smjili Privacy Policy

01 Introduction

smjili ("we," "us," or "our") operates the online casino and sports betting platform accessible at smjili.app (the "Platform"). We are committed to protecting the privacy and security of your personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and other applicable data protection laws.

This Privacy Policy describes how we collect, use, store, share, and protect your personal data when you access or use the smjili Platform. By creating an account or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein.

02 Information We Collect

smjili collects various types of personal information to provide, maintain, and improve our services. The categories of information we collect include:

2.1 Information You Provide Directly

• Account Registration Data: Full legal name, date of birth, gender, residential address, email address, mobile phone number, and username.
• Identity Verification Data: Government-issued identification documents (e.g., Philippine passport, driver's license, UMID, SSS ID), proof of address documents (utility bills, bank statements), and selfie photographs for identity verification purposes.
• Financial Information: Payment method details including GCash account information, PayMaya account information, bank account numbers, and transaction history related to deposits and withdrawals.
• Communication Data: Records of your communications with our customer support team via live chat, email, or phone, including the content of messages and support tickets.

2.2 Information Collected Automatically

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, betting history, session duration, click patterns, referral sources, and other behavioral data related to your use of the Platform.
• Location Data: Approximate geographic location derived from your IP address to ensure compliance with jurisdictional restrictions and to provide localized services.
• Cookies and Similar Technologies: Data collected through cookies, web beacons, and similar tracking technologies as described in Section 9 of this Privacy Policy.

2.3 Information from Third Parties

• Payment processors (GCash, PayMaya, banks) may provide transaction confirmation data.
• Identity verification service providers may provide verification results and fraud detection data.
• Marketing partners may provide aggregated demographic and interest data for targeted advertising purposes.

03 How We Use Your Information

smjili processes your personal information for the following purposes:

• Account Management: To create, maintain, and manage your smjili account, including authentication and access control.
• Service Provision: To provide access to casino games, sports betting markets, and other Platform features, and to process your bets and gaming transactions.
• Payment Processing: To process deposits, withdrawals, and other financial transactions, and to maintain accurate financial records.
• Identity Verification and KYC: To verify your identity and age, comply with anti-money laundering (AML) regulations, and prevent fraud and underage gambling.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Security and Fraud Prevention: To detect, prevent, and investigate fraudulent activity, security breaches, and violations of our Terms and Conditions.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes, including PAGCOR licensing requirements and tax reporting obligations.
• Marketing and Communications: To send you promotional offers, bonuses, newsletters, and other marketing communications (with your consent where required by law).
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the Platform.
• Responsible Gaming: To monitor gaming behavior, identify potential problem gambling patterns, and implement responsible gaming measures such as deposit limits and self-exclusion.

04 Legal Basis for Processing

Under Philippine data protection law, smjili processes your personal information based on the following legal grounds:

• Consent: You have provided explicit consent for the processing of your personal data for specific purposes, such as receiving marketing communications.
• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms and Conditions) and to provide the services you have requested.
• Legal Obligation: Processing is required to comply with legal obligations, including KYC/AML requirements, tax reporting, and regulatory compliance under PAGCOR regulations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and Platform improvement, provided that such interests do not override your fundamental rights and freedoms.

05 Data Sharing & Disclosure

smjili does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for the purposes described in this Privacy Policy:

• Service Providers: Third-party vendors who provide services on our behalf, including payment processors (GCash, PayMaya, banks), identity verification providers, cloud hosting services, customer support platforms, and marketing service providers. These service providers are contractually obligated to protect your data and use it only for the purposes we specify.
• Game Providers: Third-party game developers and software providers whose games are featured on the Platform. These providers may receive limited data necessary to operate their games and track gameplay.
• Regulatory Authorities: PAGCOR and other government agencies as required by law or regulation, including for licensing compliance, tax reporting, and law enforcement purposes.
• Legal and Professional Advisors: Lawyers, accountants, auditors, and other professional advisors who assist us in operating our business and complying with legal obligations.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections described in this Privacy Policy.
• Law Enforcement and Legal Processes: When required by law, court order, subpoena, or other legal process, or when necessary to protect our rights, property, or safety, or the rights, property, or safety of others.

All third parties with whom we share your personal information are required to maintain appropriate security measures and to process your data only in accordance with our instructions and applicable data protection laws.

06 Data Security

smjili takes the security of your personal information seriously and implements industry-standard technical and organizational measures to protect your data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption. Sensitive data stored in our databases is encrypted at rest.
• Access Controls: Access to personal information is restricted to authorized personnel only, based on the principle of least privilege. All employees and contractors with access to personal data are bound by confidentiality obligations.
• Secure Infrastructure: Our Platform is hosted on secure cloud infrastructure with regular security audits, vulnerability assessments, and penetration testing.
• Monitoring and Logging: We maintain comprehensive security logs and employ real-time monitoring systems to detect and respond to security incidents.
• Regular Updates: We regularly update our systems, software, and security protocols to address emerging threats and vulnerabilities.

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. You acknowledge that you provide your personal information at your own risk. If you become aware of any security breach or unauthorized access to your account, you must notify us immediately.

07 Data Retention

smjili retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Data: Retained for the duration of your account's active status and for seven (7) years after account closure, as required by Philippine financial record-keeping regulations.
• Transaction Records: Retained for a minimum of seven (7) years to comply with tax, accounting, and anti-money laundering requirements.
• Identity Verification Documents: Retained for seven (7) years after account closure to comply with KYC/AML regulations.
• Marketing Communications: Retained until you withdraw consent or request deletion, or for three (3) years from the date of last interaction.
• Technical and Usage Data: Retained for up to two (2) years for analytics and Platform improvement purposes.

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention and disposal policies.

08 Your Rights

Under the Data Privacy Act of 2012 and other applicable laws, you have the following rights regarding your personal information:

• Right to Access: You have the right to request access to the personal information we hold about you and to receive a copy of that information.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information.
• Right to Erasure: You have the right to request deletion of your personal information, subject to legal retention requirements and legitimate business needs.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes or based on legitimate interests.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 14. We will respond to your request within thirty (30) days, or as otherwise required by applicable law.

09 Cookies & Tracking

smjili uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content and advertising. Cookies are small text files stored on your device that allow us to recognize you and remember your preferences.

Types of Cookies We Use:

• Essential Cookies: Required for the Platform to function properly, including authentication, security, and session management.
• Performance Cookies: Collect anonymous data about how you use the Platform to help us improve performance and user experience.
• Functional Cookies: Remember your preferences and settings to provide enhanced, personalized features.
• Advertising Cookies: Track your browsing activity to deliver targeted advertisements and measure campaign effectiveness.

You can control cookie settings through your browser preferences. However, disabling certain cookies may limit your ability to use some features of the Platform. For more information about cookies and how to manage them, please visit your browser's help documentation.

10 Third-Party Links

The smjili Platform may contain links to third-party websites, services, or applications that are not operated or controlled by smjili. This Privacy Policy does not apply to third-party websites or services. We are not responsible for the privacy practices or content of third parties.

We encourage you to review the privacy policies of any third-party websites or services you visit. Your interactions with third-party websites are governed by their respective privacy policies, and smjili assumes no liability for their data handling practices.

11 Children's Privacy

The smjili Platform is intended for use by individuals who are at least 21 years of age. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal information from a person under 21, we will take immediate steps to delete that information and terminate the associated account.

If you are a parent or guardian and believe that your child has provided personal information to smjili, please contact us immediately using the contact details in Section 14.

12 International Transfers

Your personal information may be transferred to, stored, and processed in jurisdictions outside the Philippines where our service providers and technology infrastructure are located. These jurisdictions may have data protection laws that differ from Philippine law.

When we transfer your personal information internationally, we ensure that appropriate safeguards are in place to protect your data, including standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms. By using the smjili Platform, you consent to the international transfer of your personal information as described in this Privacy Policy.

13 Changes to This Policy

smjili reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. We will notify you of material changes by posting a prominent notice on the Platform or by sending an email to the address associated with your account.

The "Last Updated" date at the top of this Privacy Policy indicates when it was last revised. Your continued use of the Platform after any changes to this Privacy Policy constitutes your acceptance of the revised policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Customer Support: [email protected]
• Live Chat: Available 24/7 on the smjili Platform

We will respond to your inquiry within thirty (30) days of receipt. For complaints regarding data protection violations, you may also contact the National Privacy Commission of the Philippines.