Privacy Policy

1. Overview

1.1 jillspin ("we," "us," "our") is committed to protecting the privacy and personal data of all users ("you," "Player") who access and use the jillspin Platform. We recognise that trust is the foundation of any lasting relationship between a gaming platform and its players — and that trust begins with being transparent about how personal information is handled.

1.2 This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC). Where applicable, we also observe internationally recognised data protection principles.

1.3 jillspin acts as the data controller for personal data collected through the Platform. We determine the purposes and means of processing your personal data and are responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

2. Data We Collect

2.1 jillspin collects the following categories of personal data, depending on how you interact with the Platform:

2.1 Identity & Contact Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Nationality and country of residence;
• Email address and mobile phone number;
• Residential address (barangay, city/municipality, province, ZIP code).

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, PhilSys National ID, SSS ID, UMID, driver's licence);
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie or liveness verification images where required;
• Source of funds documentation where required by anti-money laundering obligations.

2.3 Financial Data

• GCash or PayMaya account reference numbers;
• BDO, BPI, or Metrobank account details (account name and number only — never full card numbers);
• Transaction history including deposits, withdrawals, and bonus activity;
• Account balance information.

2.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features used;
• Game history, bet amounts, and wagering patterns;
• Login timestamps and access logs.

2.5 Communications Data

• Records of live chat conversations with our support team;
• Email correspondence sent to or received from jillspin;
• Feedback, complaints, and dispute records.

3. How We Collect Your Data

3.1 Directly from You. The majority of personal data we hold is provided directly by you during account registration, KYC verification, payment processing, or when you contact our support team.

3.2 Automatically. When you access the jillspin Platform, certain technical data is collected automatically through cookies, server logs, and similar tracking technologies. This includes your IP address, device identifiers, and browsing behaviour on the Platform.

3.3 From Third Parties. We may receive data about you from third-party identity verification providers, payment processors (such as GCash and PayMaya), fraud prevention services, and analytics partners. All such third parties are contractually required to handle your data in accordance with applicable data protection laws.

4. Purpose of Processing

4.1 jillspin processes your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, and login data
Age and identity verification (KYC)	Identity, KYC documents, date of birth
Processing deposits and withdrawals	Financial data, identity data
Anti-money laundering (AML) compliance	Financial data, KYC documents, transaction history
Fraud detection and prevention	Technical data, financial data, usage patterns
Customer support and dispute resolution	Communications data, account data
Responsible gaming monitoring	Usage data, wagering patterns, account data
Platform improvement and analytics	Technical and usage data (aggregated/anonymised)
Marketing communications (with consent)	Contact data, preferences
Legal and regulatory compliance	All categories as required by law

5. Legal Basis for Processing

5.1 Under the Data Privacy Act of 2012 and its Implementing Rules, jillspin processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to upon registration — including account management, payment processing, and game provision;
• Legal Obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, KYC requirements, and regulatory reporting obligations;
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving our services — where such interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where we have obtained your explicit consent. You may withdraw consent at any time.

6. Data Sharing & Disclosure

6.1 jillspin does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances:

• Payment Processors: GCash, PayMaya, BDO, BPI, Metrobank, and other payment service providers receive the minimum data necessary to process your transactions;
• Identity Verification Providers: Third-party KYC and AML service providers who assist us in verifying your identity and complying with regulatory requirements;
• Game Providers: Software providers whose games are hosted on the jillspin Platform may receive anonymised or pseudonymised usage data for game performance purposes;
• Regulatory Authorities: We may disclose your data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities when required by law or court order;
• Fraud Prevention Services: Shared data with fraud detection partners to protect the integrity of the Platform and all players;
• Professional Advisers: Lawyers, auditors, and consultants bound by confidentiality obligations, where necessary for legal or business purposes.

6.2 All third parties with whom jillspin shares personal data are required to implement appropriate technical and organisational security measures and to process data only for the specified purpose.

7. Data Retention

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

• Account Data: Retained for the duration of your account and for five (5) years following account closure, in accordance with Philippine AML record-keeping requirements;
• KYC Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later;
• Transaction Records: Retained for five (5) years from the date of each transaction;
• Support Communications: Retained for three (3) years from the date of the last interaction;
• Technical & Usage Logs: Retained for up to twelve (12) months, after which they are anonymised or deleted.

7.2 Where retention beyond these periods is required by a specific legal obligation, regulatory direction, or ongoing dispute, jillspin will retain the relevant data until that obligation is resolved.

8. Security Measures

8.1 jillspin implements a layered approach to data security, combining technical, organisational, and procedural safeguards to protect your personal data against unauthorised access, disclosure, alteration, or destruction.

8.2 Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jillspin Platform;
• Encryption of sensitive data at rest, including financial records and KYC documents;
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent necessary for their role;
• Regular security audits, vulnerability assessments, and penetration testing;
• Two-factor authentication (2FA) options for player accounts;
• Secure, access-controlled data centres with physical security protocols.

8.3 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jillspin will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay where required.

9. Cookies & Tracking Technologies

9.1 jillspin uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver relevant content. A cookie is a small text file placed on your device when you visit the Platform.

9.2 We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly — including session management, login authentication, and security features. These cannot be disabled;
• Performance & Analytics Cookies: Help us understand how players use the Platform so we can improve it. Data collected is aggregated and anonymised;
• Functional Cookies: Remember your preferences (such as language settings) to provide a more personalised experience;
• Marketing Cookies: Used to deliver relevant promotions and offers. These are only placed with your consent.

9.3 You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

10. Your Data Privacy Rights

10.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jillspin:

10.2 To exercise any of the above rights, please contact our Data Privacy Officer at [email protected]. We will respond to all verified requests within thirty (30) days. In complex cases, this period may be extended by a further thirty (30) days, with notice provided to you.

10.3 If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

11. Minors & Age Restriction

11.1 The jillspin Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine gambling regulations. jillspin does not knowingly collect personal data from individuals under the age of 21.

11.2 If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

12. International Data Transfers

12.1 In the course of providing our services, your personal data may be transferred to and processed in countries outside the Philippines — for example, where our technology partners or game providers are based. jillspin ensures that any such international transfers are subject to appropriate safeguards, including contractual data protection clauses that meet the standards required by the Data Privacy Act of 2012.

12.2 Where personal data is transferred internationally, jillspin takes all reasonable steps to ensure that the receiving party provides a level of data protection equivalent to that required under Philippine law.

13. Changes to This Privacy Policy

13.1 jillspin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

13.2 The "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how jillspin protects your personal data.

13.3 Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

14. Contact Our Data Privacy Officer

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact jillspin's designated Data Privacy Officer: