kbjili Privacy Policy

kbjili ("we", "us", "our", "the Platform") operates the online gaming platform accessible at kbjili.app. As a PAGCOR-regulated gaming operator serving Filipino players across the Philippines — from Metro Manila and Cebu to Davao, Iloilo, and beyond — we handle a range of personal information as part of our day-to-day operations.

This Privacy Policy ("Policy") describes in plain language:

• What categories of personal data kbjili collects from you;
• The purposes for which that data is processed;
• Who we may share it with, and under what conditions;
• How long we retain it;
• The security measures we have in place to protect it; and
• The rights you hold as a data subject under Philippine law.

This Policy applies to all kbjili products and services, including our website, mobile-optimized platform, live chat support, promotional communications, and any other touchpoint through which you interact with kbjili. It should be read together with our Terms and Conditions, which govern the broader relationship between you and kbjili.

If you have questions about any part of this Policy, our Data Privacy Officer is reachable through the contact details listed in Section 14 of this document.

kbjili collects personal data across several categories. The specific data points collected depend on how you interact with our platform and the services you use.

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Gender;
• Nationality and place of residence (city/province in the Philippines);
• Government-issued ID type and number (e.g., Philippine National ID, UMID, passport, driver's license, SSS or PhilHealth card).

2.2 Contact Data

• Philippine mobile number;
• Email address;
• Residential address (barangay, city/municipality, province).

2.3 Financial & Transaction Data

• GCash or PayMaya account number linked to your kbjili wallet;
• Bank account details (BPI, BDO, Metrobank, UnionBank) used for deposits and withdrawals;
• Deposit and withdrawal history, including transaction amounts, timestamps, and reference numbers;
• Bonus credits claimed and wagering activity records.

2.4 Technical & Device Data

• IP address and approximate geolocation derived from it;
• Device type, operating system, and browser information;
• Session duration and login timestamps;
• Cookies and similar tracking data (see Section 7 for full details).

2.5 Gaming Activity Data

• Game session records, including games played, bets placed, wins, and losses;
• Sports betting selections, odds accepted, and settlement outcomes;
• Responsible gaming tool usage, including deposit limits set and self-exclusion requests made.

2.6 Communications Data

• Records of live chat conversations with kbjili support agents;
• Emails sent to and received from kbjili's support team;
• Responses to surveys, feedback forms, or promotional participation records.

kbjili collects personal data through the following primary channels:

• Direct Submission: Information you provide when registering an account, completing identity verification, contacting support, or participating in promotions;
• Automated Collection: Technical data collected automatically when you browse or interact with the kbjili website or platform, including via cookies, server logs, and session-tracking tools;
• Third-Party Verification: Identity and address data received from KYC verification partners and payment processors when we verify your identity or process a financial transaction;
• Regulatory Sources: Information received from PAGCOR or other government bodies in connection with our licensing and compliance obligations, including self-exclusion registry checks.

kbjili does not purchase personal data lists from third-party data brokers. We do not obtain your personal information from social media platforms without your explicit consent.

The table below summarizes the key purposes for which kbjili processes your personal data and the corresponding category of data used for each purpose:

kbjili does not use your personal data for automated decision-making processes that produce legal or similarly significant effects on you, without providing a human review mechanism.

Under the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules, kbjili relies on the following lawful bases for processing your personal data:

• Contractual Necessity: Processing required to register your account, verify your identity, process transactions, and provide all gaming services is necessary for the performance of the contract between you and kbjili;
• Legal Obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws (RA 9160, as amended), tax reporting obligations under the Bureau of Internal Revenue, and any lawful order from a competent Philippine government authority;
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics — where these interests are not overridden by your data protection rights;
• Consent: Processing for direct marketing communications and non-essential analytics cookies, where you have provided clear, freely given, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

kbjili does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your data only in the circumstances described below, and only to the minimum extent necessary for each purpose:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank receive the transaction data necessary to process your deposits and withdrawals. Each processor is bound by their own data protection obligations and is not permitted to use your data for any other purpose;
• Identity Verification (KYC) Providers: Third-party KYC service providers receive your name, date of birth, and ID document details for the sole purpose of verifying your identity as required by PAGCOR and applicable Philippine law;
• Game Content Providers: Third-party game studios may receive session-level data (such as a pseudonymous player ID, bet amounts, and game outcomes) to facilitate game delivery and settle bets. These providers do not receive your full identity data;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other competent Philippine government bodies may receive your data when kbjili is legally required to report or respond to an official inquiry;
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by kbjili may access personal data on a strictly confidential, need-to-know basis in connection with their advisory services;
• Business Transfers: In the event of a merger, acquisition, or sale of kbjili's business assets, your personal data may be transferred to the acquiring entity. You will be notified in advance of any such transfer and of any material change to the way your data is handled.

kbjili uses cookies and similar tracking technologies on its platform. Below is a summary of the cookie categories in use:

• Strictly Necessary Cookies: These cookies are essential for the kbjili platform to function. They maintain your authenticated session, prevent cross-site request forgery (CSRF) attacks, and remember your language preference. These cookies cannot be disabled without breaking core platform functionality;
• Functional Cookies: These remember your display preferences and responsible gaming settings so you do not have to re-enter them each session. They are enabled by default but can be disabled in your browser settings;
• Analytics Cookies: With your consent, kbjili uses anonymized analytics data to understand how players navigate the platform, which features are most used, and where performance bottlenecks occur. This data does not identify you personally and is used only in aggregate form;
• Session Security Tokens: Short-lived tokens stored in your browser's session storage to authenticate API requests during active gameplay. These are deleted automatically when you close your browser tab.

You can manage your cookie preferences at any time through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in or using the kbjili platform. kbjili does not use third-party advertising or retargeting cookies.

kbjili retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following retention periods apply as a general guide:

• Account & Identity Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by BIR and AMLC regulations;
• Gaming Activity Records: Retained for five (5) years from the date of the session or bet, for regulatory audit and dispute resolution purposes;
• Customer Support Communications: Retained for three (3) years from the date of the communication, unless the subject matter is connected to an ongoing investigation or dispute;
• Marketing Consent Records: Retained for the period of your consent plus two (2) years, to demonstrate compliance in the event of a complaint;
• Technical & Log Data: Server logs are retained for ninety (90) days for security monitoring and then permanently deleted.

Upon expiry of the applicable retention period, kbjili securely deletes or irreversibly anonymizes your personal data using industry-standard data disposal practices.

kbjili takes the security of your personal data seriously. We have implemented the following technical and organizational measures to protect your information against unauthorized access, loss, alteration, or disclosure:

• Encryption in Transit: All data transmitted between your browser and the kbjili platform is encrypted using TLS 1.2 or higher. Connections via unencrypted HTTP are automatically redirected to HTTPS;
• Encryption at Rest: Sensitive personal data — including government ID numbers, payment account references, and authentication credentials — is stored using AES-256 encryption;
• Password Security: User passwords are never stored in plain text. kbjili uses industry-standard one-way hashing with salting (bcrypt) for all password storage;
• Access Controls: Access to personal data within kbjili's internal systems is restricted on a need-to-know basis using role-based access controls. All staff with data access undergo regular data privacy training;
• Security Monitoring: kbjili operates continuous security monitoring on its platform infrastructure to detect and respond to anomalous access patterns, brute-force attempts, and other threat indicators;
• Vulnerability Management: Regular penetration testing and security audits are conducted by qualified third-party security professionals. Critical vulnerabilities are remediated on a priority basis.

In the event of a personal data breach that poses a risk to your rights and freedoms, kbjili will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay through their registered email address.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by kbjili:

• Right to Be Informed: You have the right to know what personal data kbjili holds about you, the purposes for which it is processed, and who it may be shared with. This Privacy Policy fulfils our obligation to inform you;
• Right of Access: You may request a copy of the personal data kbjili holds about you, together with information on how it is used. We will respond to verified access requests within fifteen (15) business days;
• Right to Rectification: If your personal data is inaccurate or incomplete, you have the right to request correction. For most details, you can update your information directly through Account Settings. For identity-verified fields, a support request with documentary evidence may be required;
• Right to Erasure: Subject to our legal retention obligations, you may request the deletion of your personal data. Note that we are unable to delete data that we are legally required to retain under PAGCOR, AMLC, or BIR regulations, even after account closure;
• Right to Object: You have the right to object to processing based on legitimate interests, and to processing for direct marketing purposes. Withdrawal of consent for marketing will take effect within 48 hours of your request;
• Right to Data Portability: You may request that kbjili provide your personal data in a structured, commonly used, machine-readable format so that it can be transferred to another data controller;
• Right to Lodge a Complaint: If you believe that kbjili has processed your personal data in violation of RA 10173, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Privacy Officer using the details in Section 14. We may need to verify your identity before processing certain requests to protect against unauthorized access to your data.

kbjili is strictly an adult platform. As mandated by PAGCOR regulations and Philippine law, only individuals who are 21 years of age or older are permitted to register and play on the kbjili platform.

kbjili does not knowingly collect personal data from any individual under the age of 21. Age verification is conducted during the registration process and again at the point of first withdrawal. Any account found to belong to a person under the age of 21 will be immediately closed, all associated balances will be forfeited in accordance with regulatory requirements, and the personal data collected will be deleted as soon as legally permissible.

If you have reason to believe that a minor has registered on the kbjili platform or has gained access to an existing account, please notify us immediately through our live chat or support email so that we can take immediate action.

kbjili's primary data storage and processing infrastructure is located within the Philippines. In certain circumstances, however, your personal data may be processed by service providers whose systems are located in other countries — for example, cloud infrastructure providers or internationally based game studio partners.

Where kbjili transfers personal data outside the Philippines, we ensure that appropriate safeguards are in place in accordance with RA 10173 and the National Privacy Commission's guidelines on cross-border data transfers. These safeguards may include:

• Standard contractual clauses approved or recognized by the National Privacy Commission;
• Transfers to countries that the NPC has determined offer an adequate level of data protection;
• Binding corporate rules where transfers occur within a corporate group subject to a recognized privacy governance framework.

kbjili will not transfer your personal data internationally to any party that cannot demonstrate adequate data protection standards consistent with Philippine law and the requirements of RA 10173.

kbjili reserves the right to update or revise this Privacy Policy at any time. The "Effective Date" displayed at the top of this Policy will be updated whenever a material change is made. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — kbjili will provide advance notice to registered players through:

• A prominent notice on the kbjili platform homepage or login screen; and/or
• An email to your registered kbjili email address, sent at least seven (7) calendar days before the revised Policy takes effect.

Your continued use of the kbjili platform after the effective date of any updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the updated Policy, you must stop using the kbjili platform and may request account closure through our support team.

Prior versions of this Privacy Policy are available upon written request to our Data Privacy Officer.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way kbjili handles your personal data, please reach out to our Data Privacy Officer through the following channels:

• Email: [email protected] — please include "Data Privacy Request" in the subject line for priority routing to our Data Privacy Officer;
• Live Chat: Available 24 hours a day, 7 days a week, directly on the kbjili platform. Our support agents can log a formal data privacy request on your behalf and escalate it to the Data Privacy Officer within one business day.

We are committed to responding to all data privacy-related requests within fifteen (15) business days of receipt, in accordance with the requirements of the National Privacy Commission. For complex requests requiring regulatory consultation, we may extend this period by an additional ten (10) business days and will notify you accordingly.

If you are not satisfied with kbjili's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), which is the independent supervisory authority responsible for enforcing RA 10173.