amjili Privacy Policy

1. Introduction

Welcome to the amjili Privacy Policy. amjili ("amjili," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the amjili online gaming platform at amjili.club (the "Platform").

This Privacy Policy describes how amjili collects, uses, stores, shares, and protects your personal information when you register an account, access the Platform, place bets, make deposits or withdrawals, contact our support team, or otherwise interact with amjili's services.

This Policy is intended to comply with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. It should be read together with our Terms & Conditions and Responsible Gaming Policy, which are incorporated herein by reference.

By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, amjili acts as the personal information controller in respect of the personal data collected through the Platform. amjili is responsible for determining the purposes and means of processing your personal data.

amjili has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data protection laws and this Privacy Policy. You may contact the DPO at any time using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

amjili collects the following categories of personal data from players and Platform visitors:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth and age verification documents
• Philippine mobile number and email address
• Residential address (barangay, city/municipality, province)
• Government-issued identification numbers (e.g., passport, driver's license, SSS/UMID, PhilSys ID)
• Selfie or photograph for identity verification purposes

3.2 Financial Data

• GCash or PayMaya account details (mobile number associated with the account)
• Bank account details for bank transfer transactions (account name, account number, bank name)
• Debit card details (card number, expiry date — stored in tokenized form only)
• Transaction history, including deposit amounts, withdrawal amounts, and dates

3.3 Gaming and Account Data

• amjili username and account ID
• Betting history, game session records, and wagering activity
• Bonus and promotion usage history
• Responsible gaming settings (deposit limits, session limits, self-exclusion status)
• Customer support interaction records and chat transcripts

3.4 Technical and Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the Platform
• Login timestamps and session duration
• Referral source and marketing attribution data

4. How We Collect Your Data

amjili collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer 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.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment verification data from payment processors such as GCash and Maya; and publicly available information where relevant to regulatory compliance.

amjili does not collect sensitive personal information (as defined under the DPA, such as health data, political opinions, or religious beliefs) unless specifically required for responsible gaming purposes (e.g., self-exclusion requests citing problem gambling).

5. How We Use Your Personal Data

amjili uses your personal data for the following purposes:

• Account management: To register and maintain your amjili account, verify your identity, and manage your player profile.
• Service delivery: To provide access to games, process bets, manage deposits and withdrawals, and deliver customer support.
• Legal and regulatory compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, PAGCOR regulatory requirements, and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and apply responsible gaming tools requested by players.
• Platform improvement: To analyze usage patterns, troubleshoot technical issues, and improve the features and performance of the amjili Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where permitted by applicable law. You may opt out at any time.
• Dispute resolution: To investigate and resolve disputes, complaints, and legal claims involving your account.

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your amjili account and deliver gaming services.
• Legal obligation: Processing required to comply with applicable laws, including AML regulations, KYC requirements, and PAGCOR licensing conditions.
• Legitimate interests: Processing necessary for amjili's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7. Data Sharing and Disclosure

amjili does not sell or rent your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, Maya, and partner banks to process deposits and withdrawals. These providers act as independent data controllers for their own services.
• KYC and identity verification providers: Third-party services that assist amjili in verifying player identities and age in compliance with regulatory requirements.
• Fraud prevention and AML partners: Services that help amjili detect and prevent fraudulent transactions and money laundering activity.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law or regulatory obligation.
• Law enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or applicable law.
• IT and platform service providers: Cloud hosting, data analytics, and customer support technology providers who process data on amjili's behalf under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party service providers who process personal data on amjili's behalf are required to implement appropriate technical and organizational security measures and to process data only in accordance with amjili's instructions and applicable law.

8. Data Retention

amjili retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Active account data: Retained for the duration of your amjili account and for a minimum of five (5) years after account closure, in compliance with AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 and its amendments.
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by a regulatory authority.
• Customer support records: Retained for three (3) years from the date of the interaction, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year to demonstrate compliance.
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods for security investigations.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with amjili's data disposal procedures.

9. Data Security

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

• Encryption: All data in transit is protected using TLS 1.2 or higher. Sensitive data at rest, including payment details and identity documents, is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized amjili personnel on a strict need-to-know basis. All staff with access to personal data undergo data privacy training.
• Two-factor authentication: amjili supports and encourages the use of two-factor authentication (2FA) for player accounts to prevent unauthorized access.
• Regular security audits: amjili conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities.
• Incident response: amjili maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, amjili will notify the National Privacy Commission and affected players within the timeframes required by the DPA.

While amjili takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your amjili account credentials and for notifying us immediately if you suspect unauthorized access to your account.

10. Cookies and Tracking Technologies

amjili uses cookies and similar tracking technologies to operate the Platform, improve your experience, and analyze usage patterns. A cookie is a small text file placed on your device when you visit the Platform.

10.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits to provide a more personalized experience.
• Analytics cookies: Help amjili understand how players use the Platform by collecting aggregated, anonymized usage data. This helps us improve features and fix issues.
• Marketing cookies: Used to deliver relevant promotional content to you based on your interests and activity on the Platform. These are only set with your consent.

10.2 Managing Cookies

You can 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 Platform. Instructions for managing cookies are available in your browser's help documentation.

amjili does not use cookies to collect sensitive personal information or to track your activity on third-party websites outside of the amjili Platform.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by amjili:

• Right to be informed: The right to be notified of how your personal data is collected and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data amjili holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update basic account information directly through your amjili account settings.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to amjili's legal retention obligations.
• Right to object: The right to object to the 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, and machine-readable format where processing is based on consent or contract.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe amjili has violated your data privacy rights.

To exercise any of these rights, please contact the amjili Data Protection Officer using the details in Section 15. amjili will respond to all verified data subject requests within fifteen (15) business days, as required by the DPA.

12. Minors and Age Restriction

The amjili Platform is strictly intended for individuals who are at least 21 years of age. 21+ amjili does not knowingly collect personal data from individuals under 21 years of age.

If amjili discovers or has reason to believe that a registered player is under 21 years of age, the account will be suspended immediately, all personal data associated with the account will be deleted (subject to any legal retention obligations), and any funds in the account will be handled in accordance with applicable regulations.

If you are a parent or guardian and believe that your child under 21 has registered an amjili account or provided personal data to amjili, please contact us immediately at the details provided in Section 15 so that we can take appropriate action.

13. International Data Transfers

amjili primarily processes and stores personal data within the Philippines. In some cases, personal data may be transferred to or accessed by service providers located outside the Philippines — for example, cloud infrastructure providers or technology partners operating in other jurisdictions.

Where personal data is transferred outside the Philippines, amjili ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual data processing agreements incorporating standard data protection clauses, or transfers to jurisdictions recognized as providing adequate data protection.

amjili will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.

14. Changes to This Privacy Policy

amjili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, amjili will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. We encourage you to review this Policy periodically to stay informed about how amjili protects your personal data.

Your continued use of the amjili Platform after the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure.

15. Contact Us and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way amjili handles your personal data, please contact our Data Protection Officer:

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 within your amjili account dashboard

amjili will acknowledge all privacy-related inquiries within three (3) business days and will provide a substantive response within fifteen (15) business days of receiving a verified request.

If you are not satisfied with amjili's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC) — the Philippine government body responsible for administering and implementing the Data Privacy Act of 2012.