Privacy Policy — kkkjilli Online Gaming

1 Who We Are

kkkjilli ("we", "our", "the Platform") is a PAGCOR-licensed online gaming platform operating through the website kkkjilli.net and serving players in the Philippines. kkkjilli is the Data Controller for all personal information collected from players and visitors to the platform.

Our registered Data Protection Officer (DPO) can be reached at support@kkkjilli.net with the subject line "Data Privacy Inquiry". Philippine players also have the right to lodge complaints directly with the National Privacy Commission (NPC) if they believe kkkjilli has not handled their data in accordance with RA 10173.

2 Personal Data We Collect

kkkjilli collects only the information necessary to operate a regulated gaming platform and comply with PAGCOR licensing requirements and Philippine anti-money laundering laws. The categories of data we collect are described below.

Registration and Identity Data

When you create a kkkjilli account, we collect your full legal name, date of birth, Philippine mobile number, and email address. This is the minimum information required to create an account. During KYC (Know Your Customer) verification — which is required before withdrawals above PAGCOR-specified thresholds — we additionally collect:

• Government-issued photo identification (Philippine passport, SSS/UMID card, PhilHealth ID, driver's license, or voter's ID)
• Proof of current Philippine residential address (utility bill, bank statement, or barangay certificate)
• Proof of payment method ownership (screenshot of your GCash or Maya account showing your registered name)

Financial Transaction Data

kkkjilli records all financial transactions on your account including deposit amounts, payment methods used, withdrawal requests, bonus credit and debit events, and running account balance history. This data is retained as required by PAGCOR regulations and the Anti-Money Laundering Act (AMLA) of the Philippines.

Gaming Activity Data

We record your gaming history across all kkkjilli products including Tongits hands played, Pusoy sessions, sports bets placed (including stake amounts, selections, and outcomes), casino game sessions, and tournament participation. This data is used for account statements, dispute resolution, and responsible gaming monitoring.

Device and Technical Data

When you access kkkjilli, we automatically collect certain technical data including your IP address, device type and operating system, browser type and version, session timestamps, and platform interaction logs. This data is used for security monitoring, fraud detection, and platform performance optimisation.

Communications Data

All communications between you and kkkjilli — including live chat transcripts, email correspondence, and customer support ticket records — are retained for dispute resolution, quality assurance, and regulatory compliance purposes.

3 How We Collect Your Data

kkkjilli collects personal data through three main channels:

• Directly from you — When you register, complete KYC, make deposits or withdrawal requests, contact customer support, or participate in promotions, you provide data directly to kkkjilli.
• Automatically through the platform — When you access and use kkkjilli, the platform automatically logs technical data including your IP address, session activity, game actions, and device information. This collection is handled through standard web server logging, cookies, and our gaming platform's event tracking system.
• From third-party service providers — Our payment processors (GCash, Maya, InstaPay-connected banks) confirm payment transaction details. Our identity verification partner confirms KYC document authenticity. PAGCOR's regulatory systems may share compliance-relevant information with kkkjilli.

4 How We Use Your Data

kkkjilli uses personal data for specific, legitimate purposes aligned with our PAGCOR licensing obligations and the services we provide to Philippine players. We do not use your data for any purpose that is incompatible with the reason it was collected.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules, kkkjilli processes personal data under the following legal bases depending on the purpose:

• Fulfillment of a contract — Most data processing at kkkjilli is necessary to provide the services you registered for. Operating your account, processing payments, and running games all fall under this basis.
• Compliance with a legal obligation — PAGCOR's licensing conditions require kkkjilli to collect and retain specific data including KYC documentation, financial transaction records, and gaming activity logs. The Anti-Money Laundering Act (AMLA) of the Philippines also mandates specific data collection and reporting obligations.
• Legitimate interest — Security monitoring, fraud detection, responsible gaming analytics, and customer support improvement are conducted on the basis of kkkjilli's legitimate business interests, balanced against your privacy rights.
• Consent — Marketing communications (promotional emails, SMS notifications about bonuses and tournaments) are sent only with your explicit consent at registration. You can withdraw this consent at any time by updating your communication preferences in your kkkjilli account settings or by emailing support@kkkjilli.net.

6 Sharing Your Personal Data

kkkjilli does not sell, rent, or trade your personal data to third-party marketers or data brokers under any circumstances. We share data only in the following limited and necessary situations:

PAGCOR and Philippine Regulatory Authorities

As a PAGCOR-licensed operator, kkkjilli is required to provide player data to PAGCOR on request and to submit regular compliance reports. We are also legally required to report suspicious transactions to the Anti-Money Laundering Council (AMLC) under the AMLA. These disclosures are not discretionary — they are mandatory legal obligations.

Payment Processors

To process your deposits and withdrawals, kkkjilli shares necessary transaction data with our payment partners — GCash, Maya, GrabPay, Coins.ph, and InstaPay-connected Philippine banks. The data shared is limited to what is required to process each specific transaction. Each payment partner operates under its own privacy policy and Philippine BSP regulations.

Identity Verification Partners

kkkjilli uses a PAGCOR-approved third-party identity verification service to validate KYC documents. Your identification documents are transmitted to this service securely for verification only. The service does not retain your documents after verification is complete.

Technology Infrastructure Providers

kkkjilli's platform runs on cloud infrastructure and uses gaming software provided by licensed technology partners. These partners may process limited technical data as part of providing infrastructure services. All technology partners are contractually bound to handle kkkjilli player data only for the purposes specified and in compliance with Philippine data protection standards.

7 Cookies and Tracking Technologies

kkkjilli uses cookies and similar tracking technologies to operate the platform and improve your experience. Here's what we use and why:

Strictly Necessary Cookies

These cookies are essential for kkkjilli to function. They manage your login session, maintain your game state, remember your preferences within a session, and ensure security features work correctly. You cannot opt out of strictly necessary cookies without disrupting your use of kkkjilli.

Performance and Analytics Cookies

kkkjilli uses anonymised analytics data to understand how players navigate the platform and identify areas for improvement. This data is aggregated and does not identify individual players. You can opt out of performance cookies in your browser settings without affecting core platform functionality.

Fraud Prevention Cookies

Our security systems use device fingerprinting and session analysis to detect unusual account activity, identify multi-accounting attempts, and prevent bot access to the platform. These are operated under kkkjilli's legitimate interest in maintaining platform security.

You can manage your cookie preferences through your browser settings. Note that disabling cookies beyond strictly necessary ones may affect some kkkjilli features including promotional pop-ups and personalised game recommendations.

8 How Long We Keep Your Data

kkkjilli retains personal data only for as long as it is necessary for the purpose for which it was collected, subject to overriding legal retention requirements. The following retention periods apply:

• Active account data — Retained for the duration of your account and for 5 years after account closure (required by PAGCOR and AMLA)
• KYC/identity documents — Retained for 5 years from the date of verification or 5 years from account closure, whichever is later
• Financial transaction records — Retained for 10 years as required by the Anti-Money Laundering Act
• Gaming history logs — Retained for 2 years for active accounts and 5 years post-closure for regulatory compliance
• Customer support communications — Retained for 2 years from the date of the last interaction on a ticket
• Marketing consent records — Retained for 3 years from the date consent was given or withdrawn
• Device/technical logs — Retained for 12 months for security monitoring purposes

When data reaches the end of its retention period and no legal obligation requires further retention, kkkjilli securely deletes or irreversibly anonymises the data. You will not receive a notification for routine data deletion at the end of standard retention periods.

9 How We Protect Your Data

kkkjilli implements multiple layers of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction:

• Encryption in transit: All data exchanged between your device and kkkjilli uses TLS 1.2 or higher encryption. This applies to your login, all game actions, and all payment transactions.
• Encryption at rest: Sensitive stored data including your identity documents, payment information, and KYC records are encrypted at rest using AES-256 encryption.
• Access controls: kkkjilli staff access to player data is role-based and strictly limited to what is required for each job function. Access to KYC documents is limited to the compliance team only.
• Penetration testing: kkkjilli's platform undergoes regular security audits and penetration testing by independent cybersecurity professionals.
• Incident response: kkkjilli has a documented data breach response procedure. In the event of a breach that affects your personal data and creates a risk to your rights, you will be notified within 72 hours as required by the NPC's breach notification rules.

10 Your Data Rights Under Philippine Law

The Philippine Data Privacy Act of 2012 grants you specific rights over your personal data held by kkkjilli. These rights can be exercised by submitting a request to support@kkkjilli.net with "Data Rights Request" in the subject line. kkkjilli will respond to all valid requests within 15 business days.

11 Children and Minors

kkkjilli is strictly an adult platform. Under PAGCOR regulations and Philippine law, participation in online gaming is prohibited for persons under 21 years of age. kkkjilli does not knowingly collect personal data from persons under 21.

If you are a parent or guardian and believe your minor child has created a kkkjilli account, please contact us immediately at support@kkkjilli.net. We will close the account, delete all associated personal data, and return any deposited funds to the payment method used. All such reports are treated with the highest priority.

During registration, kkkjilli requires age confirmation and may request date of birth verification. Accounts where age falsification is suspected are flagged for mandatory KYC and suspended until identity is confirmed.

12 Changes to This Privacy Policy

kkkjilli may update this Privacy Policy from time to time to reflect changes in our data practices, new platform features, or updated regulatory requirements. Material changes will be communicated to registered players via email at least 7 days before they take effect.

The date at the top of this page shows when this policy was last updated. We recommend reviewing this page periodically. Your continued use of kkkjilli after the effective date of any changes constitutes acceptance of the updated Privacy Policy. If you do not agree with an updated version, you may close your account and request deletion of non-mandatory data by contacting us.

13 Contact and Data Rights Requests

For all privacy-related matters — including data access requests, correction requests, erasure requests, and questions about this policy — contact kkkjilli's Data Protection Officer: