Privacy Policy –
How Fjili Keeps Your Data Safe

1Introduction

This Privacy Policy explains how fjili ("fjili," "we," "us," "our") collects, uses, stores, and protects personal information that you provide when you register, deposit, play, or otherwise interact with the fjili online gaming platform available at fjili.best.

Fjili is committed to protecting the privacy of every player on our platform. This isn't just a regulatory requirement for us — it's part of how we build and maintain the trust of the Filipino players who use fjili every day. We wrote this policy to be genuinely readable, not to be a document full of jargon that nobody wants to work through.

By creating an account on fjili or using the platform in any way, you acknowledge that you have read and understood this Privacy Policy and you consent to the collection and use of your personal information as described here. If you do not agree with how we handle your data, please do not create an account or use our services.

2Who We Are

Fjili operates as a licensed online gaming platform serving the Philippine market. As the operator of fjili.best, we act as the personal information controller for all data collected through the platform, meaning we determine the purposes and means by which your personal data is processed.

We have appointed a Data Protection Officer (DPO) responsible for overseeing our compliance with applicable data protection laws, including RA 10173. The DPO is the primary point of contact for any data-related queries, complaints, or requests from users.

Contact details for the fjili Data Protection Officer are provided in Section 15 of this policy. You can reach us at any time — we aim to acknowledge all data-related requests within two business days.

3Personal Data We Collect

Fjili collects personal information across several categories depending on how you interact with the platform. Here is a clear breakdown of what we collect and why each category is necessary:

4How We Collect Your Data

Fjili collects personal data through the following methods:

• Direct submission: Information you provide when you fill in the registration form, complete KYC verification, contact customer support, or update your account settings.
• Automated collection: Technical data collected automatically when you access fjili.best — including your IP address, browser type, device identifiers, and session activity logs. This happens whether or not you are logged in.
• Payment providers: Confirmation data received from GCash, Maya, and other payment processors when you make a deposit or withdrawal. Fjili does not store full payment credentials — only confirmation references and partial identifiers necessary for transaction matching.
• Identity verification partners: When we conduct KYC verification, our authorised identity verification service provider processes your submitted documents and returns a verification result to fjili. The documents themselves are not stored indefinitely on fjili's servers beyond what is required by law.
• Cookies and similar technologies: Session data collected through cookies placed on your device when you use fjili.best. See Section 8 for full details on cookie use.
• Third-party game providers: Game studios whose products appear on fjili may log gameplay sessions. Their data collection is governed by their own privacy policies, though fjili only integrates providers who meet minimum data protection standards.

5Why We Use Your Data

Every piece of personal data fjili collects is used for a specific, legitimate purpose. We do not collect data speculatively — if we collect it, there is a defined reason for it. Here are the primary purposes for which fjili processes your personal information:

• Providing the service: To create and manage your account, process your deposits and withdrawals, deliver games, apply bonuses, and generally operate the fjili platform as described in our Terms and Conditions.
• Identity verification and KYC: To verify that you are who you say you are and that you meet eligibility requirements — particularly age verification (21+) and confirmation that you are not subject to any self-exclusion order.
• Anti-money laundering (AML) compliance: Philippine law requires fjili to conduct due diligence on financial transactions. We process transaction data, identity data, and source-of-funds information to meet these obligations under the Anti-Money Laundering Act and its amendments.
• Fraud prevention and security: To detect and prevent unauthorised access, fraudulent transactions, bonus abuse, and other security threats. Technical data such as IP addresses and device fingerprints play a key role in this.
• Customer support: To respond to your queries, resolve disputes, and maintain a record of your interactions with the support team for quality assurance purposes.
• Responsible gaming: To operate tools like deposit limits, self-exclusion, and session reminders effectively. Responsible gaming data is used to protect players and to comply with regulatory requirements.
• Platform improvement: Aggregated and anonymised usage data helps fjili identify how the platform is being used, where problems occur, and where improvements can be made. This does not involve reviewing individual player behaviour for commercial profiling.
• Legal and regulatory compliance: To meet our obligations under Philippine gaming regulations, tax law, AML law, and data protection law. Some data may need to be retained for defined periods regardless of whether your account is active.
• Service communications: To send you account-related notifications such as deposit confirmations, withdrawal updates, security alerts, and changes to our terms. These communications are operational, not marketing.

6Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), fjili must have a lawful basis for processing your personal information. Depending on the type of processing, we rely on one or more of the following legal bases:

• Contractual necessity: Processing required to fulfil the contract between you and fjili — specifically, to provide the gaming service, process transactions, and manage your account.
• Legal obligation: Processing necessary for fjili to comply with applicable laws — including AML requirements, KYC obligations, gaming regulatory requirements, and data retention laws.
• Legitimate interests: Processing that serves fjili's legitimate interests in operating a secure, fair, and compliant platform — such as fraud detection, security monitoring, and platform analytics — provided those interests are not overridden by your rights.
• Consent: Processing for purposes where you have given us clear, specific consent — primarily marketing communications. You can withdraw consent at any time without affecting the lawfulness of prior processing.

If you have questions about the legal basis for any specific processing activity, you can contact our Data Protection Officer (see Section 15) for clarification.

7Data Sharing with Third Parties

Fjili does not sell, rent, or trade your personal data to third parties. Full stop. However, to operate the platform effectively and meet our legal obligations, we do share certain data with trusted service providers and regulatory authorities. Here is who we share data with and why:

• Payment processors: GCash, Maya, GrabPay, InstaPay, PESONet, BDO, BPI, UnionBank, Visa, and Mastercard receive the minimum data necessary to process your transactions — typically account references and transaction amounts.
• Identity verification providers: Accredited KYC service partners who process identity document data on fjili's behalf under strict data processing agreements. They are not permitted to use your data for any purpose other than verification for fjili.
• Game studios and content providers: Game session data may be shared with the studio whose game you are playing for game integrity and dispute resolution purposes. These providers operate under their own privacy policies and are required to meet minimum standards before integration on fjili.
• Regulatory and law enforcement authorities: Fjili is legally required to share relevant information with the Philippine Amusement and Gaming Corporation (PAGCOR) and other competent authorities, including the Anti-Money Laundering Council (AMLC), when required to do so by law or regulatory order.
• Professional advisors: Lawyers, auditors, and accountants acting in their professional capacity may access limited personal data as required for their engagement, bound by professional confidentiality obligations.
• Technology service providers: Cloud hosting, security monitoring, and customer support platform providers who process data on fjili's behalf under data processing agreements that restrict their use of your data.

8Cookies and Tracking Technologies

Fjili uses cookies and similar tracking technologies when you visit fjili.best. A cookie is a small text file stored on your device by your browser. Cookies help the platform remember your preferences, keep you logged in between sessions, and analyse how the site is being used.

The cookies used on fjili fall into the following categories:

• Strictly necessary cookies: Required for the platform to function at all — including session management (keeping you logged in), security tokens, and load balancing. These cannot be disabled without breaking the service.
• Functional cookies: Remember your preferences such as language, currency display settings, and game lobby layout. Disabling these means you may need to re-set preferences on each visit.
• Analytics cookies: Collect anonymised data about how visitors use fjili.best — pages visited, time spent, errors encountered. This data is used in aggregate to improve the platform and is not tied to individual user profiles.
• Security cookies: Help detect and prevent fraudulent activity by cross-referencing session data with known threat patterns. These are strictly necessary for platform security.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookie categories may affect platform functionality. Fjili does not use third-party advertising cookies or behavioural tracking cookies tied to advertising networks.

9Data Retention

Fjili retains personal data only for as long as it is necessary for the purpose for which it was collected, or as required by law. The following retention periods apply to the main categories of data we hold:

When data reaches the end of its retention period and there is no ongoing legal basis for continued storage, fjili securely deletes or anonymises it. Anonymised data that can no longer be linked back to an individual is not subject to these retention limits.

10Data Security

Fjili takes data security seriously. We apply industry-standard technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and fjili.best is encrypted using current TLS protocols. The padlock in your browser confirms this.
• Data encryption at rest: Sensitive personal and financial data stored on fjili's servers is encrypted using AES-256 encryption. This means that even in the event of a server breach, the raw data cannot be read without the encryption keys.
• Access controls: Personal data is accessible only to fjili employees and contractors who require it for their specific role. Access is governed by role-based permissions, and all access is logged.
• Two-factor authentication: Available to all fjili players for account login. Fjili staff with access to personal data systems are required to use multi-factor authentication.
• Regular security audits: Fjili's platform infrastructure undergoes periodic security testing, including penetration testing, to identify and address vulnerabilities before they can be exploited.
• Incident response: Fjili maintains a documented data breach response procedure. In the event of a breach affecting your data, we will notify affected users and the National Privacy Commission (NPC) within the timeframes required by RA 10173.

11Your Data Rights Under Philippine Law

Under the Data Privacy Act of 2012 (RA 10173), you have specific rights concerning your personal information held by fjili. These are genuine, enforceable rights — not just principles. Here's what you can exercise:

To exercise any of these rights, contact fjili's Data Protection Officer at support@fjili.best with a clear description of your request. Fjili will acknowledge your request within 2 business days and provide a substantive response within 30 days. In complex cases, we may require an extension of up to 60 days, and we will notify you of any extension.

We may ask you to verify your identity before processing a data rights request to ensure that personal information is not disclosed to the wrong person. This verification step is for your protection, not to create barriers to exercising your rights.

12Children and Minors

Fjili is strictly for adults aged 21 and above. The platform does not knowingly collect or process personal information from anyone under the age of 21. If you are under 21, you are not permitted to register or use fjili under any circumstances.

Fjili uses age verification procedures during registration and as part of ongoing KYC compliance to confirm that all active account holders meet the minimum age requirement. If fjili discovers that an account has been registered by a person under 21, the account will be immediately suspended, any remaining balance returned to the verified payment source, and the personal data processed will be deleted as promptly as legally permissible.

If you are a parent or guardian and believe that a minor may have accessed fjili, contact our support team immediately at support@fjili.best. We will investigate and take appropriate action as a matter of priority.

13Cross-Border Data Transfers

Some of fjili's service providers — including cloud infrastructure, game studios, and technology partners — may be located outside the Philippines. When personal data is transferred to a country outside the Philippines, fjili ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under RA 10173.

Safeguards for international data transfers include standard contractual clauses in data processing agreements, requiring recipient entities to process personal data only for specified purposes and to implement security measures equivalent to those required under Philippine law. Fjili does not transfer personal data to jurisdictions without adequate data protection frameworks unless contractual protections are in place.

If you would like details of the specific safeguards applied to international transfers involving your data, contact the fjili Data Protection Officer (see Section 15).

14Updates to This Privacy Policy

Fjili may update this Privacy Policy from time to time to reflect changes in our data practices, changes to the platform, or changes in applicable law. When we make material changes, we will notify active users via the email address registered to their fjili account at least 7 days before the changes take effect.

The version number and effective date at the top of this page confirm whether you are reading the most current version. We encourage you to review this policy periodically — it is always accessible at fjili.best/privacy-policy.

Continued use of the fjili platform after the effective date of a policy update constitutes your acceptance of the revised terms. If you do not agree with a material change, you may close your account before the effective date without penalty.

15Contact Our Data Protection Officer

For any questions, requests, or concerns relating to this Privacy Policy or the handling of your personal data, please contact fjili's Data Protection Officer. We are committed to responding promptly and transparently to all data-related enquiries.