amjilli Privacy Policy

1 Introduction

amjilli ("amjilli," "we," "us," "our") operates the online gaming and sports betting platform accessible at amjilli.co (the "Platform"). amjilli is committed to processing personal data responsibly and in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission of the Philippines.

This Privacy Policy ("Policy") applies to all personal data processed by amjilli in connection with your registration, use of the Platform, payment transactions, and communications with amjilli's support team. It applies to all Members and to visitors who access the Platform without registering.

By accessing the Platform or registering for an amjilli account, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not consent to the terms of this Policy, please do not access or use the Platform.

2 Data Controller

amjilli is the data controller responsible for the personal data collected through the Platform. As data controller, amjilli determines the purposes and means of processing your personal data and is accountable for ensuring that processing is carried out in accordance with applicable Philippine data privacy laws.

amjilli has appointed a Data Protection Officer (DPO) / Privacy Officer, who is responsible for overseeing compliance with this Policy and the Data Privacy Act of 2012. For all data privacy matters, including requests to exercise your data subject rights, please contact the Privacy Officer at [email protected].

3 Personal Data We Collect

amjilli collects the following categories of personal data in connection with the operation of the Platform. Collection is limited to data that is adequate, relevant, and necessary for the stated purposes.

4 How We Collect Your Data

amjilli collects personal data through the following channels:

• Direct Collection: Information you provide when registering for an amjilli account, completing KYC verification, making deposits or withdrawal requests, contacting support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 10 (Cookies & Tracking) for more detail.
• Payment Processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners when you complete a deposit or withdrawal.
• Identity Verification Providers: Data received from third-party KYC verification services engaged by amjilli to assist with age and identity verification in compliance with PAGCOR requirements.
• Fraud Prevention Partners: Risk signals and fraud indicators received from fraud detection services to protect the integrity of the Platform and its Members.

5 Purposes & Legal Basis for Processing

amjilli processes personal data for the following purposes, each of which has a lawful basis under the Data Privacy Act of 2012:

• Account Registration and Management: Processing necessary for the performance of the contract between amjilli and the Member (account terms). Without this data, amjilli cannot provide access to the Platform.
• Payment Processing: Processing necessary for the performance of the contract, and to comply with legal obligations including anti-money laundering (AML) regulations applicable to Philippine gaming operators.
• Identity and Age Verification (KYC): Processing necessary to comply with legal obligations under PAGCOR regulations requiring verification that all Members are aged 21 or above and are who they claim to be.
• Responsible Gaming Monitoring: Processing in amjilli's legitimate interests and to comply with responsible gaming obligations — including monitoring gameplay patterns to identify potential problem gambling indicators.
• Fraud and Security: Processing in amjilli's legitimate interests to protect the Platform and its Members from fraudulent transactions, account takeovers, and other security threats.
• Customer Support: Processing necessary for the performance of the contract and in amjilli's legitimate interests to maintain service quality records.
• Marketing Communications: Processing based on your explicit consent, given during registration or subsequently via your account communication preferences. You may withdraw this consent at any time.
• Legal and Regulatory Compliance: Processing necessary to comply with applicable laws, including responding to lawful requests from PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and courts or law enforcement agencies.

6 Disclosure of Your Data

amjilli does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Personal data may be disclosed to the following categories of recipients, strictly on a need-to-know basis and subject to appropriate confidentiality and data processing obligations:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners require certain data to process your deposit and withdrawal transactions.
• Game Content Providers: Third-party studios (e.g., Pragmatic Play, Evolution Gaming, JILI) may receive session and gameplay data required for game provision and dispute resolution. These providers are contractually bound to process data only for specified purposes.
• Identity Verification Providers: Third-party KYC providers receive identity documentation for age and identity verification, under strict contractual data processing terms.
• Fraud Prevention Services: Risk and fraud data is shared with fraud detection partners to protect the Platform and Members.
• Technology and Infrastructure Providers: Cloud hosting, data storage, and platform infrastructure providers process data as data processors under amjilli's instructions, subject to appropriate data processing agreements.
• Regulatory and Government Authorities: amjilli will disclose personal data to PAGCOR, the National Privacy Commission, the AMLC, the Bureau of Internal Revenue, courts, and law enforcement agencies where required by applicable Philippine law or lawful order.
• Professional Advisers: Legal counsel, auditors, and compliance advisers may access personal data where necessary for the provision of professional services, subject to professional confidentiality obligations.

7 International Data Transfers

7.1 Some of amjilli's service providers and game content partners are located outside the Republic of the Philippines. Where personal data is transferred to recipients in other countries, amjilli ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012 and the National Privacy Commission's rules on cross-border data transfers.

7.2 Safeguards used for international transfers may include: contractual clauses requiring the overseas recipient to protect personal data to standards equivalent to Philippine requirements; verification that the destination country provides an adequate level of data protection; or your explicit consent where applicable.

7.3 To obtain further information about the safeguards applicable to any specific international transfer, please contact the amjilli Privacy Officer at [email protected].

8 Data Retention

8.1 amjilli retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable laws and regulations.

8.2 The following indicative retention periods apply:

• Account and KYC Data: Retained for the duration of your active account plus a minimum of five (5) years after account closure, in compliance with Philippine AML and gaming regulatory requirements.
• Financial Transaction Data: Retained for a minimum of five (5) years after the date of the transaction, as required by AMLC regulations and PAGCOR compliance requirements.
• Gameplay Data: Retained for a minimum of three (3) years for dispute resolution and regulatory reporting purposes.
• Support Communications: Retained for a minimum of two (2) years for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of your membership and for three (3) years following withdrawal of consent or account closure.

8.3 Upon expiry of applicable retention periods, personal data will be securely deleted, destroyed, or anonymised such that it can no longer identify you.

9 Security Measures

amjilli implements technical, organisational, and physical security measures appropriate to the nature of the personal data processed and the risks involved. These measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your device and amjilli's servers is protected by 256-bit TLS/SSL encryption.
• Password Hashing: Member passwords are stored using industry-standard cryptographic hashing functions. Plaintext passwords are never stored or accessible to amjilli staff.
• Access Controls: Internal access to personal data is restricted to amjilli staff and contractors who require it to perform their job functions, subject to role-based access controls and confidentiality obligations.
• Two-Factor Authentication: 2FA is available to all Members and is used internally for staff access to systems containing personal data.
• Vulnerability Management: amjilli conducts regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Incident Response: amjilli maintains a data breach response procedure. In the event of a personal data breach that poses a real risk of serious harm, amjilli will notify the National Privacy Commission and affected data subjects in accordance with applicable legal requirements.

10 Cookies & Tracking Technologies

10.1 amjilli uses cookies and similar tracking technologies on the Platform to enable core functionality, improve performance, and support security and fraud prevention operations. The following cookie types are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that maintain your logged-in state and security cookies that prevent cross-site request forgery. These cookies cannot be disabled without affecting Platform functionality.
• Performance Cookies: Used to collect anonymised data about how Members use the Platform — page load times, error rates, navigation paths — to help amjilli improve the platform experience. Data collected is aggregated and not linked to individual Members.
• Functionality Cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations, so you don't have to reset them on each visit.
• Security and Fraud Prevention Cookies: Used to identify suspicious activity patterns and protect the Platform and its Members against fraud, account takeovers, and bot traffic.

10.2 amjilli does not use third-party advertising cookies or cross-site tracking cookies that share your data with advertising networks for behavioural profiling purposes.

10.3 You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the Platform.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights with respect to your personal data held by amjilli:

• Right to Be Informed: The right to be informed whether amjilli holds personal data about you, and to be provided with information about how it is processed. This Policy fulfils that obligation.
• Right of Access: The right to request a copy of the personal data amjilli holds about you, together with information about the purposes for which it is processed and the categories of recipients to whom it has been disclosed.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. Basic account data (name, mobile number, email) can be updated directly from your account profile. For KYC-related corrections, contact the Privacy Officer.
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing was based solely on consent that you have since withdrawn. Note that this right is subject to amjilli's legal obligations to retain certain data for regulatory compliance purposes.
• Right to Object: The right to object to processing of your personal data based on amjilli's legitimate interests, or processing for direct marketing purposes. Marketing opt-outs can be managed directly from your account communication preferences.
• 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 Damages: The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, or unlawfully obtained personal data, in accordance with the Data Privacy Act.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your rights have not been respected.

To exercise any of the above rights, submit a written request to the amjilli Privacy Officer at [email protected]. amjilli will acknowledge your request within three (3) business days and endeavour to respond fully within fifteen (15) business days. Identity verification may be required before the request is processed.

12 Children's Privacy & Age Restriction

12.1 The amjilli Platform is strictly restricted to individuals who are at least twenty-one (21) years of age. amjilli does not knowingly collect personal data from persons under 21 years of age.

12.2 Age verification is conducted as part of the KYC process for all new Members. Any account found to belong to a person under 21 years of age will be immediately suspended and all personal data associated with the account will be deleted in accordance with applicable law.

12.3 If you are a parent or guardian and believe that a person under 21 years of age has registered for an amjilli account using their information or yours, please contact amjilli immediately at [email protected] so that the account can be investigated and closed.

13 Third-Party Links

The amjilli Platform may contain references to game content or services provided by third-party studios and partners. amjilli is not responsible for the privacy practices of third-party studios or external websites. This Policy applies only to data processed by amjilli through the Platform. amjilli recommends that you review the privacy policies of any third-party providers before engaging with their services.

14 Marketing Communications

14.1 amjilli may send you promotional communications about new games, bonus offers, and Platform updates by SMS, email, or in-platform notification, where you have given your consent to receive such communications.

14.2 You may withdraw your consent to marketing communications at any time by: (a) updating your communication preferences in the amjilli account dashboard; or (b) sending a request to [email protected] with the subject line "Unsubscribe."

14.3 Withdrawal of consent to marketing communications does not affect the lawfulness of processing carried out before withdrawal. It also does not affect amjilli's ability to send you transactional communications relating to your account, such as deposit confirmations, withdrawal notifications, and security alerts, which are sent on the basis of the account contract rather than marketing consent.

15 Changes to This Privacy Policy

15.1 amjilli reserves the right to update or amend this Privacy Policy at any time to reflect changes in the Platform, applicable law, or amjilli's processing activities. Material changes will be communicated to registered Members by in-platform notice or email to the registered address associated with the Member's account, no less than seven (7) days before the changes take effect.

15.2 The version of this Policy bearing the most recent effective date displayed at the top of this page constitutes the current applicable version. Continued use of the Platform after the effective date of any revised Policy constitutes acceptance of the revised terms.

15.3 amjilli maintains an archive of prior versions of this Policy. Requests for prior versions should be directed to the Privacy Officer.

16 Contact — Privacy Officer

For all data privacy inquiries, data subject rights requests, or complaints relating to amjilli's processing of your personal data, please contact the amjilli Privacy Officer using the details below:

• Privacy Inquiries: [email protected]
• General Support: [email protected]
• VIP Support: [email protected]
• Live Chat: Available 24/7 through the amjilli Platform after login.

amjilli will acknowledge privacy-related requests within three (3) business days. If you are not satisfied with amjilli's response to a data privacy complaint, you have the right to escalate your concern to the National Privacy Commission of the Philippines.