Your Privacy Matters to 16jili

Effective Date: 1 January 2026 · Last Updated: 15 May 2026

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 16jili ("16jili," "we," "us," or "our") collects, uses, stores, and protects the personal information of users ("you," "your," or "Player") who access or use the 16jili online gaming platform at https://16jili.app (the "Platform").

This Policy applies to all personal data collected through the Platform, including data provided during account registration, identity verification, deposits and withdrawals, customer support interactions, and general use of the Platform. It applies to all players based in the Philippines and is intended to comply with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

By registering an account on the 16jili Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

2. Data Controller Information

16jili is the data controller responsible for your personal information collected through the Platform. As data controller, 16jili determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data privacy laws.

Our designated Data Protection Officer ("DPO") can be contacted at: [email protected] — please mark your message "Data Privacy / DPO" so it is routed to the correct team.

3. Personal Data We Collect

16jili collects the following categories of personal data from players:

3.1 Registration and Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you are 21 years of age or older)
• Mobile number registered in the Philippines
• Email address
• Username and encrypted password
• Residential address in the Philippines

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., PhilSys National ID, UMID, LTO driver's license, Philippine passport, COMELEC Voter's ID)
• Proof of address documents where required
• Selfie or liveness verification images where required for enhanced KYC

3.3 Financial and Transaction Data

• GCash or PayMaya mobile wallet number
• Philippine bank account details (bank name, account number) for withdrawal processing
• Deposit and withdrawal transaction history
• Account balance and gaming transaction records

3.4 Gaming Activity Data

• Game history, bet amounts, and outcomes
• Bonus and promotion usage records
• Session duration and login timestamps
• Responsible gaming tool usage (deposit limits, self-exclusion requests)

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform usage logs and error reports

3.6 Communications Data

• Records of live chat, email, and support ticket interactions
• Feedback and survey responses
• Marketing communication preferences

4. How We Collect Your Data

16jili collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey.
• Automatically — through cookies, web beacons, and server logs when you access and use the Platform.
• From third parties — from identity verification service providers, payment processors (GCash, PayMaya, Philippine banks), and fraud prevention services, where necessary to verify your identity or process transactions.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 16jili processes your personal data on the following legal bases:

Processing Purpose	Legal Basis
Account registration and management	Performance of contract
Identity verification (KYC)	Legal obligation / Compliance with gaming regulations
Processing deposits and withdrawals	Performance of contract
Fraud prevention and security	Legitimate interests / Legal obligation
Responsible gaming monitoring	Legal obligation / Legitimate interests
Customer support	Performance of contract / Legitimate interests
Marketing communications	Consent (you may withdraw at any time)
Platform analytics and improvement	Legitimate interests

6. How We Use Your Data

16jili uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your 16jili player account, including processing your login and managing your account settings.
• Identity verification: To verify that you are who you say you are, that you are at least 21 years of age, and that you are eligible to use the Platform under applicable Philippine regulations.
• Payment processing: To process deposits via GCash, PayMaya, and debit cards, and to process withdrawals to your verified Philippine bank account or e-wallet.
• Gaming services: To provide access to games, record your gaming activity, calculate and credit winnings, and administer bonuses and promotions.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, underage gambling, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling behaviour, to administer self-exclusion and deposit limit requests, and to comply with responsible gaming obligations.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Legal compliance: To comply with applicable Philippine laws and regulations, including gaming regulations, anti-money laundering requirements, and data privacy laws.
• Marketing: To send you promotional offers, bonus notifications, and platform updates — but only where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyse usage patterns, identify technical issues, and improve the features and performance of the Platform.

7. Sharing Your Data

16jili does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment service providers: GCash, PayMaya, and Philippine banks, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and identity verification services used to verify your identity and age.
• Fraud prevention and security providers: Third-party services used to detect and prevent fraudulent activity, money laundering, and other prohibited conduct.
• Gaming software providers: Game developers and platform technology providers who supply the games and software infrastructure for the Platform, who may receive anonymised or pseudonymised gaming activity data.
• Regulatory authorities: The Philippine Amusement and Gaming Corporation (PAGCOR), the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where required by law or regulation.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by 16jili, subject to strict confidentiality obligations.
• Law enforcement: Philippine law enforcement agencies, where required by a valid court order, subpoena, or other lawful process.

All third parties with whom 16jili shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and are prohibited from using your data for any purpose other than the specific purpose for which it was shared.

8. Cookies and Tracking Technologies

16jili uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and analyse Platform usage. The following types of cookies are used:

Cookie Type	Purpose	Duration
Strictly Necessary	Required for the Platform to function — session management, login authentication, security tokens	Session
Functional	Remembers your preferences such as language, display settings, and responsible gaming limits	Up to 12 months
Analytics	Collects anonymised data about how players use the Platform to help us improve features and performance	Up to 24 months
Marketing	Used to deliver relevant promotional content and measure the effectiveness of campaigns — only with your consent	Up to 12 months

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may affect the functionality of the Platform. Withdrawing consent for marketing cookies will not affect your ability to use the Platform.

9. Data Retention

16jili retains your personal data for as long as your account is active and for such additional periods as are required by applicable Philippine law and regulation. The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• Financial and transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended).
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the activity.
• Customer support records: Retained for a minimum of two (2) years from the date of the interaction.
• Marketing consent records: Retained for as long as you remain subscribed and for one (1) year following unsubscription, as evidence of consent.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 16jili's data disposal procedures.

10. Data Security

16jili implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including financial information and KYC documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication for administrative access to systems containing personal data;
• Regular penetration testing and vulnerability assessments conducted by independent security specialists;
• Intrusion detection and prevention systems monitoring for suspicious activity;
• Regular staff training on data privacy and information security obligations;
• A documented incident response plan for managing data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 16jili will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the requirements of the Philippine DPA and NPC Circular No. 16-03.

11. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 16jili:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, which is the purpose of this Policy.
• Right of access: You have the right to request a copy of the personal data that 16jili 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 that 16jili holds about you.
• 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 16jili's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to 16jili's overriding legitimate grounds.
• 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 withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 16jili has processed your personal data in violation of the Philippine DPA.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." We will respond to your request within thirty (30) days of receipt, in accordance with NPC guidelines. We may need to verify your identity before processing your request.

12. Children's Privacy

The 16jili Platform is strictly intended for persons who are at least twenty-one (21) years of age. We do not knowingly collect personal data from persons under the age of 21. If you are under 21, you must not use the Platform or provide any personal data to us.

If 16jili becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that your child has provided personal data to 16jili, please contact us immediately at [email protected].

13. Changes to This Policy

16jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email and by posting a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Your continued use of the Platform following notification of any amendment constitutes your acceptance of the revised Policy.

14. Contact and Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or about how 16jili processes your personal data, please contact us:

• Data Protection Officer: [email protected] (subject: "Data Privacy / DPO")
• General Support: [email protected]
• Live Chat: Available 24/7 via the Platform

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about how to file a complaint with the NPC is available on the NPC's official website.