iiijl Privacy Policy

1. Information We Collect

iiijl collects several categories of personal information to provide, maintain, and improve our services and to comply with PAGCOR regulatory and anti-money laundering obligations.

1.1 Personal Identification Data

• Full legal name as it appears on a government-issued ID
• Date of birth (used to verify the 21+ age requirement under PAGCOR rules)
• Nationality and country of residence
• Government-issued identification numbers (passport, driver's license, UMID, PhilID, SSS, TIN)
• Photographs or scanned copies of identification documents
• Proof of address (utility bill, bank statement, barangay certificate)

1.2 Contact Information

• Email address
• Mobile phone number
• Residential or mailing address
• City or municipality (e.g., Manila, Cebu, Davao, Quezon City, Makati, Pasig)

1.3 Account and Gaming Data

• Account username and encrypted password hash
• Account registration date and history of activity
• Game session records including game type, bets placed, outcomes, and winnings
• Bonus claims, wagering history, and promotion participation records
• Responsible gaming settings such as deposit limits and self-exclusion requests

1.4 Financial Data

• GCash account number or PayMaya wallet identifier
• Bank account details for BPI, BDO, Metrobank, UnionBank, and other Philippine banks used for transactions
• Deposit and withdrawal transaction records including amounts, timestamps, and references
• Source of funds documentation provided during enhanced KYC verification

1.5 Technical and Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, browser type and version
• Mobile carrier information (Globe, Smart, PLDT, etc.) when applicable
• Cookie identifiers and session tokens
• Pages visited, time spent, clicks, and navigation paths within the iiijl platform

1.6 Communications Data

• Records of customer support interactions via live chat, email, and phone
• Feedback, survey responses, and complaint records
• Marketing preference settings and email/SMS opt-in status

2. How We Collect Your Information

iiijl collects personal information through the following means:

2.1 Direct Collection

Information you provide voluntarily when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, participating in promotions, or responding to surveys. This represents the primary source of personal data held by iiijl and is collected with your knowledge and consent at each point of interaction.

2.2 Automated Collection

Technical information automatically collected when you visit and interact with the iiijl website, including cookies, server log files, session identifiers, and similar tracking technologies. This information is collected through your browser or device without requiring any direct input from you.

2.3 Third-Party Sources

iiijl may receive information about you from third-party sources, including:

• Payment processors and e-wallet providers (GCash, PayMaya) confirming transaction details
• Identity verification service providers that validate government-issued IDs
• Fraud prevention and anti-money laundering screening services
• Publicly available records and databases consulted for compliance purposes

3. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, iiijl processes your personal information on the following lawful bases:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms and Conditions you accepted upon registration, including account management, game operation, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) requirements, Know Your Customer (KYC) obligations, and other applicable Philippine laws and regulations.
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring, where our legitimate interests are balanced against your rights and freedoms as a data subject.
• Consent: Processing for marketing communications, optional profile personalization, and non-essential analytics, where you have provided express, informed, and freely given consent that you may withdraw at any time.

4. How We Use Your Information

iiijl uses the personal information we collect for the following purposes:

4.1 Account Management and Service Delivery

• Creating and maintaining your iiijl account
• Verifying your identity and age (21+ requirement) per PAGCOR regulations
• Processing deposits, withdrawals, and financial transactions
• Providing access to casino games, sports betting, and other platform features
• Delivering customer support and resolving disputes

4.2 Regulatory and Legal Compliance

• Fulfilling PAGCOR reporting and record-keeping requirements
• Complying with Anti-Money Laundering Act obligations, including suspicious transaction reporting
• Responding to lawful requests from courts, regulators, and law enforcement agencies
• Maintaining audit trails and transaction logs as required by Philippine gaming law

4.3 Fraud Prevention and Security

• Detecting and preventing fraudulent account activity, bonus abuse, and payment fraud
• Monitoring for suspicious betting patterns or security threats
• Verifying that accounts are not operated by prohibited or excluded persons

4.4 Responsible Gaming

• Monitoring gaming patterns to identify potential problem gambling indicators
• Enforcing self-exclusion requests and deposit limit settings
• Providing responsible gaming alerts, cooling-off periods, and intervention where warranted

4.5 Marketing and Communications

• Sending promotional offers, bonus notifications, and newsletters where you have opted in
• Personalizing bonus recommendations and game suggestions based on your preferences
• Conducting surveys and collecting feedback to improve our services

4.6 Platform Improvement and Analytics

• Analyzing aggregated, anonymized usage data to improve website performance and user experience
• Testing new features and measuring the effectiveness of platform changes
• Conducting internal research and reporting on platform usage trends

5. Disclosure of Your Information

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

5.1 Regulatory and Legal Authorities

iiijl is required by law to disclose player information to PAGCOR and other competent Philippine authorities upon lawful demand, including courts, law enforcement, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC). Such disclosure is made strictly in compliance with applicable legal procedures.

5.2 Authorized Service Providers

iiijl shares data with carefully vetted third-party service providers who process information on our behalf and are bound by strict data processing agreements:

• Payment processors and e-wallet platforms (GCash, PayMaya, banking partners) for transaction processing
• Identity verification and KYC service providers
• Fraud prevention and security monitoring services
• Cloud infrastructure and data hosting providers
• Customer relationship management and support platforms
• Email and SMS communication service providers for transactional and marketing messages

All authorized service providers are required to handle your data in accordance with the Data Privacy Act of 2012, these Privacy Policy terms, and any additional contractual data protection obligations imposed by iiijl.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of iiijl's assets, your personal information may be transferred to the acquiring entity. We will provide reasonable notice of such transfer and ensure the acquiring party is bound by privacy protections at least as strong as those described in this Policy.

5.4 Protection of Rights

iiijl may disclose personal information where we believe disclosure is reasonably necessary to protect the rights, property, or safety of iiijl, our players, or third parties, including in connection with fraud investigations and legal disputes.

6. Cookies and Tracking Technologies

The iiijl website uses cookies and similar technologies to provide a functional, personalized, and secure experience. By using our website, you consent to our use of cookies in accordance with this policy.

6.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for website operation, including authentication sessions, security tokens, and game session continuity. Cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and recently played games.
• Analytics Cookies: Aggregate, anonymized data on site usage patterns, page performance, and feature adoption to help us improve the platform.
• Marketing Cookies: Track engagement with promotional content to help us deliver relevant offers based on your gaming history. Only activated with your consent.

6.2 Managing Cookies

You may control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies. Note that disabling strictly necessary cookies may impair core website functionality, including the ability to log in and play games. Deleting analytics or marketing cookies will not affect your access to any iiijl service.

7. Data Retention

iiijl retains personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, and resolve disputes. Specific retention periods include:

• Account data: Retained for the duration of the account relationship and for five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Customer support records: Retained for three (3) years following resolution of the relevant support interaction.
• Marketing data: Retained until you withdraw consent or for a maximum of two (2) years from the last marketing interaction, whichever is earlier.
• Technical log data: Typically retained for ninety (90) days unless required for ongoing security investigations or legal proceedings.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized so that it can no longer be attributed to any individual.

8. Data Security Measures

iiijl implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• Encryption: All data transmitted between your browser and iiijl servers is encrypted using industry-standard TLS 1.3 / 256-bit SSL protocols. Sensitive data at rest, including financial information and government ID details, is encrypted using AES-256 encryption.
• Access Controls: Personal data access is restricted to iiijl personnel and authorized service providers who have a documented, legitimate business need. Role-based access controls and multi-factor authentication are enforced for all staff accessing personal data systems.
• Infrastructure Security: iiijl servers are hosted in secure, ISO 27001-certified data centers with physical security controls, redundant power systems, and continuous intrusion detection monitoring.
• Regular Audits: Security systems and access logs are reviewed regularly through internal audits and periodic third-party penetration testing to identify and remediate vulnerabilities.
• Incident Response: iiijl maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, iiijl will notify the National Privacy Commission (NPC) within seventy-two (72) hours and affected individuals without undue delay, in accordance with the Data Privacy Act of 2012.

While iiijl employs industry-leading security practices, no digital platform can guarantee absolute security. You play an important role in protecting your account by using a strong password, enabling two-factor authentication, and not sharing your login credentials with others.

9. Your Rights as a Data Subject

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

• Right to Be Informed: You have the right to know what personal data iiijl collects about you and how it is processed, as described in this Privacy Policy.
• Right of Access: You may request a copy of the personal data iiijl holds about you, including information about how it is processed and with whom it is shared.
• Right to Rectification: If any personal data held by iiijl is inaccurate, incomplete, or outdated, you may request that it be corrected or updated.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations (such as the five-year PAGCOR retention requirement for financial records).
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to compelling legitimate grounds that override your interests.
• Right to Data Portability: You may request a copy of personal data you provided to iiijl in a commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe iiijl has violated your data privacy rights, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, contact iiijl Data Privacy Officer at [email protected] with the subject line "Data Subject Rights Request." Requests are processed within thirty (30) calendar days. Complex or multiple requests may require up to sixty (60) calendar days; iiijl will notify you of any extension within the initial thirty-day period.

10. Children's Privacy

iiijl services are strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with PAGCOR regulations and Philippine gaming law. We do not knowingly collect personal information from any person under the age of 21.

If iiijl becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately close the associated account, refund any deposits, and delete all associated personal data without delay. Parents or guardians who believe their minor child has registered an account with iiijl should contact us immediately at [email protected].

11. Cross-Border Data Transfers

Some of iiijl's authorized service providers and infrastructure components are located outside the Philippines. Where personal data is transferred to recipients in other countries, iiijl ensures that such transfers comply with the Data Privacy Act of 2012 and its Implementing Rules and Regulations. Specifically, iiijl requires that:

• The recipient country has been determined to provide an adequate level of data protection, or
• Appropriate contractual safeguards (such as standard data protection clauses) are in place between iiijl and the overseas recipient, or
• Other approved data transfer mechanisms prescribed by the National Privacy Commission are applied.

By using iiijl services and providing personal data, you acknowledge and consent to the transfer of your information to overseas service providers subject to the safeguards described above.

12. Third-Party Links and Services

The iiijl website may contain links to game providers, payment portals, and other third-party platforms. These third parties operate under their own privacy policies, which iiijl neither controls nor endorses. When you leave the iiijl platform and interact with a third-party service, your personal data becomes subject to that third party's privacy practices.

iiijl encourages you to review the privacy policies of any third-party services you access through or in connection with the iiijl platform. Our inclusion of any third-party link or service does not constitute an endorsement of their privacy or security practices.

13. Marketing Communications

With your consent, iiijl may send promotional emails, SMS messages, and in-app notifications regarding bonuses, new games, tournaments, and special offers. You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any promotional email
• Updating your communication preferences in your iiijl account settings
• Contacting customer support at [email protected] with an opt-out request

Opting out of marketing communications does not affect your receipt of transactional messages (such as deposit confirmations, withdrawal notifications, and security alerts), which are sent regardless of marketing preferences as they are necessary for account operation.

14. Changes to This Privacy Policy

iiijl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, we will:

• Update the "Effective Date" and "Last Updated" date at the top of this document
• Post a prominent notice on the iiijl website homepage for a minimum of thirty (30) days following the update
• Send a notification email to all registered account holders where changes materially affect their privacy rights

Your continued use of iiijl services following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you must discontinue using iiijl services and may request account closure.

15. Contact and Data Subject Requests

For all privacy-related inquiries, data subject rights requests, or concerns about how iiijl processes your personal information, please contact our Data Privacy Officer:

If you are not satisfied with iiijl's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for administering and implementing the Data Privacy Act of 2012.