2jil Privacy Policy

1. Who We Are

2jil ("the Company," "we," "us," or "our") is the operator of the online gaming platform accessible at 2jil.org, licensed by the Philippine Amusement and Gaming Corporation (PAGCOR) to provide online gaming services to eligible players in the Philippines. 2jil acts as the Personal Information Controller for the personal data processed through the platform, as that term is defined under the Data Privacy Act of 2012 (DPA) and its implementing rules.

All references in this Privacy Policy to "the 2jil platform," "2jil services," or "the platform" refer collectively to the 2jil website, mobile application, customer support channels, and all associated digital properties operated by the Company.

2. Scope of This Policy

This Privacy Policy applies to:

• All registered 2jil account holders ("Players");
• Visitors who access the 2jil platform without registering;
• Individuals who communicate with 2jil via live chat, email, or any other support channel.

This Policy does not apply to third-party websites, payment processors, or game studios whose services are accessed through the 2jil platform. Those third parties operate under their own privacy policies, which we encourage you to review independently. 2jil is not responsible for the privacy practices of any third party.

3. Personal Data We Collect

2jil collects only the personal data necessary for the purposes described in Section 5 of this Policy. The categories of data we may collect include:

We do not collect special categories of personal data (such as health data, racial or ethnic origin, religious beliefs, or biometric data) except where strictly required by Applicable Law or PAGCOR directives and with your explicit consent.

4. How We Collect Your Data

2jil collects personal data through the following means:

• Direct Provision: Data you provide when registering a 2jil account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotions;
• Automated Technologies: Data collected automatically as you interact with the platform, including IP addresses, device data, session logs, and cookies (see Section 7);
• Third-Party Sources: Data received from payment service providers (e.g., GCash, Maya, BPI) necessary to process your transactions, and from identity verification and AML screening services engaged by 2jil to fulfill its regulatory obligations under PAGCOR licensing conditions and the Anti-Money Laundering Act (AMLA).

5. Purpose & Legal Basis for Processing

2jil processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

• Account Registration & Management — To create and maintain your 2jil account, authenticate your identity at login, and provide access to platform services. Legal basis: performance of contract.
• Transaction Processing — To process deposits, withdrawals, and bonus credits to and from your 2jil Wallet. Legal basis: performance of contract.
• KYC & Age Verification — To verify that you meet the PAGCOR-mandated minimum age of 21 years and to confirm your identity as required under PAGCOR licensing conditions. Legal basis: compliance with legal obligation.
• Anti-Money Laundering (AML) Compliance — To conduct transaction monitoring, suspicious activity reporting, and customer due diligence required under the Philippine AMLA (Republic Act No. 9160, as amended). Legal basis: compliance with legal obligation.
• Customer Support — To respond to your inquiries, complaints, and requests made through 2jil's support channels. Legal basis: performance of contract / legitimate interest.
• Responsible Gaming — To enforce deposit limits, process self-exclusion requests, and monitor gaming activity for indicators of problem gambling as required by PAGCOR. Legal basis: compliance with legal obligation / legitimate interest.
• Platform Security & Fraud Prevention — To detect and prevent unauthorized access, cheating, bonus abuse, and other fraudulent or harmful activity on the platform. Legal basis: legitimate interest.
• Marketing & Promotions — To send you information about 2jil promotions, new games, and special offers, where you have consented to receive such communications. Legal basis: consent (withdrawable at any time).
• Legal Compliance & Regulatory Reporting — To comply with orders, directives, and reporting requirements issued by PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities. Legal basis: compliance with legal obligation.

6. Sharing Your Personal Data

2jil does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients, strictly for the purposes described in Section 5:

• Payment Service Providers: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and other payment processors, solely to process your financial transactions;
• Game Studios & Platform Providers: Licensed game suppliers (e.g., Evolution Gaming, JILI, Pragmatic Play, PG Soft) who deliver games on the 2jil platform, to the extent necessary for game session authentication and game history retrieval;
• Identity Verification & AML Service Providers: Third-party KYC and AML screening providers engaged by 2jil to fulfill its PAGCOR and AMLA compliance obligations;
• Regulatory & Law Enforcement Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council, and other Philippine government authorities, when required by law, court order, or regulatory directive;
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by 2jil, subject to professional confidentiality obligations;
• Business Successors: In the event of a merger, acquisition, or transfer of 2jil's business or assets, personal data may be transferred to the successor entity, subject to the protections of this Privacy Policy.

All third-party service providers engaged by 2jil are required to process personal data only on 2jil's instructions and in accordance with data processing agreements that include appropriate data protection obligations consistent with the DPA.

7. Cookies & Tracking Technologies

2jil uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small data files stored on your device when you access 2jil.org. We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function — session authentication, security tokens, login state management. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences (e.g., language, game lobby filters) to improve your experience on 2jil.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the platform, helping 2jil identify and resolve performance issues and improve the user interface.
• Security Cookies: Used for fraud detection and platform security purposes, including detecting unusual login patterns or suspicious session behavior.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will affect your ability to access the 2jil platform. 2jil does not use advertising tracking cookies or share behavioral data with advertising networks.

8. Data Retention

2jil retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Applicable Law:

• KYC and identity verification records: Minimum of five (5) years from account closure, as required under Philippine AMLA regulations;
• Transaction records: Minimum of five (5) years from the date of the transaction;
• Account data: Duration of the active account plus five (5) years from the date of account closure;
• Customer support communications: Three (3) years from the date of the interaction;
• Marketing consent records: Until consent is withdrawn plus one (1) year for evidence of compliance.

Upon expiry of applicable retention periods, 2jil will securely delete or anonymize your personal data in accordance with its data retention and disposal procedures.

9. Data Security

2jil implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS 1.3) with 256-bit AES encryption for all data in transit between your device and 2jil's servers;
• Encryption of sensitive data fields (including passwords and financial account identifiers) at rest using industry-standard algorithms;
• Role-based access controls limiting employee access to personal data to only those with a legitimate need;
• Multi-factor authentication for administrative access to systems that process personal data;
• Regular security audits, vulnerability assessments, and penetration testing of platform infrastructure;
• Documented data breach response procedures, including notification to the National Privacy Commission (NPC) and affected individuals within the timeframes required by the DPA in the event of a personal data breach.

While 2jil implements robust security measures, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your 2jil account credentials.

10. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 2jil:

• Right to be Informed: The right to know what personal data 2jil collects about you and how it is used — this Privacy Policy is 2jil's primary mechanism for fulfilling this right;
• Right of Access: The right to obtain a copy of your personal data held by 2jil;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected;
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data, subject to 2jil's legal retention obligations under PAGCOR and AMLA requirements;
• Right to Object: The right to object to the processing of your personal data for marketing purposes; this right does not apply to processing based on legal obligation or performance of contract;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact 2jil's Data Protection Officer using the contact details in Section 14. 2jil will respond to your request within fifteen (15) business days of receipt.

11. Children's Privacy

The 2jil platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations. 2jil does not knowingly collect personal data from individuals under 21 years of age. If 2jil discovers or is notified that it has inadvertently collected personal data from an underage individual, 2jil will immediately suspend the relevant account, delete the associated personal data (to the extent not required to be retained under Applicable Law), and report the matter to PAGCOR as required. If you believe a minor has registered on the 2jil platform, please notify us immediately via the contact details in Section 14.

12. Cross-Border Data Transfers

2jil primarily processes personal data within the Philippines. Where personal data must be transferred to third-party service providers located outside the Philippines (for example, certain game studio infrastructure providers or cloud hosting providers), 2jil ensures that such transfers are made in compliance with the Data Privacy Act and its implementing rules, including ensuring that the recipient country provides an adequate level of data protection or that appropriate contractual safeguards (such as Standard Contractual Clauses) are in place.

13. Changes to This Privacy Policy

2jil reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or PAGCOR directives. When material changes are made, 2jil will notify registered Players via in-platform notification or email to the address registered on the Player's 2jil account. The updated Privacy Policy will be published on this page with a revised "Last Updated" date. Continued use of the 2jil platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

14. Contact & Data Protection Officer

For questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data by 2jil, please contact our Data Protection Officer (DPO):

• Data Protection Officer, 2jil
• Email: [email protected] (plain text — do not click; this is not a hyperlink)
• Live Chat: Available 24/7 within the 2jil platform

If you are not satisfied with 2jil's response to a privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines, which is the competent data protection supervisory authority.