gili58 Privacy Policy

This Privacy Policy ("Policy") describes how gili58 ("Company," "We," "Us," "Our"), a Philippine Amusement and Gaming Corporation (PAGCOR) licensed online gaming operator, collects, uses, processes, discloses, and safeguards your personal information when you use our website at https://gili58.cam, mobile applications, and related services (collectively, the "Platform").

By accessing or using the gili58 Platform, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with our privacy practices, you must immediately discontinue use of our Platform and services.

1. Information We Collect

1.1 Personal Information You Provide

When you register for a gili58 account, use our services, or communicate with us, we collect the following categories of personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification numbers (e.g., Philippine passport number, driver's license number, National ID number);
• Contact Information: Residential address, email address, mobile phone number, alternative contact details;
• Account Credentials: Username, password (stored in encrypted form), security questions and answers;
• Financial Information: Payment method details (GCash account, PayMaya account, bank account numbers), transaction history, deposit and withdrawal records, betting history;
• Verification Documents: Copies of government-issued IDs, proof of address documents (utility bills, bank statements), selfie photographs for identity verification;
• Communication Data: Records of your communications with our customer support team via live chat, email, or phone, including complaint details and resolution records;
• Marketing Preferences: Consent preferences for receiving promotional communications, newsletter subscriptions, and marketing material preferences.

1.2 Information Collected Automatically

When you access the gili58 Platform, we automatically collect certain technical and usage information through cookies, server logs, and similar technologies:

• Device Information: Device type, operating system, browser type and version, device identifiers (IMEI, MAC address), screen resolution;
• Connection Information: IP address, internet service provider, geographic location (country, region, city), time zone settings;
• Usage Data: Pages visited, games played, betting patterns, session duration, click-through rates, referral sources, search queries within the Platform;
• Cookie Data: Unique identifiers stored in cookies and similar tracking technologies to maintain your session, remember your preferences, and analyze Platform usage;
• Performance Data: Platform loading times, error reports, crash logs, and other performance metrics to improve service quality.

1.3 Information from Third-Party Sources

We may receive additional information about you from third-party sources, including:

• Payment processors (GCash, PayMaya, banks) to verify transactions and prevent fraud;
• Identity verification services to confirm your identity and comply with Know Your Customer (KYC) requirements;
• Credit reference agencies to assess financial risk and prevent money laundering;
• Marketing partners who provide aggregated demographic data to help us better understand our user base;
• Social media platforms if you choose to link your social media accounts to your gili58 account;
• Law enforcement agencies, regulatory authorities, or courts in response to lawful requests or legal obligations.

2. How We Use Your Information

2.1 Legal Bases for Processing

Under the Data Privacy Act of 2012, we process your personal information based on the following legal grounds:

• Consent: You have given explicit consent for us to process your personal information for specific purposes;
• Contract Performance: Processing is necessary to perform our contractual obligations to you, including providing gaming services, processing payments, and managing your account;
• Legal Obligation: Processing is required to comply with Philippine laws and regulations, including PAGCOR licensing requirements, anti-money laundering laws, and tax obligations;
• Legitimate Interest: Processing is necessary for our legitimate business interests, such as fraud prevention, Platform security, and service improvement, provided these interests do not override your fundamental rights and freedoms.

2.2 Specific Purposes of Data Processing

We use your personal information for the following purposes:

• Account Management: Creating and maintaining your user account, authenticating your identity, managing your profile settings, and providing access to gaming services;
• Service Provision: Enabling gameplay, processing bets, calculating winnings, managing your account balance, and facilitating deposits and withdrawals;
• Payment Processing: Verifying payment methods, processing financial transactions, preventing payment fraud, and complying with anti-money laundering regulations;
• Regulatory Compliance: Fulfilling obligations under PAGCOR regulations, implementing Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures, age verification (21+), and reporting suspicious transactions to authorities;
• Security and Fraud Prevention: Detecting and preventing fraudulent activities, unauthorized access, account abuse, bonus exploitation, collusion, and other violations of our Terms and Conditions;
• Customer Support: Responding to your inquiries, resolving disputes, addressing technical issues, and providing assistance with account-related matters;
• Platform Improvement: Analyzing usage patterns, conducting performance testing, identifying bugs, optimizing user experience, and developing new features;
• Marketing and Promotions: Sending promotional offers, bonus announcements, tournament invitations, and personalized recommendations based on your preferences and gaming behavior (only with your consent);
• Responsible Gaming: Monitoring player behavior for signs of problem gambling, implementing deposit limits, enforcing self-exclusion requests, and providing access to responsible gaming resources;
• Legal Proceedings: Establishing, exercising, or defending legal claims, responding to court orders, cooperating with law enforcement investigations, and complying with regulatory inquiries.

3. Data Sharing and Disclosure

3.1 Third-Party Service Providers

We may share your personal information with trusted third-party service providers who assist us in operating the Platform and delivering our services. These providers are contractually obligated to protect your information and use it only for the specified purposes:

• Payment Processors: GCash, PayMaya, banks, and other financial institutions to process deposits, withdrawals, and payment verifications;
• Cloud Hosting Providers: Secure cloud infrastructure providers for data storage and Platform hosting;
• Identity Verification Services: KYC and anti-fraud service providers to verify your identity and prevent fraudulent account creation;
• Customer Support Platforms: Live chat software providers, helpdesk systems, and customer relationship management (CRM) tools;
• Marketing Service Providers: Email marketing platforms, SMS providers, and analytics tools to deliver promotional communications (only with your consent);
• Game Providers: Third-party game developers and live dealer studio operators who provide gaming content on our Platform;
• Analytics Services: Google Analytics and similar tools to analyze Platform usage and improve user experience.

3.2 Legal and Regulatory Disclosures

We may disclose your personal information when required by law or in response to legal obligations:

• To comply with PAGCOR reporting requirements and regulatory audits;
• To respond to lawful requests from law enforcement agencies investigating illegal activities;
• To comply with Anti-Money Laundering Council (AMLC) reporting obligations;
• To respond to court orders, subpoenas, or other legal processes;
• To report suspected criminal activity, money laundering, terrorist financing, or fraud;
• To protect our legal rights and property in legal proceedings;
• To enforce our Terms and Conditions and investigate violations;
• To comply with tax reporting obligations to the Bureau of Internal Revenue (BIR).

3.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity or acquiring party. You will be notified via email or prominent notice on our Platform before your information is transferred and becomes subject to a different privacy policy.

3.4 No Sale of Personal Information

gili58 does not sell, rent, or trade your personal information to third parties for their marketing purposes. We only share information as described in this Privacy Policy or with your explicit consent.

4. Data Security and Protection Measures

4.1 Technical Security Measures

We implement industry-standard security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data transmissions between your device and our servers are encrypted using SSL/TLS protocols. Sensitive data stored in our databases is encrypted at rest using AES-256 encryption;
• Access Controls: Strict role-based access controls limit employee access to personal information on a need-to-know basis. All access is logged and monitored;
• Firewall Protection: Multi-layered firewall systems protect our infrastructure from external threats and unauthorized access attempts;
• Intrusion Detection: Real-time monitoring systems detect and respond to suspicious activities, potential security breaches, and cyber attacks;
• Regular Security Audits: Independent security firms conduct periodic penetration testing, vulnerability assessments, and security audits;
• Secure Data Centers: Our servers are hosted in certified data centers with physical security measures including 24/7 surveillance, biometric access controls, and environmental monitoring;
• Backup and Disaster Recovery: Regular data backups and disaster recovery procedures ensure business continuity and data availability.

4.2 Organizational Security Measures

• All employees and contractors sign confidentiality agreements and undergo data privacy training;
• Background checks are conducted on personnel with access to sensitive systems;
• Incident response procedures are in place to address potential data breaches promptly;
• Regular security awareness training helps staff identify and prevent social engineering attacks;
• Data minimization principles ensure we collect only information necessary for specified purposes;
• Regular privacy impact assessments evaluate risks associated with new processing activities.

4.3 Your Security Responsibilities

While we implement robust security measures, you also play a crucial role in protecting your account:

• Create a strong, unique password and change it regularly;
• Never share your account credentials with anyone;
• Enable two-factor authentication when available;
• Log out after each session, especially on shared devices;
• Be cautious of phishing emails and suspicious links;
• Keep your contact information up to date to receive security alerts;
• Report any suspicious activity on your account immediately.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

5.1 Retention Periods

• Active Accounts: Personal information for active accounts is retained for the duration of your relationship with gili58 plus any additional period required by law;
• Closed Accounts: After account closure, we retain certain information for up to 10 years to comply with PAGCOR record-keeping requirements, anti-money laundering obligations, and potential legal claims;
• Transaction Records: Financial transaction records are retained for 10 years as required by Philippine tax and anti-money laundering laws;
• Identity Verification Documents: Copies of identification documents are retained for 5 years after account closure to comply with regulatory requirements;
• Marketing Communications: Consent records and marketing communication preferences are retained until you withdraw consent or 3 years after your last interaction with us;
• Technical Data: Server logs, IP addresses, and usage data are typically retained for 12-24 months unless longer retention is necessary for security or legal purposes;
• Customer Support Records: Communication records with customer support are retained for 5 years for quality assurance and dispute resolution purposes.

5.2 Data Deletion

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with our data disposal procedures. Anonymized data may be retained indefinitely for statistical analysis and business intelligence purposes.

6. Your Privacy Rights

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

6.1 Right to Access

You have the right to request access to the personal information we hold about you. We will provide you with a copy of your data in a commonly used electronic format within 30 days of your request.

6.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings or by contacting customer support.

6.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal information in certain circumstances, such as when the information is no longer necessary for the purposes for which it was collected. However, we may retain certain information when required by law or for legitimate business purposes such as fraud prevention.

6.4 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes at any time. You can opt out of marketing communications by clicking the unsubscribe link in emails or updating your communication preferences in your account settings.

6.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format and request transmission to another service provider where technically feasible.

6.6 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw consent at any time. However, withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.

6.7 Right to Lodge a Complaint

You have the right to lodge a complaint with the National Privacy Commission if you believe we have violated your data protection rights. Contact details: National Privacy Commission, 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City, Manila 1300, Philippines. Email: [email protected]. Website: https://www.privacy.gov.ph

6.8 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within 30 days and may request additional information to verify your identity before processing your request.

7. Cookies and Tracking Technologies

gili58 uses cookies and similar tracking technologies to enhance your experience on our Platform, analyze usage patterns, and deliver personalized content.

7.1 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly, including session management, authentication, and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences, language settings, and customization choices to enhance your user experience.
• Analytics Cookies: Collect anonymous usage data to help us understand how visitors interact with the Platform and identify areas for improvement.
• Marketing Cookies: Track your browsing behavior across websites to deliver personalized advertisements and measure campaign effectiveness (only with your consent).

7.2 Managing Cookie Preferences

You can control cookie settings through your browser preferences. However, disabling essential cookies may affect Platform functionality and your ability to access certain features. Most browsers allow you to refuse cookies, delete existing cookies, or receive notifications before cookies are stored.

8. International Data Transfers

While gili58 primarily operates within the Philippines and stores data on Philippine servers, some of our third-party service providers may process data outside the Philippines. When we transfer personal information internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by the National Privacy Commission;
• Ensuring the receiving country provides adequate data protection as determined by the NPC;
• Obtaining your explicit consent for international transfers where required by law.

9. Children's Privacy

gili58's services are intended exclusively for individuals who are at least 21 years of age, the legal gambling age in the Philippines. We do not knowingly collect personal information from individuals under 21 years of age. If we discover that we have inadvertently collected information from someone under 21, we will immediately delete such information and close the associated account. If you believe a minor has provided personal information to us, please contact [email protected] immediately.

10. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Material changes will be communicated via email to your registered email address and through prominent notice on our Platform at least 30 days before taking effect. Your continued use of gili58 services after changes become effective constitutes acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information.

11. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact:

• Data Protection Officer: [email protected]
• Customer Support: [email protected]
• Live Chat: Available 24/7 on the Platform
• Phone: +63 2 XXXX XXXX (24/7 hotline)
• Mailing Address: gili58 Data Privacy Office, [Address], Manila, Philippines