emjili Privacy Policy

1. Introduction

Welcome to the emjili Privacy Policy. emjili ("we", "us", "our") operates the online gaming platform accessible at emjili.net — a PAGCOR-regulated platform serving Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and communities throughout the Philippine archipelago.

We are fully committed to protecting the personal data and privacy of every individual who registers, browses, or interacts with the emjili platform. This Privacy Policy describes in clear, plain English exactly what personal information we collect from you, why we collect it, how we use it, who we may share it with, and what rights you have over your own data under Philippine law.

This policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the applicable directives of the National Privacy Commission of the Philippines ("NPC"). It also reflects our obligations as a PAGCOR-regulated online gaming operator with respect to the handling of player data for anti-money laundering ("AML") and know-your-customer ("KYC") purposes.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, emjili is the personal information controller responsible for the personal data collected through the emjili platform. All data collected by emjili is processed within the legal framework established by the DPA and overseen by the National Privacy Commission.

If you have any questions, concerns, or requests relating to your personal data, or if you wish to exercise any of your data subject rights as described in Section 10 of this Policy, please contact our Data Protection Officer ("DPO") using the contact details provided in Section 14.

3. Data We Collect

emjili collects personal data that is necessary, relevant, and adequate for the purposes described in this Policy. We do not collect personal data beyond what is required for those purposes. The categories of personal data we collect are set out below.

3.1 Account Registration Data

When you create an emjili account, we collect the information you provide during the registration process, including your full legal name, date of birth, email address, mobile number, and account credentials (username and password in hashed form). This information is required to open and maintain your account.

3.2 Identity Verification (KYC) Data

In compliance with PAGCOR anti-money laundering regulations and Republic Act No. 9160 (Anti-Money Laundering Act, as amended), emjili conducts mandatory KYC verification for all registered accounts. KYC data may include a copy of your government-issued photo ID (such as a Philippine National ID, passport, SSS ID, driver's licence, or voter's ID), a selfie or liveness check image, proof of address documents, and source-of-funds declarations where applicable.

3.3 Financial Transaction Data

emjili records all deposit and withdrawal transactions processed through your account, including the payment method used (e.g., GCash, Maya, BPI, BDO, Metrobank, InstaPay, or 7-Eleven), transaction amounts in Philippine Peso (PHP / ₱), transaction timestamps, and transaction reference numbers. We do not store full payment credentials such as complete bank account numbers or full card numbers.

3.4 Gaming Activity Data

We collect data about your gaming activity on the emjili platform, including game history, wager amounts, win and loss records, session durations, game preferences, and interactions with bonus and promotional features. This data is used for account management, regulatory reporting, responsible gaming monitoring, and platform improvement purposes.

3.5 Device & Technical Data

When you access emjili via a browser or mobile device, we automatically collect certain technical information including your IP address, browser type and version, operating system, device type and model, screen resolution, and mobile network operator. This data helps us maintain platform security, detect fraud, and improve the user experience.

3.6 Communications Data

If you contact emjili customer support via live chat, email, or any other communication channel, we retain records of those communications — including the content of messages, timestamps, and support ticket identifiers — for the purposes of resolving your query, training our support team, and maintaining an audit trail of player interactions.

3.7 Marketing Preferences

Where you have provided explicit opt-in consent, we collect information about your marketing communication preferences, including which types of promotions and communications you wish to receive and through which channels (email, SMS, push notification).

4. How We Collect Your Data

emjili collects your personal data through the following means:

• Directly from you: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automatically: Technical and device data collected automatically when you access or interact with the emjili platform through cookies, web beacons, server logs, and similar tracking technologies (see Section 9).
• From third-party verification providers: Identity and fraud-check data received from licensed KYC and AML screening services used to verify your identity and comply with PAGCOR regulatory requirements.
• From payment processors: Transaction confirmation data received from GCash, Maya, BPI, BDO, Metrobank, InstaPay, and other payment partners upon processing of deposits and withdrawals.

5. Why We Process Your Personal Data

emjili processes your personal data for the following purposes:

6. Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, emjili processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary for the performance of the contract between you and emjili — i.e., the provision of our gaming platform services under the Terms & Conditions you accepted at registration.
• Legal obligation: Processing is required to comply with applicable law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and other applicable Philippine regulations.
• Legitimate interests: Processing is necessary for emjili's legitimate interests in operating a secure, fraud-free platform, including fraud prevention, platform security, and responsible gaming monitoring — provided such interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and optional data uses, processing is based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

emjili does not sell your personal data to any third party. We may share your personal data with the following categories of recipients only where necessary and in accordance with applicable law:

7.1 PAGCOR and Regulatory Authorities

As a PAGCOR-regulated platform, emjili is required to submit player data, transaction reports, and KYC documentation to PAGCOR and other relevant Philippine regulatory and law enforcement authorities upon lawful request or as part of mandatory regulatory reporting obligations.

7.2 KYC and AML Service Providers

emjili engages licensed third-party identity verification and AML screening services to conduct KYC checks on registered players. These providers process the identity documents and data you submit during KYC verification solely for the purpose of identity confirmation and sanctions screening.

7.3 Payment Processors

To process your deposits and withdrawals, emjili shares the minimum necessary transaction data with your selected payment provider — such as GCash, Maya, BPI, BDO, Metrobank, or InstaPay. These providers operate under their own privacy policies and are independently regulated under Philippine financial law.

7.4 Game Technology Providers

emjili's platform is powered by third-party game technology providers including Evolution Gaming, Pragmatic Play, and JILI Games. These providers may receive session and game-play data required to operate their games within the emjili platform environment.

7.5 IT and Security Service Providers

emjili works with trusted IT infrastructure, cloud hosting, and cybersecurity vendors who may process technical and log data on our behalf under strict data processing agreements that bind them to handle your data in accordance with the DPA.

8. Data Retention

emjili retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, and for as long as required by applicable law and regulation. Key retention periods are as follows:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR regulatory requirements and the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in line with AML obligations.
• Gaming activity records: Retained for up to three (3) years from the date of the recorded activity, unless a longer period is required for regulatory reporting or dispute resolution.
• Customer support communications: Retained for up to two (2) years from the date of last contact, unless the communication relates to an unresolved dispute or legal proceeding.
• Marketing preference records: Retained until you withdraw consent or request deletion, subject to any applicable statutory retention minimum.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with NPC guidelines.

9. Cookies & Tracking Technologies

emjili uses cookies and similar tracking technologies on the emjili platform to provide essential functionality, improve user experience, and support our security and analytics operations. The types of cookies we use are described below:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that maintain your login state and security tokens that protect your account from cross-site request forgery attacks. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, last visited game category, and display preferences. These improve your experience but are not essential.
• Analytics cookies: Collect anonymised data about how players navigate and use the platform — including pages visited, session duration, and feature interactions — to help emjili improve platform design and functionality.
• Security and fraud prevention cookies: Help us identify suspicious activity, detect unauthorised access attempts, and protect the integrity of your account.

You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will impair or prevent access to the emjili platform. emjili does not use third-party advertising or behavioural profiling cookies.

10. Your Data Subject Rights

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

• Right to be informed: The right to be notified of the purpose, scope, and manner of processing of your personal data — which is fulfilled by this Privacy Policy.
• Right of access: The right to request a copy of the personal data emjili holds about you and information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data emjili holds about you.
• Right to erasure or blocking: The right to request deletion or blocking of personal data that is no longer necessary, was collected unlawfully, or where you have withdrawn consent — subject to emjili'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, on grounds relating to your particular situation.
• Right to data portability: The right to receive personal data you have provided to emjili in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to damages: The right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact emjili's Data Protection Officer as described in Section 14. emjili will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. We may request proof of identity before processing any request to protect against unauthorised access.

11. Data Security

emjili implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security measures include:

• SSL/TLS encryption: All data transmitted between your device and the emjili platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Password hashing: Account passwords are stored using strong cryptographic hashing algorithms — emjili never stores passwords in plain text.
• Access controls: Personal data is accessible only to authorised emjili personnel who require it to perform their job functions, under role-based access control policies.
• Regular security audits: emjili conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities in our platform and infrastructure.
• Data breach response: In the event of a personal data breach that is likely to result in risk to your rights and freedoms, emjili will notify the National Privacy Commission within seventy-two (72) hours and will inform affected data subjects without undue delay, in accordance with NPC Circular No. 16-03.

While emjili takes all reasonable precautions to secure your personal data, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your emjili account and to notify us immediately if you suspect any unauthorised activity on your account.

12. Children's Privacy and Age Restriction

The emjili platform is strictly for adults aged 21 years and older. emjili does not knowingly collect, process, or retain personal data from individuals below the age of 21. The 21-year minimum age threshold reflects the legal gambling age under PAGCOR regulations in the Philippines.

If emjili discovers or is notified that personal data has been collected from an individual below the age of 21 — whether through a false declaration at registration or any other means — the relevant account will be immediately suspended, the collected data will be deleted (subject to any mandatory regulatory retention requirements), and any funds held in the account will be handled in accordance with PAGCOR's prescribed procedures for underage account closures.

Parents and guardians who believe that a minor in their care may have registered an emjili account are strongly encouraged to contact emjili support immediately at [email protected].

13. Changes to This Privacy Policy

emjili reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable law, regulatory requirements, or platform services. When material changes are made, emjili will notify registered users via the email address on file or through a prominent notice on the platform prior to the changes taking effect.

The "Last updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the emjili platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of and agreement to the revised terms. If you do not agree with the changes, you must cease using the platform and contact emjili support to request account closure.

We encourage you to review this Privacy Policy periodically to stay informed about how emjili is protecting your personal data.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by emjili, please contact our Data Protection Officer through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the emjili platform
• Support Hours: 00:00 – 24:00 PHT, every day including Philippine public holidays

emjili aims to acknowledge all data-related enquiries within twenty-four (24) hours and to provide a substantive response within fifteen (15) business days in accordance with NPC guidelines. Where a request is complex or involves a large volume of data, emjili may extend this period by a further fifteen (15) business days, with prior notification to the requesting data subject.

If you are not satisfied with emjili's response to your data subject request or complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.