SM JILI Privacy Policy

SM JILI Casino ("SM JILI," "we," "us," or "our") is committed to protecting the privacy and personal data of all users who access or use the SM JILI platform. We understand that Filipino players trust us with sensitive personal and financial information, and we take that responsibility seriously.

This Privacy Policy describes the types of personal data SM JILI collects, the purposes for which it is processed, the parties with whom it may be shared, the security measures we employ to protect it, and the rights available to you as a data subject under Philippine law.

By registering for an SM JILI account or otherwise using the SM JILI platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use the SM JILI platform.

This Privacy Policy should be read together with our Terms and Conditions and our Responsible Gaming Policy, all of which form part of your agreement with SM JILI.

For the purposes of the Data Privacy Act of the Philippines (RA 10173), SM JILI Casino is the personal information controller responsible for the personal data collected through the smjili.asia platform.

SM JILI has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. Contact details for the DPO are provided in Section 14 of this Policy.

SM JILI is registered with the National Privacy Commission (NPC) of the Philippines as required under RA 10173 and its Implementing Rules and Regulations.

SM JILI collects personal data from you in the following ways: directly from you when you register or use the platform, automatically through your use of the platform, and from third parties such as payment processors and identity verification providers.

Registration Data: When you create an SM JILI account, we collect:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Email address
• Mobile phone number
• Residential address (city, province, country)
• Username and encrypted password

KYC Verification Data: To comply with PAGCOR regulations and Philippine anti-money laundering laws, SM JILI collects:

• Government-issued photo identification (passport, driver's license, SSS/UMID card, PhilSys National ID, or equivalent)
• Proof of address (utility bill, bank statement, or equivalent)
• Selfie or live photo for identity matching purposes
• Source of funds declaration where required by law

Financial Data: When you make deposits or withdrawals, SM JILI collects:

• GCash or PayMaya account reference (not your full credentials)
• Bank account details (account name, bank name, account number) for bank transfer transactions
• Transaction history and amounts

Usage Data: SM JILI automatically collects the following data when you use the platform:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, games played, session duration, and click patterns
• Login timestamps and session activity logs

Communications Data: If you contact SM JILI support, we retain records of your communications, including live chat transcripts and email correspondence.

SM JILI processes your personal data only for the purposes described below. We do not use your data for any purpose that is incompatible with these stated purposes without your prior consent.

• Account Management: To create, maintain, and manage your SM JILI account, including verifying your identity and age, processing login requests, and managing account security.
• Service Delivery: To provide you with access to SM JILI games, process your deposits and withdrawals, and deliver the core gaming services you have requested.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160, as amended), the Data Privacy Act (RA 10173), and other applicable Philippine laws and regulations. This includes conducting KYC verification, filing suspicious transaction reports with the AMLC where required, and maintaining transaction records for the legally mandated retention period.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the SM JILI platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through SM JILI's 24/7 support channels.
• Responsible Gaming: To monitor gaming patterns and identify users who may be exhibiting signs of problem gambling, in order to provide appropriate responsible gaming interventions and comply with PAGCOR responsible gaming requirements.
• Platform Improvement: To analyze usage patterns and improve the SM JILI platform, user interface, and game offerings. This analysis is conducted on aggregated or anonymized data where possible.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may withdraw this consent at any time through your account settings or by contacting SM JILI support.

Under the Data Privacy Act of the Philippines, SM JILI processes your personal data on the following legal bases:

• Contractual Necessity: Processing necessary for the performance of the contract between you and SM JILI — including account creation, game access, and payment processing — is carried out on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with PAGCOR regulations, AML laws, tax laws, and other applicable Philippine legal obligations is carried out on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, platform security, and service improvement is carried out on the basis of SM JILI's legitimate interests, provided those interests are not overridden by your rights and interests.
• Consent: Processing for marketing communications and non-essential cookies is carried out on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

SM JILI does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, and Philippine banking partners receive the minimum personal and financial data necessary to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations.
• KYC and Identity Verification Providers: Third-party identity verification services receive your KYC documents and biometric data solely for the purpose of verifying your identity and age in compliance with PAGCOR requirements.
• Regulatory Authorities: SM JILI is required by law to share certain data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities upon lawful request or as required by applicable regulations.
• Technology and Infrastructure Providers: Cloud hosting, cybersecurity, and platform infrastructure providers may process your data on SM JILI's behalf as data processors, subject to binding data processing agreements that require them to protect your data in accordance with RA 10173.
• Professional Advisors: Legal, accounting, and auditing firms may access your data on a confidential basis where necessary for SM JILI's compliance and governance obligations.

SM JILI retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law, whichever is longer.

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AML laws.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, in compliance with the Anti-Money Laundering Act.
• Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, as required by Philippine financial regulations.
• Support Communications: Retained for two (2) years following the resolution of the relevant inquiry or dispute , unless a longer retention period is required for ongoing legal proceedings.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymized within 30 days.

Upon expiry of the applicable retention period, SM JILI will securely delete or anonymize your personal data in accordance with its data disposal procedures.

SM JILI implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the SM JILI platform is encrypted using TLS (Transport Layer Security). Sensitive data at rest — including passwords and financial information — is encrypted using AES-256 or equivalent standards.
• Access Controls: Access to personal data is restricted to SM JILI personnel and authorized third parties who have a legitimate need to access it. All access is logged and subject to regular review.
• Two-Factor Authentication: SM JILI offers two-factor authentication (2FA) for user accounts and requires it for all internal administrative access to systems containing personal data.
• Penetration Testing: SM JILI conducts regular security assessments and penetration tests to identify and remediate vulnerabilities in its systems.
• Incident Response: SM JILI maintains a data breach response plan. In the event of a personal data breach that poses a real risk of serious harm, SM JILI will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected users without undue delay, as required by RA 10173.

While SM JILI takes all reasonable steps to protect your personal data, no security system is completely impenetrable. You are responsible for maintaining the security of your SM JILI account credentials and for notifying SM JILI immediately if you suspect unauthorized access to your account.

SM JILI uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the SM JILI platform to function. They enable core features such as session management, login authentication, and security. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: These cookies remember your preferences — such as language settings and responsible gaming limits — to provide a more personalized experience. They are set only with your consent.
• Analytics Cookies: These cookies collect anonymized data about how users interact with the SM JILI platform, helping us identify areas for improvement. They are set only with your consent.
• Marketing Cookies: These cookies are used to deliver relevant promotional content to SM JILI users. They are set only with your explicit consent and may be withdrawn at any time.

You can manage your cookie preferences through the SM JILI cookie consent banner displayed on your first visit, or through your browser settings. Please note that disabling strictly necessary cookies may impair your ability to use the SM JILI platform.

Under the Data Privacy Act of the Philippines (RA 10173), you have the following rights with respect to your personal data held by SM JILI:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data SM JILI holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data SM JILI holds about you. You may update basic account information directly through your SM JILI account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to SM JILI's legal retention obligations under PAGCOR regulations and AML laws.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may exercise this right at any time through your account settings or by contacting SM JILI support.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: If you believe SM JILI has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact SM JILI's Data Protection Officer using the contact details provided in Section 14. SM JILI will respond to all data subject requests within 15 business days of receipt, as required by the NPC's guidelines.

SM JILI Casino is strictly intended for users who are 21 years of age or older. SM JILI does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the SM JILI registration and KYC process.

If SM JILI becomes aware that personal data has been collected from a person under 21 years of age, it will immediately close the relevant account, delete the associated personal data (subject to any legal retention obligations), and report the matter to the appropriate authorities if required.

If you are a parent or guardian and believe that your child has registered on SM JILI, please contact our support team immediately at the contact details provided in Section 14.

SM JILI primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure partners located outside the Philippines — for example, cloud hosting providers — SM JILI ensures that such transfers are carried out in compliance with Section 21 of the Data Privacy Act and the NPC's guidelines on cross-border data transfers.

Specifically, SM JILI ensures that any recipient of personal data outside the Philippines provides an adequate level of data protection, either through the NPC's whitelist of countries with adequate protection, through binding contractual clauses approved by the NPC, or through other lawful transfer mechanisms.

SM JILI reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, SM JILI will notify registered users via email or through a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of SM JILI following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy. We encourage you to review this Policy periodically.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact SM JILI's Data Protection Officer:

If you are not satisfied with SM JILI's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act.