jiino1 Privacy Policy – How We Collect, Use, and Protect Your Personal Data

1. Introduction

This Privacy Policy (hereinafter "Policy") describes how jiino1 (hereinafter "jiino1," "we," "us," or "the Platform") collects, processes, uses, stores, and discloses personal data belonging to individuals (hereinafter "Player," "User," or "you") who access or use the online gaming services available at jiino1.cam and any associated mobile-optimized interfaces.

jiino1 takes the privacy of its Filipino players seriously. We operate in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines, its Implementing Rules and Regulations (IRR), and any relevant issuances of the National Privacy Commission (NPC). Where applicable, we also observe internationally recognized data protection standards consistent with those frameworks.

By registering an account on jiino1 and using any of our services, you acknowledge that you have read and understood this Policy in its entirety. This Policy forms part of our broader legal framework, which includes our Terms & Conditions and Responsible Gaming Policy.

2. Data Controller Identity

For the purposes of the Data Privacy Act of 2012 and its IRR, jiino1 acts as the Personal Information Controller (PIC) in respect of all personal data processed in connection with the operation of jiino1.cam and the delivery of online gaming, sports betting, and related services to players in the Philippines.

All data protection inquiries, requests, and complaints may be directed to jiino1's designated Data Protection Officer (DPO) using the contact details set out in Section 13 of this Policy. jiino1 is committed to responding to all DPO communications within the timeframes prescribed by the NPC.

3. Personal Data We Collect

jiino1 collects personal data from players through various channels and at different stages of the player lifecycle. The categories of personal data we process are set out in the table below.

3.1 Sensitive Personal Information

Certain categories of data processed by jiino1 may qualify as sensitive personal information under the Data Privacy Act of 2012, including but not limited to biometric data collected for identity verification purposes. jiino1 applies heightened protection standards to all sensitive personal information and processes such data only to the extent strictly necessary for the lawful purposes described in this Policy.

4. Purpose of Processing & Legal Basis

jiino1 processes personal data only for specific, legitimate purposes. The primary purposes for which we process your personal data, together with the applicable legal basis under the Data Privacy Act of 2012, are as follows:

• Account Registration and Management: To create, maintain, and administer your jiino1 player account, verify your identity, and enable access to the Platform's services. Legal basis: performance of a contract.
• Age Verification and Eligibility Screening: To confirm that all players accessing real-money gaming services are at least twenty-one (21) years of age, in compliance with applicable Philippine gaming regulations. Legal basis: compliance with a legal obligation.
• Payment Processing: To facilitate deposits via GCash, Maya, BPI, BDO, and other approved payment channels, and to process withdrawal requests in Philippine Peso (₱). Legal basis: performance of a contract.
• Anti-Money Laundering (AML) Compliance: To conduct Know Your Customer (KYC) checks, monitor transactions for suspicious activity, and report to relevant Philippine authorities where required. Legal basis: compliance with a legal obligation.
• Responsible Gaming Compliance: To administer self-exclusion arrangements, enforce deposit and loss limits, monitor gaming behavior patterns for indicators of problem gambling, and provide appropriate interventions. Legal basis: compliance with a legal obligation and legitimate interest.
• Platform Security and Fraud Prevention: To detect, investigate, and prevent unauthorized account access, bonus abuse, collusion, and other fraudulent or prohibited conduct. Legal basis: legitimate interest.
• Customer Support: To respond to player queries, resolve disputes, process complaints, and maintain records of communications for quality assurance and audit purposes. Legal basis: performance of a contract.
• Service Improvement and Analytics: To analyze aggregated usage patterns, optimize platform performance, and develop new features that serve the needs of Filipino players. Legal basis: legitimate interest (only anonymized or aggregated data is used for this purpose).
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to marketing communications. Legal basis: consent. You may withdraw consent at any time through your account settings.

5. Data Sharing & Disclosure

jiino1 does not sell, rent, or trade your personal data to third parties for their own marketing purposes under any circumstances. We may share your personal data with third parties only in the following limited and controlled circumstances:

5.1 Service Providers and Processors

jiino1 engages third-party service providers who process personal data on our behalf as Personal Information Processors (PIPs) under the Data Privacy Act. These include payment gateway operators (GCash/Maya infrastructure, BancNet, InstaPay), KYC and identity verification technology providers, cloud hosting and data storage providers, game software providers, and customer support platform operators. All processors are contractually bound to process personal data only in accordance with jiino1's documented instructions and applicable Philippine data protection law.

5.2 Regulatory and Law Enforcement Disclosure

jiino1 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Philippine National Police, or other competent Philippine government authorities where required to do so by law, court order, or binding regulatory direction. In all such cases, jiino1 will disclose only the minimum personal data necessary to satisfy the legal requirement.

5.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of jiino1's assets, your personal data may be transferred to the relevant successor entity. jiino1 will notify affected players of any such transfer and the resulting changes to data processing arrangements prior to the transfer taking effect.

6. Data Retention

jiino1 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law, whichever is longer. The following general retention periods apply:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements under the Anti-Money Laundering Act of 2001 (AMLA) as amended.
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of submission, or longer where required by PAGCOR or AMLC regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Retained for three (3) years from the date of the last interaction, unless the matter is subject to an ongoing dispute or legal proceedings, in which case records are retained until final resolution.
• Marketing consent records: Retained for the duration of the marketing relationship plus two (2) years following withdrawal of consent.

Upon expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymized in accordance with jiino1's data destruction procedures.

7. Security Measures

jiino1 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jiino1's servers.
• Encryption of sensitive personal data at rest using industry-standard cryptographic algorithms.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for all administrative system access.
• Regular third-party penetration testing and security vulnerability assessments.
• Intrusion detection and prevention systems monitoring the Platform infrastructure around the clock.
• Documented data breach response procedures compliant with the NPC's mandatory breach notification requirements under NPC Circular 16-03.

In the event of a personal data breach that is likely to give rise to a real risk of serious harm to affected players, jiino1 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will communicate with affected players without undue delay thereafter.

8. Cookies & Tracking Technologies

jiino1 uses cookies and similar tracking technologies on jiino1.cam to ensure the Platform functions correctly, to analyze usage patterns, and to provide a personalized player experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for Platform operation. These enable core functions such as secure login session management, account authentication, and fraud detection. These cookies cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: Used to collect aggregated, anonymized data about how players navigate and use the Platform. This information helps jiino1 improve user experience and identify technical issues. No individually identifiable data is retained through these cookies.
• Functional Cookies: Enable the Platform to remember your preferences and settings, such as your preferred language, display settings, and responsible gaming configurations.
• Session Security Cookies: Used to detect and prevent unauthorized access attempts, including brute-force login attacks and session hijacking.

You may configure your browser to block or delete cookies; however, doing so may affect your ability to use certain features of jiino1. For mobile users accessing jiino1 through a mobile browser on Android or iOS devices in the Philippines, your device's browser privacy settings govern cookie behavior.

9. Your Data Subject Rights

As a data subject under the Data Privacy Act of 2012 of the Philippines, you are entitled to exercise the following rights in relation to your personal data processed by jiino1. All rights requests may be submitted to jiino1's Data Protection Officer using the contact details in Section 13.

jiino1 will respond to all verifiable data subject rights requests within fifteen (15) working days of receipt, in accordance with NPC guidelines. Where a request is complex or involves a large volume of data, we may extend this period by up to thirty (30) additional days, with prior notification to you.

10. Protection of Minors

jiino1 does not knowingly collect personal data from individuals under the age of twenty-one (21) years. The Platform is strictly intended for adults aged 21 and above in accordance with Philippine gaming regulations. During account registration, jiino1 requires players to declare their date of birth and consent to age verification. Where jiino1 discovers or has reasonable grounds to believe that personal data has been collected from an individual under the age of 21, the relevant account will be immediately suspended, the personal data will be isolated and securely deleted or returned, and any deposits will be refunded to the payment method of origin.

11. Cross-Border Data Transfers

Certain personal data processed by jiino1 may be transferred to, stored on, or processed by servers or service providers located outside the Philippines where necessary for the delivery of the Platform's services — for example, in connection with cloud infrastructure providers or game software suppliers operating from other jurisdictions.

Wherever personal data is transferred outside the Philippines, jiino1 ensures that such transfers are subject to adequate safeguards consistent with the requirements of the Data Privacy Act of 2012 and the NPC's rules on cross-border data flows. These safeguards include binding contractual clauses with receiving parties, ensuring that recipient jurisdictions provide an adequate level of data protection, or obtaining your explicit consent where required.

12. Policy Amendments

jiino1 reserves the right to update or revise this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance from the National Privacy Commission, or material changes in our data processing practices. Where revisions are material, jiino1 will provide at least seven (7) days' advance notice by posting a prominent notification on the Platform and, where practicable, by notifying registered players through their registered Philippine mobile number.

Your continued use of jiino1 following the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated Policy. The current version of this Policy, together with the effective date, is always accessible on this page. We recommend reviewing this Policy periodically to remain informed of how jiino1 protects your personal data.

13. Contact & Complaints

For all privacy-related inquiries, data subject rights requests, or complaints regarding jiino1's handling of your personal data, please contact our Data Protection Officer. jiino1 is committed to acknowledging all DPO communications promptly and to resolving privacy concerns in good faith.

If you are not satisfied with jiino1's response to your privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). The NPC's contact details and complaint submission procedures are publicly available on the NPC's official website.