SM JILI Privacy Policy

1. Introduction

SM JILI ("we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the SM JILI platform at sm-jili.app (the "Platform"). This Privacy Policy describes how SM JILI collects, uses, stores, shares, and protects personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. By registering for or using the SM JILI Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with SM JILI's Terms and Conditions and Responsible Gaming Policy, both of which are available on the Platform.

2. Data Controller

SM JILI acts as the personal information controller in respect of the personal data collected through the Platform. SM JILI has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Privacy Policy and applicable data protection law. Contact details for the DPO are set out in Section 13 of this Policy.

3. Personal Data We Collect

SM JILI collects the following categories of personal data in connection with your use of the Platform:

Category	Examples	Source
Identity Data	Full legal name, date of birth, government-issued ID number, nationality	Provided by you during registration or KYC verification
Contact Data	Email address, Philippine mobile number, residential address	Provided by you during registration
Financial Data	GCash number, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records	Provided by you or collected via payment processors
Gaming Data	Game history, wager amounts, session duration, bonus usage, win/loss records	Generated automatically through Platform use
Technical Data	IP address, device type, browser type, operating system, session logs	Collected automatically via cookies and server logs
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Generated through your communications with SM JILI

SM JILI does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive information is collected (such as government ID details for KYC purposes), it is handled with additional safeguards as required by the DPA.

4. How We Use Your Personal Data

SM JILI uses the personal data we collect for the following purposes:

• Account Management: To create, verify, and maintain your SM JILI player account, including identity verification and age confirmation (21+ requirement).
• Transaction Processing: To process deposits, withdrawals, and bonus credits via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Regulatory Compliance: To fulfil our obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and Know Your Customer (KYC) requirements as directed by PAGCOR and other relevant authorities.
• Platform Operation: To deliver, maintain, and improve the games, features, and services available on the SM JILI Platform.
• Responsible Gaming: To monitor gaming behaviour, identify signs of problem gambling, and administer self-exclusion, deposit limits, and other responsible gaming tools.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, cheating, money laundering, and other prohibited activities.
• Marketing Communications: To send you promotional offers, bonuses, and platform updates where you have provided consent. You may withdraw consent at any time via your account settings or by contacting support.
• Analytics and Improvement: To analyse Platform usage patterns and improve the user experience for all SM JILI players.

5. Legal Basis for Processing

SM JILI processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and SM JILI (i.e., to operate your account and deliver gaming services).
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including gaming, AML, and tax obligations.
• Legitimate Interests: Processing is necessary for SM JILI's legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided those interests are not overridden by your rights and interests.
• Consent: For marketing communications and certain non-essential cookies, processing is based on your freely given, specific, and informed consent, which you may withdraw at any time.

6. Data Sharing and Disclosure

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

• Payment Processors: GCash, PayMaya, and banking partners (BPI, BDO, Metrobank) to process your financial transactions.
• Identity Verification Providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements.
• Game Providers: Licensed game software providers whose games are available on the SM JILI Platform, to the extent necessary to deliver those games.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law or regulatory direction.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged by SM JILI under strict data processing agreements.
• Professional Advisers: Legal, accounting, and auditing firms engaged by SM JILI, subject to professional confidentiality obligations.

All third-party service providers engaged by SM JILI are required to process personal data only in accordance with SM JILI's instructions and applicable data protection law.

7 . Cookies and Tracking Technologies

SM JILI uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage, and deliver relevant content. The following types of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and security tokens.
• Functional Cookies: Remember your preferences such as language settings and display options to personalise your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform to help us improve performance and content.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent and can be withdrawn at any time via your browser settings or account preferences.

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the SM JILI Platform.

8. Data Retention

SM JILI retains personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by Philippine AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session.
• Support Communications: Retained for two (2) years from the date of the last communication.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with SM JILI's data disposal procedures.

9. Security Measures

SM JILI implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the SM JILI Platform.
• Encryption at rest for all stored personal and financial data.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments.
• Multi-factor authentication for administrative access to SM JILI systems.
• Incident response procedures aligned with the National Privacy Commission's breach notification requirements.

While SM JILI takes all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your SM JILI account credentials.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by SM JILI:

• Right to be Informed: The right to be told how your personal data is being collected and processed — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of the personal data SM JILI holds about you.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected.
• Right to Erasure: The right to request deletion of your personal data, subject to SM JILI's legal and regulatory retention obligations.
• Right to Object: The right to object to 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 format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe SM JILI has not handled your personal data in accordance with the DPA.

To exercise any of these rights, please contact SM JILI's Data Protection Officer using the details in Section 13. SM JILI will respond to verified requests within fifteen (15) business days. We may need to verify your identity before processing your request.

11. Children's Privacy

The SM JILI Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. SM JILI does not knowingly collect personal data from individuals under the age of 21. If SM JILI becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended and the data will be deleted. If you believe a minor has registered on the Platform, please contact our support team immediately.

12. Updates to This Privacy Policy

SM JILI may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. The revised Policy will be posted on this page with an updated effective date. Where changes are material, SM JILI will notify registered players via email or a prominent notice on the Platform. Your continued use of the Platform following notification of any update constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how SM JILI protects your personal data.

13. Contact — Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or SM JILI's handling of your personal data, please contact our Data Protection Officer:

Email: [email protected]
General Support: [email protected]
Response Time: Within 15 business days for formal data requests; within 4–6 hours for general support enquiries.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with SM JILI's response to your privacy concern.