asjili Privacy Policy

1. Data Controller Information

asjili is the data controller responsible for the personal information of users of the asjili Platform at asjili.cam. As data controller, asjili determines the purposes and means of processing your personal data and is accountable for its protection in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

asjili operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing activities are conducted in compliance with both PAGCOR requirements and the data privacy obligations established by the National Privacy Commission (NPC) of the Philippines.

2. Personal Data We Collect

asjili collects the following categories of personal data from players and website visitors:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, government ID number	Account registration, KYC age and identity verification
Contact Data	Email address, mobile number, residential address	Account communications, support, notifications
Financial Data	GCash number, PayMaya number, bank account details, transaction history	Processing deposits, withdrawals, and AML compliance
KYC Documents	Scanned government-issued ID, proof of address documents	Identity verification, PAGCOR and AML compliance
Gaming Activity Data	Game history, bet amounts, session duration, win/loss records	Platform operation, responsible gaming monitoring, PAGCOR reporting
Technical Data	IP address, device type, browser, operating system, session logs	Security, fraud detection, platform optimization
Marketing Preferences	Communication opt-in/opt-out status, promotional preferences	Sending promotional offers and bonuses (with consent)

We do not collect sensitive personal information beyond what is strictly necessary for KYC identity verification and PAGCOR regulatory compliance. We do not collect biometric data, political opinions, religious beliefs, or health information except where an identity document incidentally includes such information (e.g., government IDs displaying birth dates for age verification purposes).

3. How We Collect Your Data

asjili collects your personal data through the following channels:

• Directly from you: Information you provide when registering an Account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automatically: Technical data collected passively when you use the Platform, including IP address, device identifiers, browser type, session logs, and gameplay activity data generated through your use of the Platform.
• From third parties: Identity verification data provided by our licensed KYC service providers; transaction data from payment processors (GCash, PayMaya, BPI, BDO, Metrobank); fraud and risk signals from security service providers; and regulatory information from PAGCOR where required by law.

4. Purposes & Legal Basis for Processing

asjili processes your personal data for the following purposes and on the following legal bases under the Data Privacy Act of 2012:

• Account Registration & Management: Processing is necessary to perform the contract between you and asjili — specifically, to create and maintain your Account and enable you to access the Platform's gaming services.
• KYC Identity & Age Verification: Processing is required by law — asjili is legally obligated under PAGCOR regulations to verify that all players are at least 21 years of age and to confirm their identity before processing withdrawals.
• Payment Processing: Processing is necessary to perform the contract — to execute your deposit and withdrawal transactions in Philippine Peso via your chosen payment method.
• Anti-Money Laundering (AML) Compliance: Processing is required by law — asjili is obligated under Philippine AML regulations to monitor transactions and report suspicious activity to the appropriate Philippine authorities.
• Customer Support: Processing is necessary to perform the contract — to investigate and resolve account queries, technical issues, and complaints.
• Responsible Gaming Monitoring: Processing is in the legitimate interest of asjili and the player — to identify patterns of gaming behavior that may indicate problem gambling and to apply appropriate responsible gaming interventions.
• Platform Security & Fraud Prevention: Processing is in asjili's legitimate interest — to detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Marketing & Promotions: Processing is based on your consent — we will send you promotional emails and notifications only if you have opted in. You may withdraw this consent at any time.
• PAGCOR Regulatory Reporting: Processing is required by law — asjili is obligated to maintain gaming records and submit reports to PAGCOR as required by our operating license conditions.

5. Sharing & Disclosure of Personal Data

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

• Game Providers: Licensed game software providers (e.g., JILI Gaming, Pragmatic Play, Evolution Gaming, PG Soft) receive limited player session data necessary to render games and manage game sessions. These providers are contractually bound to process data only on asjili's instructions.
• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers receive the financial information necessary to process your deposit and withdrawal transactions in PHP.
• KYC & Identity Verification Providers: Licensed third-party KYC verification services that process your identity documents on asjili's behalf for age and identity verification purposes.
• PAGCOR & Government Authorities: asjili may disclose your personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), law enforcement agencies, or other Philippine government authorities where required by law, court order, or regulatory mandate.
• Security & Fraud Prevention Providers: Third-party fraud detection services that analyze technical data to identify suspicious account activity or unauthorized access attempts.
• Professional Advisers: Lawyers, auditors, and compliance consultants who require access to your data in connection with their professional services to asjili, subject to confidentiality obligations.

All third parties with whom asjili shares personal data are contractually required to implement appropriate technical and organizational data protection measures and to process your data only for the specified purpose and under asjili's instructions.

6. Data Retention

asjili retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account Data: Retained for the duration of your active Account plus a minimum of five (5) years following Account closure, in compliance with PAGCOR record-keeping requirements and AML regulations.
• KYC Documents: Retained for a minimum of five (5) years from the date of document submission or from the date your Account is closed, whichever is later, as required under Philippine AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction in compliance with AMLC and BIR record-keeping obligations.
• Gaming Activity Logs: Retained for a minimum of two (2) years from the date of activity for operational, responsible gaming, and PAGCOR reporting purposes.
• Customer Support Records: Retained for three (3) years from the date of last interaction for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the period of your opt-in consent plus three (3) years to demonstrate compliance with consent obligations.

When personal data is no longer required and no legal retention obligation applies, asjili securely destroys or anonymizes such data in a manner that prevents reconstruction of the original information.

7. Data Security Measures

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

• Transport Encryption: All data transmitted between your device and the asjili Platform is encrypted using 256-bit SSL/TLS protocols.
• Data Encryption at Rest: Sensitive personal data (including KYC documents and financial information) stored on our servers is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to asjili personnel and authorized third-party processors who require it for their specific role. Access is governed by role-based permissions and requires multi-factor authentication.
• Intrusion Detection: Our infrastructure is monitored 24/7 by automated intrusion detection and prevention systems.
• Regular Security Audits: asjili engages independent cybersecurity specialists to conduct periodic penetration testing and security audits of the Platform and underlying infrastructure.
• Staff Training: All asjili personnel handling personal data receive mandatory data privacy training at onboarding and annually thereafter.
• Incident Response: In the event of a personal data breach that poses a real risk of serious harm to affected data subjects, asjili will notify the National Privacy Commission (NPC) within 72 hours of discovery and will notify affected players without undue delay, in accordance with NPC Circular 16-03.

While we implement robust security measures, no internet-based service can guarantee absolute security. Players are also responsible for maintaining the security of their Account credentials and for immediately notifying asjili of any suspected unauthorized access.

8. Cookies & Tracking Technologies

The asjili Platform uses cookies and similar tracking technologies to enhance your experience, analyze Platform usage, and support security functions. The following types of cookies may be placed on your device:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled. They include session management cookies, authentication tokens, and fraud prevention cookies.
• Performance & Analytics Cookies: Collect aggregated, anonymized data about how visitors use the Platform to help us improve functionality and user experience.
• Functional Cookies: Remember your preferences (such as language settings and game history) to provide a more personalized experience.
• Security Cookies: Used to detect fraudulent activity, unauthorized logins, and other security threats.

You may control cookie settings through your browser preferences. Note that disabling certain cookies may affect the functionality of the asjili Platform, including your ability to log in or play games. asjili does not use cookies to track your activity across third-party websites unrelated to the Platform.

9. Children's Privacy

The asjili Platform is strictly intended for individuals aged 21 years and older in accordance with PAGCOR regulations. asjili does not knowingly collect personal data from any individual under the age of 21. All Accounts are subject to mandatory KYC age verification before withdrawals are processed.

If asjili becomes aware that personal data has been collected from an individual under 21, the associated Account will be immediately suspended, the personal data will be securely deleted, and any funds held in the Account will be handled in accordance with our Terms & Conditions and applicable PAGCOR guidelines.

If you are a parent or guardian and believe that a minor in your care has registered on the asjili Platform, please contact us immediately at [email protected] so we can investigate and take appropriate action.

10. Cross-Border Data Transfers

Some of asjili's third-party service providers — including certain game providers, technical infrastructure providers, and KYC verification services — may be located outside the Philippines. Where personal data is transferred to a recipient in a foreign country, asjili ensures that adequate data protection safeguards are in place, including:

• Contractual clauses binding the foreign recipient to data protection standards equivalent to those required under the Philippine Data Privacy Act;
• Transfers to countries recognized by the National Privacy Commission as providing an adequate level of data protection; and/or
• Other lawful transfer mechanisms approved by the National Privacy Commission.

asjili will not transfer your personal data to a foreign jurisdiction where such transfer would violate Philippine law or where the receiving jurisdiction does not provide adequate protection for your personal data rights.

11. Exercising Your Data Subject Rights

To exercise any of your rights under the Philippine Data Privacy Act of 2012 — including the right to access, rectify, erase, object to processing, or request portability of your personal data — please submit a written request to our Data Protection Officer using the contact details provided in Section 12 below.

Your request should include:

• Your full name as registered on your asjili Account;
• Your Account ID or registered email address for identification purposes;
• A clear description of the right you wish to exercise and the specific data concerned;
• A copy of a valid government-issued ID for identity verification purposes.

asjili will acknowledge your request within five (5) business days and will respond substantively within fifteen (15) business days of receiving a complete and verified request. In complex cases requiring additional time, we will notify you of the extended timeline and the reason for the extension, as permitted by the Data Privacy Act.

We will not charge a fee for processing a data subject rights request unless the request is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable administrative fee or refuse to act on the request.

12. Data Protection Officer

In compliance with Section 21 of the Philippine Data Privacy Act of 2012, asjili has designated a Data Protection Officer (DPO) responsible for overseeing our data protection strategy and ensuring compliance with all applicable data privacy regulations.

You may contact asjili's Data Protection Officer for any privacy-related inquiries, data subject rights requests, or to report a suspected privacy breach:

• Email: [email protected] (Subject line: "Data Privacy Request – [Your Name]")
• Live Chat: Available 24/7 via the asjili Platform (request to speak with the Data Privacy team)
• Response Time: Initial acknowledgment within 5 business days; full response within 15 business days

13. Changes to This Policy

asjili reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine laws and regulations, or PAGCOR requirements. We will notify registered Players of material changes by:

• Posting a prominent notice on the asjili Platform for at least 30 days prior to the effective date of the change; and/or
• Sending an email notification to the registered email address on your Account.

The "Last Updated" date at the top of this Policy will be revised to reflect the date of any update. Your continued use of the asjili Platform after the effective date of a revised Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must cease using the Platform and contact us to request Account closure.

14. Contact Us

For any questions, concerns, or complaints regarding this Privacy Policy or asjili's data handling practices, please contact us through the following channels:

• 24/7 Live Chat: Available directly on the asjili Platform
• Email: [email protected]

If you are unsatisfied with our response to a privacy concern, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). The NPC oversees compliance with the Data Privacy Act of 2012 and can be contacted through the NPC's official channels in the Philippines.