phjelly Privacy Policy

1. Introduction

phjelly ("we," "us," "our," or "phjelly") operates the online gambling platform accessible at phjelly.net, offering Filipino players access to online slots, live casino games, sports betting, bingo, and video poker, including Jacks or Better. We are committed to handling all personal data we collect in connection with the operation of our platform with the utmost care, transparency, and respect for the privacy rights of our players.

This Privacy Policy has been prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC) of the Philippines. It governs the collection, use, storage, disclosure, and deletion of personal data that phjelly processes in connection with your use of the phjelly platform.

By registering an Account with phjelly, depositing funds, placing bets, or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the platform and contact our Data Protection Officer to request Account closure.

2. Data Controller

2.1 phjelly is the personal information controller in respect of all personal data collected through the phjelly.net platform. As the personal information controller, phjelly determines the purposes and means of processing your personal data and bears primary responsibility for ensuring that processing activities comply with Republic Act No. 10173.

2.2 phjelly has appointed a Data Protection Officer (DPO) in accordance with the requirements of the National Privacy Commission. The DPO is responsible for overseeing phjelly's data protection compliance programme, handling data subject access requests, and serving as the primary point of contact with the NPC. The DPO may be contacted at the email address listed in Section 17 of this Policy.

2.3 phjelly's Data Protection Officer registration details are on file with the National Privacy Commission consistent with NPC Circular No. 17-01.

3. Personal Data We Collect

phjelly collects the following categories of personal data in connection with your use of the platform:

3.1 Identity and Contact Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth and age verification documentation
• Philippine residential address (barangay, city/municipality, province)
• Valid email address
• Mobile phone number (for OTP verification and account security)
• Copies of government-issued photo identification (e.g., Philippine Passport, SSS UMID, PRC ID, Driver's Licence, PhilSys National ID)
• Proof of address documents (utility bills, bank statements issued in the Philippines)

3.2 Financial Data

• GCash account number or PayMaya account details
• Philippine bank account details (BPI, BDO, Metrobank, UnionBank) used for deposits and withdrawals
• Transaction history, including deposit amounts, withdrawal amounts, and timestamps
• Source of funds documentation (where required for high-value transactions under AMLA)

3.3 Gaming Activity Data

• Game session logs, including games played, wager amounts, outcomes, and session duration
• Sports betting history, including markets selected, odds, and settlement outcomes
• Bonus and promotion history
• Responsible gaming tool usage, including deposit limits, self-exclusion requests, and cooling-off periods

3.4 Technical and Device Data

• IP address and geolocation data (used for fraud prevention and regulatory compliance)
• Device type, operating system, and browser type
• Session identifiers and authentication tokens
• Platform usage logs, including pages visited, click paths, and time spent on each section

3.5 Communications Data

• Records of live chat conversations with phjelly customer support
• Email correspondence sent to or received from phjelly support
• Records of any formal complaints submitted to phjelly
• Survey responses and feedback submitted voluntarily through the platform

4. How We Collect Your Data

4.1 Directly from you. The majority of personal data phjelly holds is information you provide directly during Account registration, KYC verification, deposit and withdrawal transactions, customer support interactions, and promotional opt-ins.

4.2 Automatically through platform use. When you access the phjelly platform, our systems automatically collect technical data such as your IP address, browser fingerprint, device identifiers, and session activity logs. This data is collected through server logs, session cookies, and analytics tools operated by phjelly directly.

4.3 From third-party KYC and fraud prevention providers. phjelly works with licensed identity verification services and anti-fraud technology providers to verify your identity and assess fraud risk. These providers may return verified identity data, sanctions screening results, and politically exposed person (PEP) status checks, which are added to your Account record.

4.4 From payment processors. When you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, InstaPay, or PESONet, the relevant payment processor shares transaction confirmation data with phjelly to reconcile your Wallet balance and maintain accurate financial records.

5. Purposes of Processing

phjelly processes your personal data for the following specific, legitimate purposes:

Purpose	Data Categories Used
Account registration and management	Identity, contact data
Age verification (21+ compliance)	Date of birth, government ID
KYC identity verification	Identity, financial data, government ID
Processing deposits and withdrawals	Financial data, identity data
Fraud prevention and AML compliance	All categories, including technical data
PAGCOR regulatory reporting	Gaming activity, financial data
Responsible gaming monitoring	Gaming activity, responsible gaming tool usage
Customer support	Identity, communications data
Platform security and integrity	Technical data, gaming activity
Marketing communications (with consent)	Contact data, gaming preferences
Platform analytics and improvement	Technical data (aggregated/anonymised)

6. Legal Bases for Processing

6.1 Contractual Necessity. Processing your identity, contact, and financial data is necessary for phjelly to perform its obligations under the Terms & Conditions you agreed to at registration — including operating your Account, processing your transactions, and providing access to games and betting markets.

6.2 Legal Obligation. Certain processing activities — including KYC verification, age verification, AML transaction monitoring, and regulatory reporting to PAGCOR — are required by Philippine law. These include obligations under the Anti-Money Laundering Act of 2001 (as amended), the Terrorism Financing Prevention and Suppression Act, and PAGCOR's applicable regulatory issuances. phjelly cannot waive these legal processing obligations at a data subject's request.

6.3 Legitimate Interests. phjelly processes technical and device data for fraud prevention, platform security, and the protection of the integrity of its gaming operations. These activities are necessary to protect both phjelly and its players from financial crime and technical exploitation, and are conducted in a manner proportionate to their purpose.

6.4 Consent. Marketing communications — including promotional emails, SMS notifications, and push notifications about bonuses, tournaments, and new game releases — are sent only to players who have provided explicit, freely given, specific, and informed consent. Consent may be withdrawn at any time through your Account notification settings or by contacting customer support.

7. Sharing Your Personal Data

7.1 phjelly does not sell, rent, or trade your personal data to any third party for their own commercial purposes. Personal data is shared only in the following specific and limited circumstances:

• KYC and identity verification providers: Licensed identity verification platforms used to confirm your identity, age, and document authenticity. These providers act as personal information processors under binding data processing agreements with phjelly.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other licensed Philippine payment service providers, solely for the purpose of processing your deposits and withdrawals.
• Anti-fraud and AML compliance services: Providers of sanctions screening, PEP checks, and transaction monitoring technology, used to fulfil phjelly's obligations under Philippine AML law.
• PAGCOR and Philippine regulatory authorities: Where required by law, regulation, court order, or lawful governmental demand, phjelly will disclose player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities.
• IT infrastructure and hosting providers: Cloud hosting and server infrastructure providers under strict data processing and confidentiality agreements, solely for the purpose of operating the phjelly platform.
• Customer support technology: Live chat and ticketing platform providers used to manage your support interactions, operating under confidentiality obligations.

7.2 All third-party processors engaged by phjelly are required to process personal data only in accordance with phjelly's documented instructions and to implement appropriate technical and organisational security measures consistent with Republic Act No. 10173.

8. Cookies and Tracking Technologies

8.1 phjelly uses the following types of cookies and similar technologies when you access phjelly.net:

• Strictly Necessary Cookies: Essential for the operation of the platform. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without rendering the platform non-functional.
• Functional Cookies: Used to remember your preferences, such as your preferred language setting, display preferences, and responsible gaming tool configurations. Disabling these cookies may affect your user experience but will not prevent access to core platform features.
• Analytical Cookies: Used by phjelly's internal analytics systems to measure aggregate platform usage patterns — such as which game categories are most popular with Filipino players in Manila, Cebu, Davao, and Makati. All data collected through analytical cookies is aggregated and anonymised before analysis. phjelly does not use Google Analytics or other third-party analytics services that transmit player data outside phjelly's controlled infrastructure.

8.2 phjelly does not deploy advertising cookies, tracking pixels from social media platforms, or any third-party retargeting technologies on phjelly.net.

8.3 You may manage cookie settings through your web browser's built-in privacy controls. Most modern browsers allow you to block or delete cookies on a per-site basis. Note that blocking strictly necessary cookies will prevent you from accessing your phjelly Account.

9. Data Retention

9.1 phjelly retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Data Category	Retention Period	Legal Basis for Retention
Account registration data	Duration of active Account + 2 years post-closure	Contractual obligation, legitimate interest
KYC documents and identity records	5 years from Account closure	AMLA / PAGCOR regulatory obligation
Transaction and financial records	5 years from date of transaction	Anti-Money Laundering Act of 2001 (as amended)
Game session logs	2 years from date of session	PAGCOR regulatory obligation, dispute resolution
Customer support records	2 years from date of interaction	Legitimate interest (dispute resolution)
Marketing consent records	Until consent is withdrawn + 1 year	Consent, legal obligation (proof of consent)
Technical / server logs	90 days (rolling)	Security, fraud prevention

9.2 Upon the expiry of applicable retention periods, phjelly will securely delete or irreversibly anonymise the relevant personal data using industry-standard data destruction methods.

10. Data Security

10.1 phjelly implements a layered, defence-in-depth approach to personal data security, including the following technical and organisational measures:

• Encryption: AES-256 encryption for data at rest; TLS 1.3 for all data in transit between your browser and phjelly's servers.
• Access Controls: Role-based access control (RBAC) ensuring that phjelly staff can only access player data to the minimum extent necessary for their specific job function.
• Authentication: Multi-factor authentication (MFA) required for all phjelly staff accessing systems that hold personal data.
• Penetration Testing: Regular third-party security audits and penetration tests conducted on the phjelly platform infrastructure.
• Monitoring: 24/7 security monitoring and intrusion detection systems covering all phjelly infrastructure.
• Staff Training: All phjelly staff with access to personal data are trained on data privacy obligations under Republic Act No. 10173 and phjelly's internal data handling procedures.

10.2 Despite these measures, no internet-based platform can guarantee absolute security. phjelly strongly encourages all players to use a strong, unique password for their Account and to enable two-factor authentication (2FA), which is available free of charge to all registered players.

10.3 In the event of a personal data breach that is likely to adversely affect the rights and freedoms of Filipino data subjects, phjelly will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, consistent with Section 20(f) of Republic Act No. 10173.

11. Cross-Border Data Transfers

11.1 The operation of phjelly's platform may involve the transfer of personal data to service providers located outside the Philippines — for example, cloud infrastructure providers and international KYC verification services. Where such transfers occur, phjelly ensures they are carried out only in compliance with Section 21 of the Data Privacy Act of 2012, which requires that:

• The recipient country provides an adequate level of data protection, as determined by the National Privacy Commission; or
• Appropriate contractual safeguards — such as binding data processing agreements incorporating NPC-approved standard contractual clauses — are in place before any transfer occurs.

11.2 phjelly does not transfer player financial transaction records, KYC identity documents, or responsible gaming records to any overseas entity except where strictly required by a licensed service provider operating under a binding data processing agreement and subject to equivalent data protection standards.

12. Your Data Privacy Rights

Under the Data Privacy Act of 2012, as a Filipino data subject you have the following rights in respect of personal data that phjelly holds about you:

• Right to be Informed: The right to know whether phjelly holds personal data about you and to receive clear information about how it is being processed. This Privacy Policy is the primary vehicle through which phjelly fulfils this right.
• Right of Access: The right to request a copy of all personal data phjelly holds about you, including information about how it is being processed. phjelly will respond to verified access requests within a reasonable period, not exceeding thirty (30) days.
• Right to Rectification: The right to request correction of any personal data phjelly holds about you that is inaccurate or incomplete. You may update basic Account details directly through your Account settings. For KYC documents and other identity records, please contact our Data Protection Officer.
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent (for consent-based processing). This right is subject to phjelly's legal retention obligations under AMLA and PAGCOR regulations, which take precedence over erasure requests for the specified retention periods.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. Marketing opt-outs are effective immediately upon request and can be made through your Account notification settings or by emailing phjelly's DPO.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible and where processing is carried out by automated means.
• Right to File a Complaint: The right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe phjelly has processed your personal data in violation of the Data Privacy Act of 2012. The NPC can be contacted through its official website.

To exercise any of the above rights, please contact phjelly's Data Protection Officer using the contact details provided in Section 17 of this Policy. We may need to verify your identity before processing your request.

13. Children's Privacy and Age Restriction

13.1 phjelly is strictly an adults-only platform. In accordance with PAGCOR regulations, only individuals aged 21 years and above are permitted to register an Account and use the phjelly platform. phjelly does not knowingly collect personal data from individuals under the age of 21.

13.2 Where phjelly becomes aware or has reasonable grounds to suspect that a player is under 21 years of age, the Account will be immediately suspended, all pending bets and bonuses voided, and any deposited funds returned to the payment method of origin following verification. The personal data associated with an underage Account will be retained only for the minimum period required to complete the refund process and comply with applicable reporting obligations, after which it will be securely deleted.

13.3 If you have reason to believe that a minor has registered an Account with phjelly using false age information, please notify us immediately at [email protected] so that we can take appropriate action without delay.

14. Marketing Communications

14.1 phjelly may send you promotional communications about bonuses, new game releases, VIP programme updates, sports betting promotions, and special offers tailored to Filipino players — but only where you have provided prior explicit consent at Account registration or through your Account notification settings.

14.2 You may withdraw your consent to receive marketing communications at any time without affecting the lawfulness of processing that occurred before your withdrawal. To opt out, you may:

• Update your notification preferences directly in your phjelly Account settings;
• Click the unsubscribe link included in any phjelly marketing email; or
• Contact customer support via live chat or by emailing [email protected].

14.3 Opting out of marketing communications does not affect transactional communications — such as deposit confirmations, withdrawal notifications, Account security alerts, and mandatory responsible gaming messages — which phjelly will continue to send as they are necessary for the operation of your Account.

15. Third-Party Links

15.1 The phjelly platform does not contain links to third-party websites, applications, or services beyond those strictly necessary for the operation of the platform (such as licensed payment processors). phjelly is not responsible for the privacy practices or content of any third-party services you may access independently outside of phjelly.net.

15.2 Where you access payment services such as GCash or PayMaya in connection with your phjelly Account, those services are governed by their own privacy policies and terms of service. phjelly encourages you to review the privacy policies of any payment service provider you use in connection with your phjelly Account.

16. Amendments to This Privacy Policy

16.1 phjelly reserves the right to update or amend this Privacy Policy at any time. Updates may be made to reflect changes in Philippine privacy law, NPC issuances, PAGCOR regulatory requirements, phjelly's data processing practices, or the introduction of new platform features.

16.2 Where a material change is made to this Privacy Policy — for example, a change to the categories of personal data collected, the purposes of processing, or the third parties with whom data is shared — phjelly will notify all registered players by email at least fourteen (14) days before the change takes effect. The updated effective date will be reflected at the top of this page.

16.3 Your continued use of the phjelly platform following the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. If you do not accept the updated terms, you may request Account closure by contacting customer support prior to the effective date.

17. Contact and Complaints

17.1 For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phjelly, please contact our Data Protection Officer. All privacy-related enquiries are handled exclusively by email — do not send sensitive documents or identification materials via live chat.

17.2 If you are not satisfied with phjelly's response to your privacy concern or believe that phjelly has violated your rights under the Data Privacy Act of 2012, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory authority responsible for enforcing Republic Act No. 10173 and can be reached through its official government channels.

17.3 phjelly takes all privacy complaints seriously. We are committed to working constructively with all Filipino players to resolve data privacy concerns promptly, fairly, and in full compliance with our obligations under Philippine law.