smjili Privacy Policy

1. Introduction and Scope

smjili ("we," "us," "our," or "Platform") is committed to protecting the privacy and security of your personal information. This Privacy Policy (hereinafter "Policy") describes how smjili collects, uses, processes, stores, discloses, and protects personal data of users (hereinafter "you," "your," or "User") who access or use our online gaming platform available at https://smjili.cam and all associated services, features, content, and applications (collectively, the "Services").

This Policy applies to all personal information collected through our website, mobile applications, customer service channels, and any other point of contact with smjili. By creating an account, accessing the Platform, or using any of our Services, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy and in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

2. Information We Collect

2.1 Personal Information Provided by You

When you register for a smjili account and use our Services, we collect the following categories of personal information that you voluntarily provide:

2.2 Automatically Collected Information

We automatically collect certain technical and usage information when you access or use the smjili Platform:

• Device Information: Device type, operating system, browser type and version, device identifiers (IMEI, MAC address), screen resolution, mobile network information
• Usage Data: Pages visited, features used, time spent on Platform, clickstream data, game play history, betting patterns, win/loss records
• Location Information: IP address, geographic location data, timezone information (used to verify Philippine jurisdiction and prevent access from restricted territories)
• Communication Records: Customer service interactions, chat logs, email correspondence, support tickets
• Transaction History: Deposit amounts, withdrawal requests, payment method usage, transaction dates and times, bonus usage

2.3 Information from Third-Party Sources

We may collect information about you from third-party sources including payment processors (GCash, PayMaya, banks), identity verification services, fraud prevention providers, credit reference agencies, and publicly available databases to verify your identity, prevent fraud, and comply with legal obligations.

3. How We Use Your Personal Information

smjili processes your personal information for the following legitimate purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your gaming account
• Processing your deposits, withdrawals, and other financial transactions
• Enabling you to participate in games and utilize Platform features
• Managing your account settings, preferences, and gaming limits
• Providing customer support and responding to your inquiries
• Resolving disputes and troubleshooting technical issues

3.2 Verification and Compliance

• Verifying your identity, age (21+ requirement), and geographic location
• Complying with PAGCOR licensing requirements and gaming regulations
• Meeting Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under the Anti-Money Laundering Act of 2001 (RA 9160)
• Detecting and preventing fraud, money laundering, and other illegal activities
• Responding to legal processes, court orders, and law enforcement requests

3.3 Security and Fraud Prevention

• Monitoring account activity for suspicious or fraudulent behavior
• Implementing security measures to protect your account and funds
• Preventing unauthorized access, hacking attempts, and cyber attacks
• Investigating and resolving security incidents
• Enforcing our Terms and Conditions and other policies

3.4 Marketing and Communications

• Sending promotional offers, bonuses, and special promotions (with your consent)
• Providing personalized gaming recommendations based on your preferences
• Conducting surveys and gathering feedback to improve our Services
• Sending important account notifications, policy updates, and security alerts

3.5 Analytics and Improvement

• Analyzing user behavior and Platform usage patterns to improve Services
• Developing new features and enhancing existing functionality
• Conducting research and statistical analysis
• Testing and optimizing Platform performance

3.6 Responsible Gaming

• Monitoring gaming patterns to identify potential problem gambling behavior
• Implementing and enforcing deposit limits, loss limits, and self-exclusion requests
• Providing responsible gaming tools and resources
• Complying with regulatory requirements for player protection

4. Disclosure and Sharing of Personal Information

smjili does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may disclose your personal information to the following categories of recipients for the purposes described below:

4.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: GCash, PayMaya, banks, and other payment service providers to process your deposits and withdrawals
• Identity Verification Services: Third-party KYC and identity verification providers to confirm your identity and prevent fraud
• Cloud Service Providers: Companies that host our servers and store our data securely
• Customer Support Platforms: Service providers that help us manage customer service inquiries and communications
• Analytics Providers: Companies that help us analyze Platform usage and improve our Services
• Marketing Service Providers: Email marketing platforms and advertising networks (only with your consent)

All service providers are contractually bound to protect your personal information and use it only for the purposes specified by smjili.

4.2 Regulatory Authorities and Law Enforcement

We may disclose personal information to regulatory bodies, law enforcement agencies, courts, and government authorities when:

• Required by law, regulation, legal process, or governmental request
• Necessary to comply with PAGCOR licensing and regulatory requirements
• Necessary to comply with Anti-Money Laundering (AML) reporting obligations
• Necessary to prevent or investigate suspected illegal activity, fraud, or security threats
• Necessary to protect the rights, property, or safety of smjili, our users, or the public

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor organization, subject to the same privacy protections outlined in this Policy.

4.4 Game Providers

Limited information (such as user ID and gaming session data) may be shared with third-party game providers to enable you to play their games on our Platform. Game providers are contractually obligated to protect your information.

5. Data Security Measures

smjili implements comprehensive technical, administrative, and physical security measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction:

5.1 Technical Security Controls

• Encryption: All sensitive data is encrypted in transit using TLS/SSL protocols and at rest using industry-standard AES-256 encryption
• Firewall Protection: Advanced firewalls protect our servers from unauthorized access and cyber attacks
• Intrusion Detection Systems: Real-time monitoring systems detect and respond to security threats
• Secure Authentication: Multi-factor authentication (MFA) and strong password requirements protect account access
• Regular Security Audits: Independent security firms conduct regular penetration testing and vulnerability assessments
• Data Segregation: Personal information is stored separately from financial data and gaming records

5.2 Administrative Security Controls

• Access Controls: Personal information is accessible only to authorized employees who require access to perform their job functions
• Employee Training: All staff receive regular training on data protection principles and security best practices
• Confidentiality Agreements: Employees and contractors are bound by strict confidentiality obligations
• Incident Response Plan: Comprehensive procedures are in place to respond to and mitigate data breaches

5.3 Physical Security Controls

• Data centers are secured with 24/7 surveillance, access controls, and environmental protections
• Regular backups ensure data availability and business continuity
• Disaster recovery procedures protect against data loss

6. Cookies and Tracking Technologies

6.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. smjili uses cookies and similar tracking technologies (web beacons, pixels, local storage) to enhance your user experience, analyze Platform usage, and deliver personalized content.

6.2 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly, including authentication, security, and load balancing. These cookies cannot be disabled.
• Performance Cookies: Collect anonymous information about how users interact with our Platform to help us improve functionality and performance.
• Functionality Cookies: Remember your preferences and settings (language, timezone, display options) to provide a personalized experience.
• Analytics Cookies: Help us understand user behavior, traffic sources, and Platform usage patterns through services like Google Analytics.
• Advertising Cookies: Used to deliver relevant advertisements and measure campaign effectiveness (only with your consent).

6.3 Managing Cookie Preferences

You can control and manage cookies through your browser settings. However, disabling certain cookies may limit your ability to use some Platform features. Most browsers allow you to:

• View and delete cookies
• Block third-party cookies
• Block cookies from specific sites
• Block all cookies (not recommended)
• Delete all cookies when closing the browser

For more information about managing cookies, visit your browser's help documentation.

7. Your Privacy Rights Under Philippine Law

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights regarding your personal information:

7.1 Right to Be Informed

You have the right to be informed about the collection, use, and processing of your personal information. This Privacy Policy fulfills our obligation to inform you of our data practices.

7.2 Right to Access

You have the right to access your personal information held by smjili. You can view and download most of your personal information through your account dashboard. For additional information, submit a request to our Data Protection Officer.

7.3 Right to Rectification

You have the right to correct inaccurate, incomplete, or outdated personal information. You can update most information directly through your account settings or by contacting customer support.

7.4 Right to Erasure or Blocking

You have the right to request deletion or blocking of your personal information in certain circumstances, such as when:

• The information is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal basis for processing
• The information was unlawfully processed
• Erasure is required by law

However, we may retain certain information as required by law (e.g., for tax purposes, regulatory compliance, fraud prevention) or to establish, exercise, or defend legal claims.

7.5 Right to Object

You have the right to object to the processing of your personal information for direct marketing purposes. You can opt out of promotional communications by clicking the "unsubscribe" link in marketing emails or adjusting your communication preferences in your account settings.

7.6 Right to Data Portability

You have the right to obtain a copy of your personal information in a structured, commonly used, and machine-readable format, and to transmit it to another service provider where technically feasible.

7.7 Right to File a Complaint

If you believe your privacy rights have been violated, you have the right to file a complaint with smjili's Data Protection Officer or with the National Privacy Commission of the Philippines.

7.8 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond to your request within fifteen (15) days. Identity verification may be required to process your request.

8. Data Retention Policy

smjili retains your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, and business requirements:

8.1 Active Account Data

While your account remains active, we retain your personal information to provide Services, maintain transaction records, and comply with regulatory obligations.

8.2 Closed Account Data

After account closure, we retain certain information for:

• Five (5) years: Transaction records, identity verification documents, and gaming history (required by PAGCOR regulations and AML laws)
• Ten (10) years: Financial records and tax-related documents (required by Bureau of Internal Revenue regulations)
• Indefinitely: Records related to fraud, disputes, legal claims, or regulatory investigations

8.3 Deletion and Anonymization

After the required retention period expires, personal information is securely deleted or anonymized such that it can no longer identify you. Anonymized data may be retained indefinitely for statistical analysis and research purposes.

9. International Data Transfers

smjili primarily processes and stores personal information within the Philippines. However, some of our service providers and technology partners may be located outside the Philippines, which may involve transferring your personal information to countries with different data protection standards.

When we transfer personal information internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by the National Privacy Commission
• Data processing agreements with strict security and confidentiality requirements
• Transfers only to countries with adequate data protection laws
• Compliance with cross-border data transfer requirements under the Data Privacy Act

10. Protection of Minors

smjili Services are strictly intended for individuals who are twenty-one (21) years of age or older. We do not knowingly collect, use, or disclose personal information from individuals under the legal gambling age.

If we become aware that we have inadvertently collected personal information from a minor, we will take immediate steps to delete such information from our systems and terminate the associated account. Parents or guardians who believe their child has provided personal information to smjili should contact us immediately at [email protected].

We implement age verification procedures including document verification and third-party age validation services to prevent minors from accessing our Platform.

11. Changes to This Privacy Policy

smjili reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this Policy, we will:

• Update the "Last Revised" date at the top of this Policy
• Notify you via email to your registered email address
• Display a prominent notice on the Platform
• In some cases, request your renewed consent for continued data processing

Your continued use of smjili Services after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the modified Policy, you must discontinue use of the Platform and close your account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

12. Contact Information and Data Protection Officer

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