Privacy Policy

1. Introduction and Scope

1.1 Our Commitment to Privacy

gili99 ("we", "us", "our", "gili99") respects the privacy rights of all users ("you", "user", "player") accessing our online gaming platform at https://gili99.cam. This Privacy Policy describes our practices regarding the collection, use, disclosure, and protection of personal information in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and all applicable Philippine data protection regulations.

By creating a gili99 account, accessing our website, or using any of our services including casino games, sports betting, live dealer tables, and promotional offers, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy. If you do not agree with our privacy practices, you must not use gili99 services.

1.2 Scope of This Policy

This Privacy Policy applies to all personal information collected through gili99's website, mobile applications, customer support channels, and any other digital platforms operated by gili99. This policy covers information collected both directly from you and automatically through your use of our services. It also governs how we share information with third-party service providers, payment processors, and regulatory authorities.

1.3 Data Controller

gili99 acts as the data controller for all personal information collected through our platform. We determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable data protection laws. For privacy-related inquiries or to exercise your data rights, you may contact our Data Protection Officer at [email protected].

2. Information We Collect

2.1 Personal Information You Provide

When you register for a gili99 account, we collect personal information necessary to provide gaming services, verify your identity, process financial transactions, and comply with Philippine gaming regulations. The personal information we collect includes:

• Identity Information: Full legal name, date of birth, nationality, and government-issued identification numbers (Philippine national ID, passport number, driver's license number)
• Contact Information: Email address, mobile phone number, residential address including street, city, province, and postal code
• Account Credentials: Username, password (stored in encrypted form), and security questions for account recovery
• Financial Information: Bank account details, GCash or PayMaya account numbers, cryptocurrency wallet addresses, payment card information (processed through encrypted third-party payment gateways), and transaction history
• Verification Documents: Copies of government-issued identification, utility bills for address verification, bank statements, and selfie photographs for identity verification purposes
• Communication Records: Chat transcripts, emails, phone call recordings with customer support, and any other communications you initiate with gili99

2.2 Information Collected Automatically

When you access gili99 services, we automatically collect certain technical and usage information through cookies, log files, and similar tracking technologies:

• Device Information: IP address, device type and model, operating system, browser type and version, screen resolution, and device identifiers
• Usage Data: Pages visited, games played, bet amounts and outcomes, time spent on platform, click patterns, navigation paths, and feature interactions
• Location Data: Approximate geographic location based on IP address to verify you are accessing gili99 from a permitted jurisdiction
• Cookies and Tracking: Session cookies for login persistence, preference cookies for language and display settings, analytics cookies for platform optimization, and advertising cookies for marketing attribution

2.3 Information From Third Parties

gili99 may receive information about you from third-party sources including:

• Payment processors providing transaction verification and fraud prevention data
• Identity verification services confirming your identity and age
• Credit reference agencies for fraud prevention and responsible gaming assessments
• Social media platforms if you choose to register using social login features
• Affiliate partners who referred you to gili99
• Public databases and regulatory authorities for compliance screening

3. How We Use Your Information

3.1 Primary Purposes

gili99 processes your personal information for the following legitimate purposes:

Account Management and Service Delivery

• Creating and maintaining your gili99 gaming account
• Processing deposits, withdrawals, and bet settlements
• Providing access to casino games, sports betting, and live dealer services
• Managing bonus offers, promotions, and VIP program benefits
• Authenticating login attempts and maintaining account security

Legal and Regulatory Compliance

• Verifying you are at least twenty-one (21) years old and eligible to gamble in the Philippines
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
• Complying with PAGCOR licensing requirements and gaming regulations
• Preventing fraud, money laundering, and other illegal activities
• Responding to legal requests from Philippine authorities
• Maintaining records as required by Philippine law

Customer Support and Communication

• Responding to inquiries, complaints, and support requests
• Sending account notifications, transaction confirmations, and security alerts
• Providing updates about platform changes, new games, and features
• Conducting customer satisfaction surveys and feedback collection

3.2 Marketing and Personalization

With your consent, gili99 uses your information to:

• Send promotional emails about new games, bonus offers, and special events
• Display personalized game recommendations based on your playing history
• Target advertising campaigns to Filipino players interested in online gaming
• Invite you to tournaments, competitions, and exclusive VIP events

You may opt out of marketing communications at any time by clicking "unsubscribe" in promotional emails or adjusting your communication preferences in account settings. Opting out of marketing does not affect essential account communications such as transaction confirmations, security alerts, or regulatory notices.

3.3 Platform Improvement and Analytics

gili99 analyzes usage data to improve our platform through:

• Identifying popular games and features to enhance user experience
• Detecting technical issues, bugs, and performance problems
• Optimizing website loading speeds and mobile responsiveness
• Developing new features based on player preferences and behavior
• Conducting A/B testing to improve interface design and functionality

3.4 Responsible Gaming

gili99 processes your data to promote responsible gaming practices:

• Monitoring betting patterns to identify potential problem gambling behavior
• Enforcing deposit limits, loss limits, and self-exclusion requests
• Providing reality check reminders during extended gaming sessions
• Connecting at-risk players with professional gambling support resources

4. Legal Basis for Processing

Under Philippine data protection law, gili99 must have a lawful basis to process your personal information. We rely on the following legal grounds:

4.1 Contractual Necessity

Processing is necessary to fulfill our contractual obligations to provide gaming services, process your bets and financial transactions, and maintain your account as agreed in our Terms and Conditions.

4.2 Legal Obligation

Processing is required to comply with Philippine laws including the Data Privacy Act, Anti-Money Laundering Act, and PAGCOR gaming regulations. This includes identity verification, transaction monitoring, and reporting suspicious activities to authorities.

4.3 Legitimate Interests

Processing is necessary for gili99's legitimate business interests including fraud prevention, platform security, service improvement, and direct marketing to existing customers, provided these interests do not override your fundamental privacy rights.

4.4 Consent

For certain processing activities such as optional marketing communications, non-essential cookies, and sharing data with third-party advertising partners, we rely on your explicit consent which you may withdraw at any time.

5. Information Sharing and Disclosure

5.1 Third-Party Service Providers

gili99 shares your personal information with trusted third-party service providers who assist in operating our platform:

Service Category	Purpose of Data Sharing
Payment Processors	GCash, PayMaya, banks, and cryptocurrency platforms process deposits and withdrawals on our behalf
Game Providers	Pragmatic Play, Evolution Gaming, and other suppliers provide gaming software and process bet transactions
Identity Verification	KYC service providers verify your age and identity against government databases
Customer Support	Live chat platforms and email services facilitate customer communications
Marketing Partners	Email service providers, SMS gateways, and advertising networks deliver promotional content
Analytics Providers	Google Analytics and similar services help us understand platform usage and performance

All third-party service providers are contractually obligated to maintain confidentiality, use data only for specified purposes, and implement appropriate security measures. We conduct due diligence to ensure providers comply with Philippine data protection laws.

5.2 Legal and Regulatory Disclosure

gili99 may disclose your information without prior notice when required by law or to protect legitimate interests:

• Responding to valid legal requests from Philippine courts, law enforcement, or regulatory authorities
• Complying with PAGCOR audits, investigations, and compliance reviews
• Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Preventing fraud, security threats, or illegal activities
• Protecting gili99's rights, property, and legal interests
• Enforcing Terms and Conditions or investigating violations

5.3 Business Transfers

If gili99 undergoes a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. You will be notified via email and prominent website notice of any ownership change affecting your data, and you will have the opportunity to delete your account before the transfer.

5.4 No Sale of Personal Data

gili99 does not sell, rent, or trade your personal information to third parties for their marketing purposes. Any data sharing occurs only as described in this Privacy Policy and with appropriate safeguards in place.

6. Data Security Measures

6.1 Technical Security

gili99 implements industry-leading security measures to protect your personal information:

• Encryption: All data transmissions use 256-bit SSL/TLS encryption. Personal information stored in databases is encrypted at rest using AES-256 encryption standards.
• Secure Servers: Data is stored on servers located in secure facilities with 24/7 monitoring, biometric access controls, and redundant power and cooling systems.
• Firewalls and Intrusion Detection: Multi-layer firewall protection and intrusion detection systems monitor and block unauthorized access attempts.
• Regular Security Audits: Independent cybersecurity firms conduct quarterly penetration testing and security assessments to identify and address vulnerabilities.
• Access Controls: Personal information access is restricted to authorized personnel only through role-based access controls and multi-factor authentication.

6.2 Organizational Security

Beyond technical measures, gili99 maintains organizational policies ensuring data security:

• All employees with access to personal data sign confidentiality agreements
• Staff receive regular training on data protection and security best practices
• We maintain incident response procedures to quickly address security breaches
• Access logs are reviewed regularly to detect unauthorized access attempts
• Data retention schedules ensure information is deleted when no longer needed

6.3 Your Security Responsibilities

While gili99 implements robust security measures, you also play a critical role in protecting your account:

• Choose a strong, unique password combining letters, numbers, and special characters
• Never share your gili99 username or password with anyone
• Logout from your account when using shared or public computers
• Enable two-factor authentication for additional account protection
• Report any suspicious account activity to customer support immediately
• Keep your registered email and mobile number secure and up to date

7. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request confirmation that gili99 is processing your personal data and to obtain copies of your data. You may request a data export containing all personal information we hold about you in a structured, commonly used, machine-readable format. To request access, email [email protected] with your account username and government-issued ID for verification. We will respond within fifteen (15) business days.

7.2 Right to Rectification

If your personal information is inaccurate, incomplete, or outdated, you have the right to request corrections. Most personal information can be updated directly through your account settings. For information requiring verification (name, date of birth, identification documents), contact customer support with supporting documentation. Changes will be processed within seven (7) business days.

7.3 Right to Erasure

You may request deletion of your personal information under certain circumstances including when data is no longer necessary for original purposes, you withdraw consent, or data was unlawfully processed. However, gili99 may retain certain information when required by law, for regulatory compliance, or to resolve disputes. Account deletion requests are processed within thirty (30) days.

7.4 Right to Restriction

You may request that gili99 restrict processing of your personal information while verifying accuracy, assessing lawfulness of processing, or when you need the data preserved for legal claims. During restriction, we will store but not actively process your data except with your consent or for legal purposes.

7.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used format and to transmit that data to another service provider. Upon request, gili99 will provide account data, transaction history, and gaming records in CSV or JSON format within fifteen (15) business days.

7.6 Right to Object

You may object to processing of your personal information for direct marketing purposes at any time. You may also object to processing based on legitimate interests by providing specific reasons related to your particular situation. Marketing objections are honored immediately, while other objections are assessed on a case-by-case basis.

7.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time by adjusting account settings, clicking "unsubscribe" in marketing emails, or contacting customer support. Withdrawal of consent does not affect the lawfulness of processing conducted before withdrawal.

7.8 Filing a Complaint

If you believe gili99 has violated your privacy rights or Philippine data protection laws, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. Contact details: National Privacy Commission, 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto Street, Pasay City 1307, Philippines. Email: [email protected], Telephone: +632 8234-2228.

8. Data Retention

8.1 Retention Periods

gili99 retains your personal information only as long as necessary to fulfill the purposes described in this Privacy Policy or as required by Philippine law:

Data Category	Retention Period
Account Information	Duration of active account plus five (5) years after account closure
Transaction Records	Seven (7) years from transaction date per AMLA requirements
Identity Documents	Five (5) years after account closure for regulatory compliance
Communication Records	Three (3) years from last contact for customer service quality and dispute resolution
Marketing Data	Until consent is withdrawn or account is closed
Website Cookies	Varies by cookie type: session cookies expire on browser close, persistent cookies last 1-24 months

8.2 Secure Deletion

When personal information reaches the end of its retention period, gili99 securely deletes or anonymizes it using industry-standard data destruction methods including cryptographic erasure, overwriting, and physical destruction of storage media. Anonymized data may be retained indefinitely for statistical analysis and platform improvement.

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit the gili99 website. Cookies help us recognize your device, remember preferences, maintain login sessions, and analyze platform usage. gili99 uses both first-party cookies (set by our domain) and third-party cookies (set by service providers like Google Analytics).

9.2 Types of Cookies We Use

• Essential Cookies: Required for core functionality including login authentication, account security, transaction processing, and fraud prevention. These cookies cannot be disabled without affecting platform functionality.
• Preference Cookies: Remember your settings such as language selection, currency display, game filters, and display options to enhance user experience.
• Analytics Cookies: Collect anonymous usage data about pages visited, time spent, click patterns, and device information to help us improve the platform. We use Google Analytics and similar services.
• Marketing Cookies: Track your interactions with gili99 marketing campaigns, attribute registrations to affiliate partners, and display personalized advertisements on third-party websites.

9.3 Managing Cookie Preferences

You can control cookies through your browser settings by blocking all cookies, accepting only first-party cookies, or receiving notifications before cookies are set. Note that blocking essential cookies will prevent you from logging in and using gili99 services. Instructions for managing cookies in common browsers:

• Google Chrome: Settings > Privacy and Security > Cookies and other site data
• Mozilla Firefox: Options > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Manage Website Data
• Microsoft Edge: Settings > Cookies and site permissions

10. International Data Transfers

While gili99 primarily operates in the Philippines and stores data on Philippine servers, some third-party service providers (payment processors, game providers, cloud services) may be located outside the Philippines. When transferring your personal information internationally, gili99 ensures adequate protection through:

• Contractual clauses requiring service providers to maintain data protection standards equivalent to Philippine law
• Selecting providers certified under international data protection frameworks such as EU-US Privacy Shield
• Implementing technical safeguards including encryption during transmission and storage
• Conducting due diligence to verify providers' security practices and compliance history

By using gili99 services, you consent to international data transfers necessary to provide gaming services, process payments, and maintain platform functionality as described in this Privacy Policy.

11. Children's Privacy

gili99 services are strictly restricted to individuals aged twenty-one (21) years or older as required by Philippine gaming regulations. We do not knowingly collect personal information from minors under twenty-one (21) years of age. Our registration process requires date of birth verification, and we conduct age checks against government identification documents.

If gili99 becomes aware that we have inadvertently collected personal information from a minor, we will immediately delete the account, erase all associated personal data, and refund any deposits to the funding source. Parents or guardians who believe a minor has registered on gili99 should contact [email protected] immediately with evidence of the minor's age.

12. Changes to This Privacy Policy

gili99 reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. When we make material changes affecting how we collect, use, or share your personal information, we will notify you through:

• Email notification to your registered email address at least thirty (30) days before changes take effect
• Prominent banner notification on the gili99 website and mobile application
• Update to the "Last Updated" date at the top of this Privacy Policy

Your continued use of gili99 services after the effective date of privacy policy changes constitutes acceptance of the updated policy. If you do not agree with policy changes, you may close your account by contacting customer support. We recommend reviewing this Privacy Policy periodically to stay informed about our data practices.

13. Contact Information

Data Protection Officer

For questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact gili99's Data Protection Officer:

• Email: [email protected]
• Customer Support: Available 24/7 via live chat on gili99.cam
• Response Time: We respond to privacy inquiries within seventy-two (72) hours and resolve requests within fifteen (15) business days for most cases

National Privacy Commission

For complaints regarding potential privacy violations, you may contact the National Privacy Commission of the Philippines:

• Address: 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto Street, Pasay City 1307, Philippines
• Email: [email protected]
• Telephone: +632 8234-2228
• Website: www.privacy.gov.ph