — a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Support and Communications Records: Retained for three (3) years from the date of the communication, or longer if the communication relates to an ongoing dispute or legal proceeding.
• Technical and Log Data: Retained for twelve (12) months from the date of generation, unless flagged in connection with a security investigation, in which case retention may be extended.

Upon expiry of applicable retention periods, Personal Data is securely deleted or anonymized. Where complete deletion is not technically feasible (for example, in backup systems), data is isolated and protected from further active processing until deletion is possible.

As a Data Subject under RA 10173, you have the following rights in respect of your Personal Data held by phjill. To exercise any of these rights, please contact phjill's Data Protection Officer through the channels set out in Clause 14.

You have the right to be informed about the collection and processing of your Personal Data before or at the time of collection. This Policy constitutes phjill's primary disclosure for this purpose.

You have the right to request a copy of the Personal Data phjill holds about you, together with information about how it is used and with whom it has been shared. Access requests will be responded to within fifteen (15) business days of receipt.

You have the right to request the correction of inaccurate or incomplete Personal Data held in your phjill Account. You may update most Account details directly from your Account settings. For corrections to KYC or identity data, contact support directly.

You have the right to request the deletion of your Personal Data, subject to applicable legal retention obligations. Where deletion is not possible due to a legal retention requirement, phjill will inform you of the reason and the earliest date on which the data can be deleted.

You have the right to object to the processing of your Personal Data based on legitimate interest — in particular, processing for direct marketing purposes. Objections to direct marketing will be honored immediately. Objections to other legitimate-interest processing will be considered against phjill's operational and legal obligations.

You have the right to receive a copy of your Personal Data in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible.

If you believe phjill has not handled your Personal Data in accordance with RA 10173 or this Policy, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). phjill requests that you contact our Data Protection Officer first to allow us to resolve the matter directly; however, your right to approach the NPC directly is unconditional.

The phjill platform is strictly intended for individuals aged twenty-one (21) years and above. phjill does not knowingly collect Personal Data from any individual under the age of 21. Account registration requires confirmation of age eligibility and may require documentary age verification. Where phjill discovers that an Account has been registered by or on behalf of an individual under the age of 21, the Account will be immediately suspended, any deposited funds returned where legally permissible, and all associated Personal Data deleted from active systems.

If you believe that a person under the age of 21 has registered an account on the phjill platform, please notify our support team immediately at the contact details provided in Clause 14 of this Policy.

phjill's primary data processing operations are conducted within the Philippines. Certain third-party service providers engaged by phjill — including cloud infrastructure providers and technology service providers — may process data in jurisdictions outside the Philippines.

Where Personal Data is transferred outside the Philippines, phjill ensures that such transfers are protected by appropriate safeguards, including: contractual data processing agreements that impose equivalent data protection obligations on the recipient; the use of approved standard contractual clauses; or transfers to jurisdictions recognized as providing an adequate level of data protection under applicable standards.

You may request details of any cross-border transfers of your Personal Data and the safeguards in place by contacting our Data Protection Officer.

phjill reserves the right to update this Privacy Policy from time to time. Material changes — defined as modifications that substantially affect your rights or how your Personal Data is processed — will be communicated to you via your registered Philippine mobile number or through an in-platform notification at least seven (7) days before the change takes effect.

Non-material changes, such as typographical corrections, clarifications of existing practices, or updates to reflect regulatory changes, may take effect immediately upon publication. The version number and effective date at the top of this Policy will be updated to reflect the current version at all times.

Your continued use of the phjill platform after the effective date of any amended Policy constitutes your acknowledgment of the update. If you do not accept the revised Policy, you may close your Account and request deletion of your Personal Data subject to applicable retention obligations.

For all privacy-related queries, data subject rights requests, or formal complaints regarding phjill's data handling practices, please contact us through the following channels:

• Data Protection Officer — Email (plain text): [email protected] — please include "Privacy — DPO Request" in the subject line.
• Live Support Chat: Available 24 hours per day, 7 days per week, via the in-platform chat function at phjill.org.
• Support Hours: 8:00 AM to 2:00 AM PHT, daily.

phjill endeavors to acknowledge all formal privacy rights requests and complaints within three (3) business days and to provide a substantive response or resolution within fifteen (15) business days. Complex requests involving large volumes of data or legal analysis may take up to thirty (30) business days, in which case phjill will notify you of the extended timeframe.

If you are not satisfied with phjill's response to your privacy complaint, you may escalate the matter to the National Privacy Commission of the Philippines (NPC) at https://privacy.gov.ph (external government resource — note: this URL is provided for informational reference only and is not a site link).