fcjili Privacy Policy — How We Protect Your Personal Data

1. Introduction and Scope

Section 1.1 – Purpose of This Policy

This Privacy Policy ("Policy") describes how fcjili ("fcjili", "we", "us", or "our") collects, uses, discloses, stores, and protects the personal data of individuals ("you", "your", or "Data Subject") who access and use the fcjili online gaming platform available at https://fcjili.cam (the "Platform"). This Policy forms an integral part of the fcjili Terms & Conditions and is incorporated by reference into those Terms.

Section 1.2 – Applicable Law

fcjili is committed to compliance with the Republic Act No. 10173, otherwise known as the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and any orders or circulars issued by the National Privacy Commission ("NPC") of the Philippines. Your personal data will be processed only in a manner that is consistent with the principles of transparency, legitimate purpose, and proportionality as prescribed by the DPA.

2. Who We Are

For the purposes of the DPA, fcjili is the Personal Information Controller (PIC) in respect of the personal data processed through the Platform. fcjili is an online gaming platform operating in the Philippines under applicable PAGCOR regulatory standards, serving Filipino players across the country — from Metro Manila, Quezon City, Makati, and Pasig in Luzon, to Cebu City in the Visayas, and Davao, Cagayan de Oro, and General Santos in Mindanao.

Queries relating to this Policy or your data subject rights may be directed to the fcjili Data Protection Officer via the contact channels listed in Section 14.

3. Personal Data We Collect

Section 3.1 – Registration Data

When you create an account with fcjili, we collect the following information:

• Full legal name
• Date of birth (to verify you are at least 21 years of age, as required by PAGCOR)
• Philippine mobile number
• Email address
• Username and encrypted password
• Preferred language

Section 3.2 – KYC Identity Verification Data

In compliance with PAGCOR requirements and the Philippine Anti-Money Laundering Act (RA 9160, as amended), fcjili collects the following identity verification documents:

• Government-issued photo identification (UMID, driver's licence, passport, Postal ID, SSS/GSIS ID, or PhilSys National ID)
• Proof of residential address (utility bill, bank statement, or similar document)
• Selfie photograph for liveness and document matching verification, where required

Section 3.3 – Financial and Transaction Data

We collect and process the following financial data in connection with your use of the Platform:

• GCash or Maya mobile wallet details (account number or registered mobile number only; no full wallet credentials)
• Bank account details for BPI, BDO, or Metrobank withdrawals where applicable
• Deposit and withdrawal history, amounts, timestamps, and payment method references
• Betting and gaming transaction history, including game type, stake, outcome, and timestamp
• Bonus and promotion usage history

Section 3.4 – Technical and Device Data

When you access the Platform, we automatically collect:

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Session identifiers and authentication tokens
• Pages visited, features accessed, and time spent on Platform sections
• Error logs and crash reports

Section 3.5 – Communications Data

Records of communications between you and fcjili's support team — including live chat transcripts, email correspondence, and support ticket histories — are retained as part of our service records.

4. How We Collect Your Data

fcjili collects your personal data through the following means:

• Directly from you — through registration forms, KYC document submission, payment processing flows, responsible gaming tool configurations, and communications with the support team.
• Automatically — through cookies, session tokens, server logs, and similar technologies when you navigate the Platform. See Section 9 for further detail on cookies.
• From payment providers — GCash, Maya, and other payment partners may share transaction confirmation data with fcjili to reconcile deposits and withdrawals.
• From identity verification partners — where fcjili uses third-party KYC or document verification services, those providers may return verification results and risk scores to fcjili.
• From fraud prevention and AML screening services — fcjili may receive risk signals or alerts from third-party compliance tools as part of its Anti-Money Laundering obligations under Philippine law.

5. Purposes and Legal Bases for Processing

The table below summarises the primary purposes for which fcjili processes your personal data and the legal basis under the DPA for each purpose:

6. Disclosure of Your Personal Data

Section 6.1 – Third Parties We Share Data With

fcjili does not sell your personal data to third parties for marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and only to the extent required for the purposes described in Section 5:

• Payment processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, Coins.ph, and other payment partners, to facilitate your financial transactions.
• KYC and identity verification providers: Licensed third-party providers that assist fcjili in verifying the authenticity of identity documents submitted during the KYC process.
• Game software providers: JILI Gaming, PG Soft, Pragmatic Play, CQ9, and other licensed game studios whose games are hosted on or accessible via the Platform. These providers may receive session and bet data for game delivery and RNG audit purposes.
• Fraud prevention and AML compliance services: Third-party services that assist fcjili in detecting fraud, suspicious transactions, and money laundering activity as required by RA 9160 and AMLC regulations.
• IT infrastructure and cloud service providers: Data centres, hosting providers, and cloud service vendors that host or process Platform data on fcjili's behalf under appropriate data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or court order.

Section 6.2 – Data Processing Agreements

All third-party service providers who process personal data on behalf of fcjili are bound by appropriate data processing agreements or equivalent contractual safeguards that require them to process personal data only on fcjili's documented instructions and in compliance with applicable Philippine privacy law.

7. Data Retention

fcjili retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply as general guidelines:

• Account and KYC data: Retained for the duration of the account relationship and for a minimum of five (5) years after account closure, in compliance with AMLC record-keeping requirements.
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with the Anti-Money Laundering Act.
• Game and betting history: Retained for a minimum of one (1) year from the date of the game round, and for the duration of any active dispute relating to those transactions.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Technical and device log data: Retained for up to twelve (12) months for security and fraud detection purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that renders it impossible to re-identify the data subject.

8. Security Measures

fcjili implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption: All data transmitted between your device and the fcjili Platform is protected by TLS (Transport Layer Security) encryption. Account passwords are stored using industry-standard one-way cryptographic hashing algorithms — they are never stored in plain text.
• Session tokenisation: Login sessions are managed through secure, time-limited tokens to reduce the risk of session hijacking.
• Access controls: Access to systems containing personal data is restricted to authorised fcjili personnel on a need-to-know basis, with role-based access controls and audit logging.
• Intrusion detection: fcjili operates automated systems to detect and respond to suspicious access patterns and potential security incidents.
• Vendor security assessments: Third-party providers handling personal data on fcjili's behalf are assessed for their security posture before engagement.

9. Cookies and Tracking Technologies

Section 9.1 – Types of Cookies Used

The fcjili Platform uses cookies and similar tracking technologies to provide and improve the Platform experience. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming configurations, to provide a personalised experience.
• Analytics cookies: Collect aggregated, anonymised data on Platform usage — such as which games are most popular and where users encounter errors — to help fcjili improve the Platform. This data does not identify you individually.
• Session replay and heatmap cookies: Used to understand how users interact with specific Platform pages in order to improve user experience design.

Section 9.2 – Managing Cookies

You may control non-essential cookies through your browser's cookie settings. Please note that disabling certain cookies may affect the functionality of the Platform. Most modern browsers (Chrome, Safari, Firefox) provide settings to block or delete cookies. On mobile browsers commonly used in the Philippines, these settings are accessible via the browser's Privacy or Site Settings menu.

10. Your Rights as a Data Subject

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

• Right to be Informed: You have the right to know how your personal data is being collected and processed, which this Policy fulfils.
• Right to Access: You may request a copy of the personal data that fcjili holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Account profile information can be updated directly from your account settings for many fields.
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data where there is no longer a legal or contractual basis for fcjili to retain it. Note that certain data must be retained for regulatory compliance purposes (see Section 7) and cannot be erased on request.
• Right to Object: You may object to processing of your personal data based on legitimate interest, including the use of your data for personalised promotions.
• Right to Data Portability: You may request your personal data in a structured, commonly used, and machine-readable format to transfer to another service provider, where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe fcjili has not handled your personal data in accordance with the DPA.

To exercise any of the above rights, contact the fcjili Data Protection Officer through the channels described in Section 14. fcjili will respond to verified data subject requests within fifteen (15) business days of receipt, or such other period as prescribed by the NPC.

11. Children and Minors

The fcjili Platform is strictly restricted to persons who are at least 21 years of age, in accordance with PAGCOR's minimum age requirements for real-money gaming in the Philippines. fcjili does not knowingly collect personal data from individuals under 21 years of age.

If fcjili becomes aware that personal data has been collected from a person under 21 years of age, that account will be suspended immediately, all associated data will be flagged for deletion (subject to any mandatory retention obligations), and the matter may be escalated to relevant Philippine regulatory authorities. If you believe a minor has registered on the Platform, please notify us immediately via the contact channels in Section 14.

12. Cross-Border Data Transfers

In the course of operating the fcjili Platform, personal data may be processed by third-party service providers whose systems are located outside the Philippines. This includes cloud infrastructure providers, game software platforms, and certain KYC verification services.

Any transfer of personal data outside the Philippines is conducted in accordance with Section 21 of the DPA and the NPC's guidelines on cross-border data transfers. fcjili ensures that recipient countries or organisations offer a comparable level of data protection, either through adequacy determinations, contractual data transfer safeguards, or binding corporate rules. fcjili does not transfer personal data to jurisdictions that do not offer adequate protections without implementing appropriate supplementary safeguards.

13. Changes to This Privacy Policy

fcjili reserves the right to amend this Privacy Policy at any time in response to changes in applicable law, regulatory guidance, or our data processing practices. Material changes to this Policy will be communicated to registered players by email or via a prominent notice on the Platform at least seven (7) days before the revised Policy takes effect.

The "Effective Date" at the top of this Policy reflects the date of the most recent revision. Continued use of the Platform after the effective date of a revised Policy constitutes your acceptance of the updated terms. If you do not agree to a material amendment, you may close your account in accordance with the account closure procedure described in the fcjili Terms & Conditions.

14. Contact and Complaints

For any queries, concerns, or requests relating to this Privacy Policy or your data subject rights, please contact the fcjili Data Protection Officer through the following channels. Contact details are provided as plain text only:

• Live Chat: The fastest channel — available 24 hours a day, 7 days a week via the chat widget on the Platform, including Philippine public holidays.
• Email: [email protected] — please include "Data Privacy Request" in your subject line for routing to the Data Protection Officer.
• Response Time: fcjili aims to acknowledge all data privacy correspondence within two (2) business days and to resolve requests within fifteen (15) business days.

If you are not satisfied with fcjili's response to your data privacy concern, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data protection matters under RA 10173.