jill5 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how jill5 ("jill5," "we," "our," or "us") collects, uses, stores, shares, and protects personal information in connection with your use of the jill5 online gaming platform accessible at jill5.net, including all associated services, games, features, and functionality (collectively, the "Platform").

jill5 is committed to protecting the privacy and security of our players' personal information. We understand that Filipino players trust us with sensitive data — including financial details and identity documents — and we take that responsibility seriously. This Policy is designed to be clear, honest, and comprehensive so you fully understand what happens to your data when you use jill5.

This Policy applies to all personal data collected through the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and your general use of the jill5 website and any associated mobile applications.

This Policy should be read together with our Terms and Conditions and Responsible Gaming Policy, both of which are available on the jill5 Platform and incorporated herein by reference.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, jill5 acts as the personal information controller in respect of all personal data collected through the Platform.

As the personal information controller, jill5 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law. Our designated Data Protection Officer (DPO) oversees our compliance with this Policy and all applicable privacy regulations.

If you wish to exercise any of your rights under applicable data protection law, or if you have questions or concerns regarding the handling of your personal data, you may contact our Data Protection Officer using the contact details provided in Section 15 of this Policy.

3 Personal Data We Collect

jill5 collects several categories of personal data in the course of providing the Platform and its associated services. The specific data collected depends on your level of engagement with the Platform. The following table outlines the main categories of personal data we collect:

jill5 does not collect special categories of personal data such as health data, biometric data, religious beliefs, or political opinions, unless explicitly required by law or with your express consent for a specific purpose.

4 How We Collect Your Data

jill5 collects personal data through a variety of methods, depending on how you interact with the Platform:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, respond to a survey, or update your account profile.
• Automatically through the Platform: Technical and usage data is collected automatically when you access and navigate the jill5 Platform, including via cookies, web beacons, pixel tags, and server logs. See Section 9 for full details on our cookie practices.
• From third-party identity verification providers: Where you provide consent for identity checks, we may receive verification results and supporting data from third-party KYC service providers.
• From payment processors: When you initiate a deposit or withdrawal, relevant transaction data is shared between jill5 and the payment provider (e.g., GCash, PayMaya, BPI) to process and confirm the transaction.
• From fraud prevention and AML screening services: jill5 may receive risk signals and flagged data from third-party compliance screening services as part of our anti-money laundering and fraud prevention obligations.
• From publicly available sources: In certain circumstances, jill5 may verify information you have provided by cross-referencing with publicly accessible records, such as those maintained by Philippine government agencies.

5 Purpose & Legal Basis for Processing

jill5 processes your personal data only for specified, legitimate purposes. The following table outlines the primary purposes for which we process personal data and the legal basis for doing so under the Philippine Data Privacy Act of 2012:

Where jill5 relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, please contact our Data Protection Officer using the details in Section 15.

6 Data Sharing & Disclosure

jill5 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We share personal data only in the following circumstances and only to the extent strictly necessary:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, 7-Eleven, Cebuana, and other payment service providers require transaction data to process deposits and withdrawals.
• Identity verification providers: Third-party KYC and document verification services receive identity data to conduct verification checks required for account activation and ongoing compliance.
• Game providers and software suppliers: Game providers integrated into the jill5 Platform may receive your player ID and gaming session data to operate game functionality.
• Fraud prevention and AML compliance services: Compliance screening providers receive flagged transaction or account data to fulfil our anti-money laundering obligations.
• IT and hosting providers: Cloud infrastructure and hosting providers process data on our behalf to operate and maintain the jill5 Platform securely.
• Philippine regulatory and law enforcement authorities: jill5 is required by law to report certain transactions and to disclose personal data upon receipt of a valid legal order or request from PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities.
• Business transfers: In the event of a merger, acquisition, or sale of jill5's business assets, your personal data may be transferred to the acquiring entity, subject to equivalent data protection safeguards.

All third-party service providers who process personal data on behalf of jill5 are bound by contractual data processing agreements that require them to process personal data only on jill5's documented instructions, maintain appropriate security measures, and comply with applicable data protection law.

7 Data Retention

jill5 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law, whichever is longer. The retention periods we apply are as follows:

• Active account data: Retained for the duration of your account's active status, plus a post-closure period as required by law.
• KYC and identity verification records: Retained for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations and AMLC record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with Philippine financial regulations.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required to resolve an ongoing dispute or regulatory inquiry.
• Marketing consent records: Retained for as long as your consent is active, plus one (1) year following withdrawal of consent, to demonstrate compliance.
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods in connection with a security incident, fraud investigation, or legal proceeding.

When personal data is no longer required and no legal retention obligation applies, jill5 securely deletes or anonymises such data in accordance with our internal data disposal procedures.

8 Data Security

jill5 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes, but is not limited to:

• Encryption in transit: All data transmitted between your device and jill5 servers is encrypted using TLS (Transport Layer Security) protocol.
• Encryption at rest: Sensitive personal data stored in jill5 databases, including identity documents and financial account details, is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. Employees and contractors with access to personal data are bound by confidentiality obligations and receive regular data protection training.
• Multi-factor authentication: Internal systems housing personal data require multi-factor authentication for all administrative access.
• Security monitoring: jill5 operates continuous security monitoring and intrusion detection systems to identify and respond to potential threats in real time.
• Vulnerability management: Regular penetration testing and vulnerability assessments are conducted on the jill5 Platform and supporting infrastructure.
• Incident response: jill5 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights, jill5 will notify the National Privacy Commission and affected players in accordance with applicable breach notification requirements.

9 Cookies & Tracking Technologies

jill5 uses cookies and similar tracking technologies (collectively, "cookies") to operate and improve the Platform, remember your preferences, analyse usage patterns, and support our security and fraud prevention measures.

The following types of cookies are used on the jill5 Platform:

• Strictly Necessary Cookies: Essential for the Platform to function. These cookies enable core features such as account authentication, session management, and security controls. They cannot be disabled without breaking Platform functionality.
• Functional Cookies: Allow the Platform to remember your preferences, such as your language settings, game lobby filters, and notification preferences, to provide a more personalised experience.
• Analytics Cookies: Help jill5 understand how players use the Platform by collecting aggregated, anonymised usage data. This data is used to identify areas for improvement and measure the effectiveness of new features.
• Security Cookies: Used to detect fraudulent activity, suspicious login attempts, and potential automated bot activity on the Platform.

Most web browsers allow you to manage cookie settings through the browser's preferences menu. You can choose to block or delete cookies; however, disabling strictly necessary cookies may affect your ability to log in and use core Platform features.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you hold the following rights in respect of your personal data held by jill5:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfils that obligation.
• Right to Access: You may request a copy of the personal data jill5 holds about you, along with information about how it is being processed.
• Right to Rectification: If any personal data jill5 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure: Subject to applicable legal retention obligations, you may request that jill5 delete personal data that is no longer necessary for the purposes for which it was collected.
• Right to Object: You have the right to object to the processing of your personal data where jill5 relies on legitimate interest as the legal basis, unless jill5 can demonstrate compelling legitimate grounds that override your interests.
• Right to Data Portability: Where technically feasible and permitted by law, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of prior processing.
• Right to Lodge a Complaint: If you believe jill5 has processed your personal data in violation of applicable law, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the rights listed above, please submit a written request to our Data Protection Officer using the contact details in Section 15. jill5 will respond to all verified data rights requests within fifteen (15) business days of receipt.

11 Children's Privacy

The jill5 Platform is strictly intended for adults who are at least 21 years of age, in accordance with the minimum age requirement for participation in casino-style gaming activities under applicable Philippine regulations. jill5 does not knowingly collect personal data from individuals under the age of 21.

Age verification is conducted as part of the KYC process during account registration. Where jill5 discovers or reasonably suspects that an account has been registered by a person under 21 years of age, the account will be suspended immediately, all associated balances (including any winnings) will be forfeited, and any personal data collected in connection with the minor's account will be securely deleted in accordance with our data disposal procedures.

12 International Data Transfers

Some of jill5's service providers, including game software suppliers, cloud hosting providers, and identity verification services, may process personal data outside of the Philippines. Where personal data is transferred to a recipient in a country that does not provide an equivalent level of data protection to the Philippines, jill5 will put in place appropriate safeguards to ensure that your personal data remains protected to the standard required under Philippine law.

Such safeguards may include contractual data processing agreements incorporating standard contractual clauses approved for use under the Philippine Data Privacy Act, or other transfer mechanisms recognised by the National Privacy Commission.

By using the jill5 Platform, you acknowledge and consent to your personal data being transferred to and processed in countries outside the Philippines as described in this section, subject to the safeguards described above.

13 Third-Party Links

The jill5 Platform may, from time to time, contain references to third-party services or providers in an informational context. Please be aware that jill5 has no control over the privacy practices of third-party websites or platforms and is not responsible for their content or privacy policies.

This Privacy Policy applies solely to personal data collected by jill5 through the jill5 Platform. We encourage you to review the privacy policy of any third-party service you interact with, particularly those handling financial transactions on your behalf (such as GCash or PayMaya), to understand how they process your personal data.

14 Policy Updates

jill5 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or the structure of the jill5 Platform. When material changes are made to this Policy, jill5 will notify you through one or more of the following methods: a prominent notice displayed on the jill5 Platform, an email notification to your registered address, or an in-platform notification upon your next login.

The "Last Updated" date at the top of this page indicates when this Policy was most recently revised. Your continued use of the jill5 Platform following the effective date of any revision constitutes your acceptance of the updated Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how jill5 is protecting your personal information. Previous versions of this Policy are available upon request by contacting our Data Protection Officer.

15 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way jill5 handles your personal data, please contact our Data Protection Officer using the details below:

If you are not satisfied with jill5's response to your privacy concern, or if you believe jill5 has processed your personal data in violation of the Philippine Data Privacy Act of 2012, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines. The NPC can be contacted through their official government channels.

jill5 takes all privacy complaints seriously and is committed to resolving any concerns promptly, fairly, and in full compliance with our obligations under Philippine data protection law.