Section 01
1. Who We Are
109jili operates as an online gaming platform accessible at 109jili.net, designed for adult players based in the Philippines. When this Privacy Policy refers to "109jili," "we," "us," or "our," it refers to the team and entity responsible for operating the platform and managing the personal data collected through it.
This policy applies to all personal information collected through the 109jili website, account registration forms, payment processes, support communications, and any other interaction between players and the 109jili platform. It should be read alongside the Terms and Conditions.
For Filipino players: The Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules set the framework for personal data protection in the Philippines. 109jili handles player data with respect for these principles regardless of where the platform's servers are located.
Section 02
2. Data We Collect
109jili collects personal data in several ways — directly from you during registration and account use, automatically through platform interaction, and occasionally from third-party services that help operate the platform. Here is a breakdown of the categories of data we collect:
| Data Category |
Examples |
When Collected |
| Identity Data |
Full legal name, date of birth, government ID number |
Registration and verification |
| Contact Data |
Email address, mobile number |
Registration, support contact |
| Financial Data |
GCash number, bank account name, partial card details |
Deposit and withdrawal processing |
| Account Data |
Username, password hash, login history, session activity |
Account creation and ongoing use |
| Transaction Data |
Deposit amounts, withdrawal requests, game history, bet records |
Every time a financial or gaming action is taken |
| Technical Data |
IP address, device type, browser version, operating system |
Automatically on site access |
| Communication Data |
Support tickets, chat transcripts, email correspondence |
When you contact 109jili support |
109jili does not intentionally collect sensitive personal data beyond what is required for identity verification, fraud prevention, and regulatory compliance. We do not collect information about race, religion, political views, or health status.
Section 03
3. How We Use Your Data
Every piece of data 109jili collects has a specific purpose. We do not retain data beyond what is necessary for the uses listed below. Here is how your personal information is used:
- Account creation and management — to set up your 109jili account, authenticate logins, and maintain your player profile.
- Identity verification — to confirm your age, prevent duplicate accounts, and comply with platform integrity requirements before processing withdrawals.
- Payment processing — to facilitate deposits and withdrawals in Philippine Peso through your chosen method (GCash, Maya, InstaPay, bank transfer, or card).
- Platform security and fraud prevention — to detect unusual login activity, identify suspicious transaction patterns, and prevent unauthorised account access.
- Customer support — to review your case history, respond to inquiries, and resolve disputes or account issues.
- Responsible gaming — to monitor playing patterns and reach out when account activity suggests a potential concern, and to apply self-exclusion or limit requests.
- Platform improvement — to analyse how players use 109jili in aggregate (non-identifiable) form and improve navigation, content, and features.
- Marketing communications — to send promotional offers via email or in-platform notification, only where you have opted in or where permitted by applicable rules. You can unsubscribe at any time.
Section 04
4. Legal Basis for Processing
109jili processes your personal data on one or more of the following grounds, depending on the specific purpose:
Contractual necessity: Most data processing at 109jili is necessary to perform the contract you entered into when you registered — meaning we need to use your data to provide account services, process payments, and deliver the gaming experience you signed up for.
Legal obligation: Certain data collection and retention — particularly identity verification records and transaction history — may be required by applicable regulations. 109jili retains this data for as long as required by law.
Legitimate interests: 109jili processes some data to protect the platform, its players, and its staff from fraud, abuse, and security threats. These legitimate interests do not override your privacy rights.
Consent: For optional purposes such as marketing emails or optional cookies, 109jili relies on your explicit consent. You may withdraw consent at any time without affecting your account access.
Section 05
5. Cookies and Tracking Technologies
Like most websites, 109jili uses cookies — small text files stored on your device — to support essential platform functions and understand how players interact with the site. Here is how they are categorised:
Essential Cookies
Required for login sessions, security tokens, and basic platform function. These cannot be turned off without breaking site access.
Analytics Cookies
Used to understand page performance and user navigation flows in aggregate, non-personal form. Helps 109jili identify areas to improve.
Preference Cookies
Remember display preferences and language settings so you don't have to reset them on each visit.
Marketing Cookies
Only set with your consent and used to tailor relevant promotions. You may opt out at any time through your browser or account settings.
You can manage or delete cookies through your browser settings at any time. Note that disabling essential cookies will affect your ability to log in and use the platform normally.
Section 06
6. Data Sharing
109jili does not sell your personal data. We share information only in the following circumstances, and only to the extent necessary for the specific purpose:
- Payment processors: GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet operators, BDO, BPI, UnionBank, Visa, and Mastercard receive the transaction data needed to complete your deposit or withdrawal. They operate under their own privacy frameworks.
- Identity verification services: Third-party KYC (Know Your Customer) providers receive limited personal data to confirm age and identity during account verification.
- Game software providers: Licensed game studios may receive session-level data (not personal identity data) to facilitate game delivery and resolve technical disputes.
- Legal and regulatory authorities: 109jili may disclose data when required by law, court order, or legitimate regulatory request. We will only share the minimum data required.
- IT and security service providers: Companies that provide hosting, cybersecurity, and infrastructure services may access data in the course of providing those services, under strict confidentiality agreements.
Cross-border transfers: Some of 109jili's service providers may be based outside the Philippines. Where data is transferred internationally, 109jili ensures that appropriate safeguards are in place consistent with applicable data protection requirements.
Section 07
7. Data Storage and Security
109jili applies practical, layered security measures to protect personal data from unauthorised access, disclosure, alteration, and loss. These measures include:
- Encryption of sensitive data both in transit (TLS/HTTPS) and at rest
- Password hashing using industry-standard algorithms — plain-text passwords are never stored
- Access controls limiting data access to authorised staff with a verified need
- Regular security reviews and monitoring for unusual access patterns
- Secure handling of financial data through PCI-compliant payment partners
While 109jili takes these precautions seriously, no online platform can guarantee absolute security. Players are responsible for keeping their login credentials private and for using strong, unique passwords. If you suspect your account has been compromised, contact 109jili support immediately.
Section 08
8. Data Retention
109jili retains personal data only for as long as it is needed for the purpose it was collected, or as required by applicable regulations. Here are the general guidelines:
| Data Type |
Retention Period |
Reason |
| Account and identity data |
Duration of account + up to 5 years after closure |
Regulatory compliance and dispute resolution |
| Transaction records |
Minimum 5 years |
Financial record requirements |
| Support communications |
3 years from last interaction |
Dispute reference and service improvement |
| Marketing preferences |
Until you opt out or account is closed |
Consent-based processing |
| Technical and log data |
Up to 12 months |
Security monitoring and fraud detection |
When retention periods expire, personal data is securely deleted or anonymised so it can no longer be linked to an individual player.
Section 09
9. Your Rights Over Your Data
As a 109jili player, you have meaningful rights over the personal data we hold about you. These rights can be exercised by contacting support at support@109jili.net. Here is a summary:
Right to Access
Request a copy of the personal data 109jili holds about you, including how it is used.
Right to Correction
Ask us to update or correct inaccurate personal details on your account.
Right to Deletion
Request erasure of your data when it is no longer needed — subject to legal retention obligations.
Right to Restrict
Ask 109jili to limit how your data is processed while a query or dispute is being resolved.
Right to Portability
Receive a structured copy of your personal data in a commonly used format to transfer elsewhere.
Right to Object
Object to data processing based on legitimate interests, including direct marketing.
109jili aims to respond to all data rights requests within 30 calendar days. In complex cases, this may be extended by a further 60 days with notice to you. Some requests may be limited where retention is legally required.
Section 10
10. Children's Privacy
109jili is strictly for adults aged 18 and above. We do not knowingly collect personal data from anyone under 18 years old. If we discover that a minor has registered an account, the account will be closed immediately and any associated data deleted to the extent permitted by applicable rules.
Account holders are responsible for ensuring that minors do not access the platform through their devices. If you have reason to believe a minor has accessed 109jili using your account or a separate account, contact support immediately.
Section 11
11. Third-Party Links
The 109jili platform does not contain links to external websites. All navigation remains within the 109jili domain. Should this change in future, this policy will be updated accordingly.
109jili is not responsible for the privacy practices of any payment provider's own website or app — for example, the GCash or Maya platforms — even though data passes through their systems during transactions. Players should review the privacy policies of their chosen payment services separately.
Section 12
12. Policy Updates
109jili may update this Privacy Policy from time to time to reflect changes in practice, technology, legal requirements, or platform features. When material updates are made, registered players will be notified by email and/or through an in-platform notice. The revised policy will be published on this page with a new effective date at the top.
Continuing to use 109jili after an updated policy becomes effective means you accept the changes. If you disagree with any update, you may close your account by contacting support. Closure requests will be handled in accordance with the current withdrawal and account termination process outlined in the Terms and Conditions.
Section 13
13. Contact Us
If you have questions about this Privacy Policy, want to exercise any of your data rights, or need to report a privacy concern, the 109jili team is reachable through the following:
Email: support@109jili.net
Subject line for data requests: "Privacy Request – [Your Username]"
Response time: Within 5 business days for acknowledgement; up to 30 days for full response
Language: Philippine English preferred
For responsible gaming requests such as self-exclusion or deposit limit adjustments, please visit the dedicated Responsible Gaming page. For general account questions, check the FAQ first — it covers the most common queries raised by 109jili players.
