1 Introduction
This Privacy Policy explains how 38jili ("we", "us", "our") collects, uses, stores, and protects personal information provided by members and visitors who use the 38jili platform at 38jili.best and any associated mobile-optimised interfaces.
By registering an account on 38jili, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. This policy should be read alongside our Terms and Conditions, which govern the overall use of the platform.
We take data privacy seriously — not just because the law requires it, but because our members deserve to know exactly what happens to their personal information when they trust 38jili with it. This document is written in plain, accessible language so that every Filipino member can understand their rights and our obligations without needing a legal background.
From Cebu to Manila, 38jili protects the personal data of every Filipino member with the same standard of care.
2 Data Controller
For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and applicable privacy regulations, 38jili is the data controller responsible for your personal information collected through this platform.
As data controller, 38jili determines the purposes and means of processing your personal data. Where 38jili engages third-party service providers who process data on our behalf (for example, payment processors or analytics providers), those providers act as data processors under written agreements that require them to handle your data in accordance with this policy and applicable law.
For all privacy-related enquiries, data access requests, or concerns, you can contact our designated Data Protection Officer at privacy@38jili.best. We will respond to all legitimate privacy requests within 15 business days.
3 Data We Collect
38jili collects personal data in several categories depending on how you interact with the platform. Below is a clear breakdown of the data types, what specific information they include, and why we collect them.
| Data Category | Examples | Purpose |
|---|---|---|
| Identity Data | Full name, date of birth, government ID details | Account verification, age confirmation, KYC compliance |
| Contact Data | Mobile number, email address | Account communications, security alerts, support |
| Financial Data | Payment method type, GCash/Maya mobile number, transaction records | Processing deposits and withdrawals, fraud prevention |
| Technical Data | IP address, device type, browser, OS, session logs | Security monitoring, platform optimisation |
| Usage Data | Games played, bets placed, pages visited, time on platform | Platform improvement, responsible gaming monitoring |
| Communications Data | Live chat transcripts, email correspondence, support ticket content | Resolving disputes, training, quality assurance |
| Preference Data | Game preferences, notification settings, language preferences | Personalising your platform experience |
We do not collect sensitive personal data such as race, religion, health information, or biometric data. Financial card numbers are never stored on 38jili's own servers — they are processed directly by our certified payment processors.
4 How We Collect Your Data
38jili collects personal data through the following channels:
- Direct submission: When you register an account, complete identity verification, make a deposit or withdrawal, or contact our support team.
- Automated collection: When you use the platform, we automatically collect technical and usage data through server logs, cookies, and similar technologies.
- Payment processors: When you make a deposit or withdrawal, our payment partners share transaction confirmation details with us to credit or debit your account correctly.
- Identity verification partners: When you complete KYC verification, our verification partner shares the result of the verification check with us.
Mobile payments on 38jili are processed through certified payment partners — your financial details are never stored on our servers.
5 Why We Use Your Data
38jili processes your personal data only for legitimate, specific purposes. Below are the main reasons we use the data we collect:
5.1 Operating Your Account
Your identity and contact data are necessary to create and maintain your 38jili account, verify your age and identity, process your deposits and withdrawals, settle your bets, and send you essential account communications such as deposit confirmations and security alerts.
5.2 Legal and Regulatory Compliance
As a licensed online gaming platform, 38jili is legally required to verify member identities, maintain transaction records, report suspicious activity to relevant authorities, and comply with anti-money laundering (AML) requirements. We process your data to fulfil these obligations.
5.3 Fraud Prevention and Security
Technical and usage data help us detect and prevent fraudulent activity, unauthorised account access, and abuse of the platform. This protects both you and all other members of 38jili.
5.4 Responsible Gaming
Usage data helps 38jili's responsible gaming team identify patterns that may indicate problematic gambling behaviour. Where concerns arise, we may contact affected members to offer support tools. This use of data is in the interests of member welfare and consistent with our responsible gaming commitments.
5.5 Platform Improvement
Aggregated, anonymised usage data helps us understand how members use 38jili and where we can improve the experience. No individually identifiable information is used in product development analysis.
5.6 Marketing Communications
With your consent, 38jili may send you promotional communications about new games, bonuses, and platform updates. You can opt out of marketing emails at any time by clicking the unsubscribe link in any email we send, or by updating your communication preferences in your account settings. Opting out of marketing does not affect your ability to use the platform or receive essential account communications.
38jili will never use your personal data for purposes that are incompatible with the reasons it was originally collected, without first obtaining your explicit consent or as otherwise permitted by law.
6 Sharing Your Data
38jili does not sell your personal data. We share your data only in the following limited circumstances:
- Payment processors (GCash, Maya, BDO, BPI, UnionBank, Visa/Mastercard networks): We share necessary transaction data to facilitate deposits and withdrawals. These providers are certified and operate under their own privacy frameworks.
- Identity verification partners: We share your identity documents and verification data with KYC/AML service providers for the purpose of verifying your identity and age. These partners process data under strict contractual obligations.
- Regulatory authorities: We are required by law to disclose certain transaction and identity data to relevant Philippine government agencies and regulators upon lawful request.
- Law enforcement: Where required by a valid court order or legal process, 38jili will cooperate with law enforcement authorities.
- Technology service providers: We use third-party providers for platform hosting, analytics, and security monitoring. These providers access only the minimum data necessary for their services and are contractually bound to maintain data confidentiality.
In all cases where data is shared with third parties, 38jili ensures that appropriate data processing agreements are in place to protect your information.
38jili's privacy practices are grounded in Philippine law and respect for every member's personal data.
7 Data Retention
38jili retains your personal data for as long as your account is active and for a period after account closure as required by law and legitimate business interests. Specific retention periods are as follows:
- Account and identity data: Retained for a minimum of 5 years after account closure to comply with AML and gaming regulatory requirements.
- Transaction records: Retained for a minimum of 5 years from the date of each transaction, in line with financial record-keeping requirements.
- Support communications: Retained for 2 years from the date of the last communication, or longer if the matter relates to an ongoing dispute or legal proceeding.
- Usage and technical data: Typically retained for 12 months in identifiable form, after which it may be anonymised and retained indefinitely for analytical purposes.
- Marketing preference data: Retained until you withdraw consent or request deletion.
When data is no longer required, it is securely deleted or anonymised in accordance with 38jili's data disposal procedures.
8 Security Measures
38jili implements a range of technical and organisational security measures to protect your personal data from unauthorised access, loss, alteration, or disclosure. These include:
- Transport Layer Security (TLS) encryption for all data in transit between your device and our servers.
- Encryption of sensitive data at rest, including financial and identity information.
- Access controls limiting which 38jili employees can access specific categories of personal data, based on their job function.
- Regular security audits and penetration testing by qualified third-party specialists.
- Two-factor authentication (2FA) available to all members for account login protection.
- Real-time monitoring systems that detect unusual account activity and flag potential security incidents.
Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that affects your personal data, 38jili will notify you and the National Privacy Commission (NPC) in accordance with the timelines required by Philippine law.
9 Cookies and Tracking Technologies
38jili uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse usage patterns. Cookies are small text files stored on your device when you visit the platform.
9.1 Types of Cookies We Use
- Essential cookies: Necessary for the platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
- Functional cookies: Remember your preferences such as language settings and notification preferences. Disabling these may affect your experience but will not prevent you from using the platform.
- Analytics cookies: Help us understand how members use 38jili so we can improve the platform. Data collected is aggregated and not used to identify you individually.
9.2 Managing Cookies
You can control cookie settings through your browser preferences. Disabling certain cookies may affect how the platform functions. Note that essential cookies cannot be disabled as they are required for basic platform operation and security.
10 Minors and Age Verification
38jili is strictly for individuals who are 21 years of age or older. We do not knowingly collect personal data from anyone under 21. If we become aware that an account has been registered by a minor, we will immediately suspend the account, delete the associated personal data, and void any bets or transactions made by that account.
Parents and guardians who are concerned that a minor may have registered on 38jili should contact our support team at support@38jili.best immediately. We will investigate and act promptly.
11 Your Privacy Rights
Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights regarding your personal data held by 38jili. These rights apply to all members, regardless of which region of the Philippines you are in.
Right to Access
Request a copy of all personal data 38jili holds about you, including how it is being used.
Right to Correction
Request correction of inaccurate or incomplete personal data held in your account.
Right to Erasure
Request deletion of your personal data where it is no longer necessary for the purposes it was collected, subject to legal retention obligations.
Right to Object
Object to processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
Right to Portability
Receive your personal data in a structured, machine-readable format so you can transfer it to another service if you choose.
Right to Complain
Lodge a complaint with the National Privacy Commission (NPC) if you believe 38jili has not handled your data in accordance with the law.
To exercise any of these rights, contact our Data Protection Officer at privacy@38jili.best with your request. We will verify your identity before processing any data access or deletion requests, and will respond within 15 business days.
12 Updates to This Policy
38jili may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When we make material changes, we will:
- Update the "Last updated" date at the top of this page.
- Send an email notification to all registered members at least 7 days before the changes take effect.
- Display a notice on the platform highlighting the key changes.
Continued use of the 38jili platform after the effective date of an updated Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, please stop using the platform and contact us to close your account.
13 Contact and Complaints
If you have any questions about this Privacy Policy, how 38jili handles your personal data, or if you wish to exercise any of your data rights, please contact us through the following channels:
- Data Privacy Enquiries: privacy@38jili.best
- General Support: support@38jili.best
- Live Chat: Available 24/7 through the 38jili platform after logging in
If you are not satisfied with our response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) through their official website or their complaints email address. 38jili fully cooperates with the NPC and takes all formal complaints seriously.
For responsible gaming concerns or to access self-exclusion tools, please visit our Responsible Gaming page for dedicated resources.