Privacy Policy

1. Information We Collect

To provide you with gaming services, process transactions, verify your identity, and comply with regulatory requirements under our PAGCOR license, 2djili collects various categories of personal information. The types of information we collect depend on how you interact with our Platform and the services you use.

1.1 Information You Provide Directly

When you register for a 2djili account, make deposits or withdrawals, contact customer support, or otherwise interact with our services, you provide us with personal information including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (such as passport number, driver's license number, or Unified Multi-Purpose ID number) required for age verification and identity confirmation in compliance with Philippine gaming regulations.
• Contact Information: Email address, mobile phone number, residential address, city, province, and postal code used for account communications, security verification, and regulatory compliance.
• Financial Information: Payment method details including GCash account information, Maya wallet details, bank account numbers (BPI, BDO, Metrobank, or other Philippine banks), and transaction history necessary for processing deposits and withdrawals.
• Account Credentials: Username, password (stored in encrypted form), and security questions used to protect your account access.
• Verification Documents: Copies of government-issued identification, proof of address documents, and selfie photographs submitted during account verification processes required by anti-money laundering regulations and PAGCOR licensing requirements.
• Communication Records: Contents of messages sent through our customer support channels including live chat transcripts, email correspondence, and feedback forms.

1.2 Information Collected Automatically

When you access 2djili through our website or mobile platform, certain information is collected automatically through technical means:

• Device Information: Type of device (smartphone, tablet, desktop computer), operating system (Android, iOS, Windows, macOS), browser type and version, device identifiers, and screen resolution.
• Usage Information: Pages visited, games played, bet amounts and outcomes, session duration, click patterns, and features used on the Platform.
• Location Information: IP address, approximate geographic location derived from IP address, and precise location data if you grant location permission on mobile devices (used to verify you are accessing the Platform from within the Philippines as required by our license).
• Technical Data: Log files, error reports, browser cookies, session identifiers, and similar tracking technologies that enable Platform functionality and security monitoring.
• Transaction Metadata: Timestamps, transaction amounts, payment method used, and transaction status for all financial activities on your account.

1.3 Information from Third Parties

In certain circumstances, we receive information about you from third-party sources to verify your identity, process payments, or comply with legal obligations:

• Payment Processors: GCash, Maya, and banking institutions provide transaction confirmations, account verification status, and fraud prevention data.
• Identity Verification Services: Third-party identity verification providers may supply information confirming the authenticity of identification documents you submit.
• Regulatory Authorities: PAGCOR or other government agencies may provide information relevant to regulatory compliance, licensing verification, or enforcement actions.
• Fraud Prevention Services: Third-party fraud detection services may provide risk assessments, device fingerprinting data, or alerts about suspicious activity patterns.

2. How We Use Your Information

2djili uses the personal information we collect for legitimate business purposes related to operating a licensed online gaming platform in the Philippines. The primary purposes for which we process your information include:

2.1 Service Provision and Account Management

• Creating and maintaining your player account with unique login credentials and personalized settings.
• Processing deposits to your gaming account through GCash, Maya, bank transfers, and other payment methods.
• Processing withdrawal requests and transferring winnings to your designated payment accounts.
• Providing access to casino games, live dealer tables, sports betting markets, and other gaming services offered on the Platform.
• Recording game outcomes, calculating winnings, updating account balances, and maintaining accurate transaction records.
• Enabling communication between you and our customer support team to resolve issues, answer questions, and provide assistance.

2.2 Legal and Regulatory Compliance

• Verifying that you are at least 21 years of age as required by Philippine gaming regulations for participation in online casino and sports betting activities.
• Confirming your identity to prevent account fraud, identity theft, and unauthorized account access.
• Conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures mandated by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160) as amended.
• Detecting and preventing money laundering, terrorist financing, fraud, collusion, and other illegal activities on the Platform.
• Complying with reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other regulatory authorities.
• Maintaining records required by law for specified retention periods and producing records in response to valid legal requests from law enforcement or regulatory agencies.
• Enforcing responsible gaming requirements including self-exclusion programs, deposit limits, and session time restrictions.

2.3 Security and Fraud Prevention

• Monitoring account activity for unusual patterns that may indicate unauthorized access, account compromise, or fraudulent transactions.
• Detecting and preventing bonus abuse, multi-accounting, collusion between players, and other violations of our Terms and Conditions.
• Protecting the Platform from cyberattacks, distributed denial-of-service (DDoS) attacks, hacking attempts, and malicious software.
• Implementing security measures including encryption, firewalls, intrusion detection systems, and access controls to safeguard your personal information.
• Investigating suspected violations of our Terms and Conditions and taking appropriate enforcement actions including account suspension or closure.

2.4 Service Improvement and Personalization

• Analyzing usage patterns to understand how players interact with our Platform and identify opportunities for improvement.
• Personalizing game recommendations, promotional offers, and content based on your gaming preferences and activity history (only with your consent where required).
• Testing new features, games, and Platform enhancements to improve user experience.
• Optimizing Platform performance, reducing loading times, and ensuring compatibility with various devices and browsers.
• Responding to feedback and implementing changes based on player suggestions and complaints.

2.5 Marketing and Communications

• Sending account-related notifications including deposit confirmations, withdrawal processing updates, password reset instructions, and security alerts (these communications are necessary for service provision and you cannot opt out).
• Providing promotional communications about bonuses, tournaments, new games, and special offers via email or SMS if you have consented to receive marketing materials (you may opt out at any time).
• Conducting player surveys to gather feedback about our services and understand player satisfaction levels.
• Sending updates about changes to our Terms and Conditions, Privacy Policy, or other important Platform policies.

3. How We Share Your Information

2djili does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we do share your information with selected third parties in specific circumstances necessary for operating our licensed gaming platform:

3.1 Service Providers and Business Partners

We engage trusted third-party companies to perform functions on our behalf, and these companies may have access to your personal information as necessary to perform their services:

• Payment Processors: GCash, Maya, and banking institutions that facilitate deposits and withdrawals receive your financial information and transaction details necessary to process payments.
• Identity Verification Providers: Specialized companies that verify the authenticity of identification documents and perform anti-fraud checks receive your identity information and supporting documents.
• Game Providers: Software companies that supply casino games, live dealer services, and sports betting platforms may receive pseudonymized data about game play and outcomes for technical operation purposes.
• Customer Support Tools: Third-party platforms that power our live chat, ticketing system, and customer relationship management receive communication records and account information necessary to provide support.
• Cloud Hosting Services: Infrastructure providers that host our Platform and databases receive all information stored on our systems but are contractually prohibited from accessing or using the data for any purpose other than providing hosting services.
• Analytics and Performance Monitoring: Tools that help us understand Platform usage, identify technical issues, and improve performance may receive anonymized or aggregated data about user behavior.

All third-party service providers are carefully selected, contractually bound to maintain confidentiality, and required to implement appropriate security measures to protect your personal information. They are prohibited from using your information for purposes other than providing services to 2djili.

3.2 Regulatory Authorities and Law Enforcement

We disclose personal information to government authorities when legally required or when necessary to comply with our regulatory obligations:

• PAGCOR: As our licensing authority, PAGCOR may require access to player information, transaction records, and operational data to ensure compliance with gaming regulations.
• Anti-Money Laundering Council (AMLC): We submit Suspicious Transaction Reports (STRs) and Covered Transaction Reports (CTRs) as required by Philippine anti-money laundering laws.
• Law Enforcement Agencies: We cooperate with valid legal requests from police, prosecutors, courts, and other law enforcement authorities investigating criminal activity.
• Tax Authorities: We report certain transactions and player winnings as required by Philippine tax laws and regulations.
• National Privacy Commission: We provide information as necessary to demonstrate compliance with the Data Privacy Act of 2012 and respond to privacy complaints.

3.3 Legal Proceedings and Rights Protection

We may disclose personal information when we believe in good faith that disclosure is necessary to:

• Comply with a legal obligation, court order, subpoena, or other legal process.
• Enforce our Terms and Conditions, investigate potential violations, and take action against players who violate our rules.
• Protect the rights, property, or safety of 2djili, our employees, other players, or the public.
• Detect, prevent, or address fraud, security issues, or technical problems.
• Defend against legal claims or litigation brought against 2djili.

3.4 Business Transfers

In the event that 2djili is involved in a merger, acquisition, asset sale, bankruptcy, or similar business transaction, your personal information may be transferred to the acquiring entity or included in transferred assets. We will notify affected users of any such change in ownership or control of personal information and provide options for how your information will be handled under the new ownership.

4. Data Security and Protection

Protecting your personal information is a top priority at 2djili. We implement comprehensive technical, administrative, and physical security measures designed to safeguard your data against unauthorized access, disclosure, alteration, or destruction:

4.1 Technical Security Measures

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption, the same level of security used by major financial institutions worldwide.
• Secure Storage: Personal information stored in our databases is encrypted at rest using industry-standard encryption algorithms.
• Firewalls and Intrusion Detection: Our network infrastructure includes multiple layers of firewalls and intrusion detection systems that monitor for and block unauthorized access attempts.
• Regular Security Audits: We conduct periodic security assessments, penetration testing, and vulnerability scans to identify and address potential security weaknesses.
• Secure Payment Processing: All payment transactions are processed through PCI-DSS compliant systems that meet international standards for payment card security.

4.2 Administrative Security Measures

• Access Controls: Access to personal information is restricted to employees who require access to perform their job functions, and all access is logged and monitored.
• Employee Training: All employees receive mandatory training on data protection, privacy requirements, and security best practices.
• Confidentiality Agreements: Employees and contractors with access to personal information sign confidentiality agreements and are subject to disciplinary action for violations.
• Incident Response Plan: We maintain a documented data breach response plan that outlines procedures for detecting, responding to, and recovering from security incidents.
• Third-Party Contracts: All service providers that process personal information on our behalf are required to implement equivalent security measures and are audited for compliance.

4.3 Physical Security Measures

• Data centers and server facilities that store personal information are protected by physical security controls including access badges, security cameras, and 24/7 monitoring.
• Backup systems are maintained in secure locations separate from primary data centers to ensure business continuity and data recovery capabilities.
• Physical documents containing personal information are stored in locked facilities with restricted access and are securely destroyed when no longer needed.

5. Data Retention

2djili retains personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal and regulatory retention requirements:

5.1 Active Account Data

While your account remains active, we retain all personal information, transaction history, game play records, and communications necessary to provide ongoing services, comply with regulatory requirements, and resolve disputes or technical issues that may arise.

5.2 Closed Account Data

If you request account closure, we retain certain information for specified periods as required by law:

• Regulatory Records: Identity verification documents, transaction records, and game play history are retained for a minimum of five years after account closure as required by PAGCOR regulations and anti-money laundering laws.
• Financial Records: All deposit and withdrawal transactions are retained for seven years in accordance with Philippine tax and accounting regulations.
• Dispute Resolution Records: Information relevant to unresolved disputes, complaints, or pending investigations is retained until the matter is fully resolved and any applicable appeal periods have expired.
• Legal Hold Data: Information subject to litigation, government investigations, or court orders is retained until the legal matter is concluded and retention is no longer required.

5.3 Data Deletion

Once retention periods have expired and there is no continuing legal basis for retaining your information, we securely delete or anonymize personal data so that it can no longer identify you. Anonymized data that cannot be linked back to you may be retained indefinitely for statistical analysis and research purposes.

6. Your Privacy Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have specific rights regarding your personal information held by 2djili:

6.1 Right to Access

You have the right to request confirmation of whether we are processing your personal information and to obtain a copy of that information. We will provide this information in an accessible format within a reasonable timeframe.

6.2 Right to Correction

If you believe any personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request correction. You can update most information directly through your account settings, or contact customer support for assistance.

6.3 Right to Erasure

You may 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, this right is subject to exceptions where we are legally required to retain information for regulatory compliance, fraud prevention, or dispute resolution.

6.4 Right to Object

You have the right to object to certain types of data processing, particularly processing for marketing purposes. You can opt out of marketing communications at any time by clicking the unsubscribe link in emails or adjusting your notification preferences in account settings.

6.5 Right to Data Portability

You have the right to receive personal information you have provided to us in a structured, commonly used, and machine-readable format, and to request that we transmit this information to another service provider where technically feasible.

6.6 Right to Withdraw Consent

Where we process your personal information based on consent, you have the right to withdraw that consent at any time. However, withdrawal of consent does not affect the lawfulness of processing conducted before withdrawal and does not affect processing based on other legal grounds.

6.7 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer through the contact information provided at the end of this Privacy Policy. We will respond to your request within the timeframe required by law, typically within 15 to 30 days depending on the complexity of the request. We may need to verify your identity before processing certain requests to protect your information from unauthorized access.

7. Cookies and Tracking Technologies

2djili uses cookies and similar tracking technologies to enhance Platform functionality, analyze usage patterns, and improve user experience. Cookies are small text files stored on your device that allow us to recognize you on return visits and remember your preferences.

7.1 Types of Cookies We Use

• Essential Cookies: These cookies are necessary for the Platform to function properly and cannot be disabled. They enable core functionality such as account login, session management, and security features.
• Performance Cookies: These cookies collect information about how you use the Platform, such as which pages you visit most often and if you receive error messages. This information is used to improve Platform performance.
• Functionality Cookies: These cookies remember your preferences and settings (such as language preference, timezone, or favorite games) to provide a personalized experience.
• Analytics Cookies: These cookies help us understand user behavior, measure traffic, and identify areas for improvement through tools like Google Analytics.

7.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. However, disabling cookies may prevent you from accessing certain features of the Platform or using some services. You can control cookie preferences through your browser settings or through cookie management tools provided on our website where applicable.

8. Third-Party Links and Services

The 2djili Platform may contain links to third-party websites, payment processors, or services operated by companies other than 2djili. This Privacy Policy applies only to information collected by 2djili and does not cover the privacy practices of third parties. We are not responsible for the privacy policies, content, or practices of external websites or services. We encourage you to review the privacy policies of any third-party sites you visit.

9. International Data Transfers

While 2djili primarily serves Filipino players and stores data within the Philippines or through Philippine data centers where possible, certain service providers we use may process data outside the Philippines. When personal information is transferred internationally, we ensure that appropriate safeguards are in place, such as standard contractual clauses approved by the National Privacy Commission or other legally recognized transfer mechanisms that provide adequate protection for your information.

10. Children's Privacy

2djili's services are intended exclusively for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from someone under the legal age, we will take immediate steps to delete that information and close the account. Parents or guardians who believe their child has provided personal information to 2djili should contact us immediately.

11. Changes to This Privacy Policy

2djili reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, regulatory requirements, or applicable laws. When we make material changes to this policy, we will notify you through prominent notice on the Platform, via email to your registered email address, or through other appropriate channels. The "Last Updated" date at the top of this policy indicates when the most recent revisions were made. Your continued use of 2djili services after changes become effective constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

12. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data protection practices, or if you wish to exercise your privacy rights, please contact our Data Protection Officer:

For complaints about our handling of personal information that are not resolved through direct contact with 2djili, you have the right to file a complaint with the National Privacy Commission of the Philippines.