a9jili Privacy Policy

1 Introduction

a9jili ("a9jili," "we," "us," or "our") is committed to protecting and respecting the privacy of every player who uses the a9jili online gaming platform available at a9jili.cam, including all associated mobile applications and services (collectively, the "Platform"). This Privacy Policy ("Policy") describes the personal data we collect, the purposes for which we process it, the parties with whom we may share it, and the rights available to you as a data subject under Philippine law.

This Policy applies to all registered a9jili players in the Philippines, including players in Metro Manila, Cebu City, Davao, Makati, Quezon City, and all other regions of the country. By registering an account and using the a9jili Platform, you acknowledge that you have read and understood this Policy and consent to the data processing practices described herein.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations ("DPA"), the data controller responsible for your personal data is a9jili, operating the Platform at a9jili.cam.

a9jili has designated a Data Privacy Officer (DPO) responsible for overseeing this Policy and handling data-related inquiries. You may contact the DPO at the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

a9jili collects the following categories of personal data in connection with your use of the Platform:

4 How We Collect Your Data

a9jili collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, using responsible gaming tools, or contacting customer support;
• Automated technologies: Cookies, pixel tags, and similar tracking technologies that collect device and behavioral data when you access or interact with the Platform (see Section 7);
• Third-party payment providers: Transaction confirmation data transmitted by GCash, Maya, BPI, BDO, and other payment processors when you complete a financial transaction;
• Identity verification partners: Information returned by KYC verification services when you upload government-issued identification documents;
• Fraud prevention and security services: Risk signals and behavioral data from security analytics tools that help detect unauthorized account access or suspicious activity.

5 Purpose of Processing & Legal Basis

a9jili processes your personal data for the following purposes, each grounded in a recognized legal basis under the Philippine DPA:

• Account creation and management: To register and maintain your a9jili player account. Legal basis: performance of contract.
• Identity and age verification: To confirm that you are at least 21 years of age and to satisfy Know Your Customer (KYC) obligations. Legal basis: legal obligation; legitimate interest.
• Payment processing: To process deposits and withdrawals via GCash, Maya, and other supported payment methods. Legal basis: performance of contract.
• Anti-money laundering (AML) compliance: To monitor and report transactions that may indicate money laundering or other financial crimes in compliance with the Philippine Anti-Money Laundering Act (AMLA). Legal basis: legal obligation.
• Game provision and Platform operation: To deliver games, record gaming activity, and ensure Platform functionality. Legal basis: performance of contract.
• Responsible gaming: To monitor gaming behavior for signs of problem gambling and to process self-exclusion or limit requests. Legal basis: legitimate interest; legal obligation.
• Customer support: To respond to inquiries, resolve disputes, and process complaints. Legal basis: performance of contract; legitimate interest.
• Security and fraud prevention: To detect, investigate, and prevent unauthorized access, fraud, cheating, and other harmful activities. Legal basis: legitimate interest; legal obligation.
• Marketing communications: To send you promotional offers and platform updates where you have opted in. Legal basis: consent. You may withdraw consent at any time via account settings.
• Legal and regulatory compliance: To comply with applicable Philippine laws, regulatory directions, and court orders. Legal basis: legal obligation.

6 Data Sharing & Disclosure

a9jili does not sell your personal data to third parties. We may share your data in the following circumstances:

• Payment service providers: GCash, Maya, BPI, BDO, Metrobank, UnionBank, Visa, Mastercard, and other payment processors receive transaction data necessary to process deposits and withdrawals. These providers are subject to their own data protection obligations.
• Identity verification and KYC partners: Third-party KYC service providers that process identity document data on our behalf to fulfill age and identity verification requirements.
• Game content providers: Certified game providers such as JILI Games, PG Soft, and Pragmatic Play receive session data necessary to deliver games and calculate results. These providers are bound by contractual data protection obligations.
• Fraud prevention and security providers: Specialized cybersecurity and fraud detection services that process risk signals on our behalf to protect the Platform and its players.
• Regulatory and law enforcement authorities: Philippine government agencies, including the Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), and law enforcement bodies, where disclosure is required by law or court order.
• Professional advisers: Legal counsel, auditors, and other professional advisers who are bound by professional confidentiality obligations.

7 Cookies & Tracking Technologies

The a9jili Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, measure Platform performance, and support security functions.

The types of cookies used on the a9jili Platform include:

• Essential cookies: Necessary for the Platform to function, including session management, login authentication, and security tokens. These cannot be disabled without impairing Platform functionality.
• Performance cookies: Used to collect anonymous data about how players navigate the Platform, which pages are visited most frequently, and where errors occur. This data is used to improve Platform performance.
• Functionality cookies: Used to remember your preferences, such as language settings and display options, so you don't need to reconfigure them on each visit.
• Security cookies: Used to detect fraudulent login attempts, bot activity, and other unauthorized behaviors.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent you from using certain features of the a9jili Platform, including logging into your account.

8 Data Retention

a9jili retains your personal data for as long as is necessary to fulfill the purposes described in this Policy, subject to any longer retention periods required by applicable Philippine law.

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following permanent account closure, in compliance with AMLA record-keeping requirements.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, consistent with AMLA obligations.
• Gaming session data: Retained for a minimum of three (3) years for regulatory compliance and dispute resolution purposes.
• Support communications: Retained for two (2) years from the date of resolution.
• Marketing data: Retained until you withdraw consent or request deletion, subject to legal minimum periods.

When data is no longer required and no legal obligation mandates its retention, a9jili will securely delete or anonymize it in a manner that prevents reconstruction of the personal data.

9 Security Measures

a9jili implements a layered set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and a9jili servers is encrypted using 256-bit SSL/TLS encryption;
• Password security: Player passwords are stored using industry-standard one-way cryptographic hashing and salting. a9jili staff cannot access your plaintext password;
• Two-factor authentication (2FA): SMS OTP-based 2FA is available for all a9jili accounts and is strongly recommended;
• Access controls: Internal access to player data is restricted on a need-to-know basis, with detailed access logs maintained;
• Intrusion detection and monitoring: Automated systems continuously monitor the Platform for unauthorized access attempts, unusual activity, and known attack vectors;
• Data segregation: Player funds and personal data are stored in segregated environments with separate access credentials and audit trails;
• Regular security assessments: a9jili conducts periodic security audits and penetration testing to identify and remediate vulnerabilities.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by a9jili:

To exercise any of these rights, please contact the a9jili Data Privacy Officer at the details provided in Section 14. a9jili will respond to your request within thirty (30) days of receipt. In complex cases, this may be extended by an additional sixty (60) days with prior notice.

11 Minors & Age Restriction

The a9jili Platform is strictly for individuals aged 21 years and above, in accordance with Philippine law governing online casino gambling. a9jili does not knowingly collect personal data from individuals under the age of 21.

a9jili employs mandatory age verification procedures at registration. If a9jili discovers that personal data has been collected from an individual under 21 years of age, the account will be immediately and permanently closed, all collected data will be deleted in accordance with our obligations, and any funds held in the account will be handled in accordance with applicable regulations.

If you are a parent or guardian and believe your minor child has registered on the a9jili Platform, please contact us immediately at the details in Section 14.

12 Cross-Border Data Transfers

Some of a9jili's service providers and technical infrastructure partners may operate outside the Philippines. Where your personal data is transferred to a jurisdiction outside the Philippines, a9jili ensures that appropriate safeguards are in place as required by the Philippine DPA. These safeguards include:

• Standard contractual clauses that bind the recipient to DPA-equivalent data protection standards;
• Transfers only to jurisdictions that the NPC has recognized as providing adequate data protection;
• Binding corporate rules applicable to transfers within a9jili's corporate group where applicable.

a9jili primary game and player data is stored on servers maintained within the Asia-Pacific region to minimize latency for Philippine players and to reduce the frequency of cross-border transfers where possible.

13 Changes to This Privacy Policy

a9jili may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. The most current version of this Policy will always be available at a9jili.cam/privacy-policy, with the "Last Updated" date revised accordingly.

For material changes that affect how we use your personal data or your rights as a data subject, a9jili will provide advance notice via the Platform's in-app notification system or to your registered contact details prior to the effective date of the change. Your continued use of the a9jili Platform after the effective date constitutes acceptance of the updated Policy.

If you do not agree with the updated Policy, you should cease using the Platform and request account closure before the effective date of the change.

14 Contact & Data Privacy Officer

For questions, requests to exercise your data rights, or concerns about this Privacy Policy, please contact the a9jili Data Privacy Officer (DPO):

• Live Chat: Available 24/7 through the a9jili Platform — fastest response channel
• Email (DPO): [email protected] — please include "Privacy Request" in your subject line
• Platform: a9jili.cam