atjili Privacy Policy

atjili ("we", "us", "our") operates the online gaming platform accessible at atjili.cam (the "Platform"). We understand that your personal information is important to you, and we take our responsibility as a data controller seriously. This Privacy Policy describes in plain, clear terms how atjili handles personal data relating to individuals who visit, register, and play on the Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its implementing rules and regulations, and the issuances of the National Privacy Commission of the Philippines ("NPC"). Where atjili processes data of individuals located in other jurisdictions, we apply the privacy standards of the applicable local law in addition to the baseline protections described in this Policy.

By registering an account with atjili, using the Platform, or providing personal information to atjili in any manner, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy applies to all personal data collected and processed by atjili in connection with the operation of the Platform, including:

• Visitors who browse the atjili Platform without registering an account.
• Individuals who initiate but do not complete the atjili registration process.
• Registered players holding an active atjili account.
• Former players whose accounts have been closed or whose data is retained by atjili in accordance with legal obligations.
• Individuals who contact atjili customer support, whether or not they hold a registered account.

This Policy does not apply to the data practices of third-party game providers, payment processors, or other service providers who operate independently and have their own privacy policies. atjili encourages players to review the privacy practices of any third-party service they interact with.

atjili collects the following categories of personal data, depending on the nature of your interaction with the Platform:

• Full legal name
• Date of birth
• Email address
• Mobile phone number
• Username chosen at registration
• Government-issued identity document details (where required for verification)
• Proof of address documentation (where required for enhanced verification)

• Deposit and withdrawal transaction records including amounts, dates, and payment method references
• GCash, Maya, BPI, BDO, Metrobank, UnionBank, Coins.ph, and other payment account identifiers (e.g., mobile number linked to GCash)
• PHP wallet balance history
• Bonus and promotional credit history
• Chargeback and dispute records where applicable

• Game session records including game titles played, wager amounts, outcomes, and session duration
• Sports betting records including selections, stake amounts, and outcomes
• Bonus utilization and wagering requirement completion records
• Responsible gaming tool settings including deposit limits and self-exclusion status

• IP address and approximate geographic location derived therefrom
• Device type, operating system, and browser version
• Session login timestamps and duration
• Pages visited within the Platform and navigation patterns
• Cookie identifiers and similar tracking technology data (see Section 7)

• Records of communications between you and atjili customer support, including chat transcripts and email correspondence
• Feedback and survey responses voluntarily submitted to atjili
• Marketing communication preferences

atjili collects personal data through the following means:

• Directly from you: When you register an account, complete identity verification, make a deposit or withdrawal, contact customer support, update your account settings, or respond to surveys and promotions.
• Automatically through technology: Through cookies, web beacons, log files, and similar tracking technologies when you access and navigate the Platform (see Section 7 for details).
• From payment providers: When you make a deposit via GCash, Maya, bank transfer, or another payment channel, the payment provider shares transaction confirmation data with atjili to facilitate crediting of your PHP wallet.
• From identity verification services: Where atjili uses third-party identity verification or age verification service providers to confirm the accuracy of the documents you submit.
• From anti-fraud and AML services: atjili may receive data from third-party risk and compliance service providers to satisfy anti-money laundering obligations and prevent fraud.

The table below describes the primary purposes for which atjili processes your personal data, together with the legal basis for each processing activity under the Data Privacy Act of 2012:

atjili does not sell, rent, or trade your personal data to third-party advertisers or marketers. atjili shares personal data only in the following circumstances:

atjili engages third-party service providers who process personal data on atjili's behalf under written data processing agreements that require them to implement appropriate technical and organizational security measures. Categories of service provider include: payment processors and e-wallet operators (GCash, Maya, BPI, BDO, and others); identity and age verification providers; fraud detection and AML compliance services; cloud hosting and data storage providers; game content providers (where required for game operation and integrity); and customer support platform operators.

atjili may disclose personal data to regulatory authorities, law enforcement agencies, courts, or other government bodies in the Philippines where required to do so by law, court order, or regulatory direction. This includes disclosures to PAGCOR in connection with atjili's gaming operations, and to the Anti-Money Laundering Council (AMLC) and Bangko Sentral ng Pilipinas (BSP) in connection with applicable financial regulations.

In the event of a merger, acquisition, restructuring, or sale of all or part of atjili's business or assets, personal data held by atjili may be transferred to the acquiring entity as part of that transaction. In such circumstances, atjili will notify affected players through the Platform and by email before any personal data is transferred and subjected to a different privacy policy.

atjili uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device by the Platform when you visit. Cookies allow atjili to recognize your device, maintain your session, and remember preferences.

• Essential Cookies: Necessary for the Platform to function. These include session authentication cookies that keep you logged in while you play. Disabling these cookies will prevent you from using the Platform.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming limit settings. Disabling these may reduce the functionality of your Platform experience.
• Analytics Cookies: Collect aggregated data about how players use the Platform — page views, session duration, navigation paths — to help atjili improve the Platform. These cookies do not identify you personally.
• Security Cookies: Used to detect and prevent fraudulent activity, account takeover attempts, and other security threats.

You may configure your browser to block or delete cookies. Note that blocking essential cookies will prevent you from accessing the atjili Platform. Analytics and functional cookies can be disabled without affecting your ability to play, though some features may behave differently. Browser-specific instructions for managing cookies are available through the help section of your browser.

atjili implements appropriate technical and organizational security measures to protect personal data from unauthorized access, disclosure, alteration, loss, or destruction. Key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between players' devices and the atjili Platform.
• Encryption at rest for sensitive data stored on atjili servers, including financial records and identity documents.
• Access controls limiting employee access to personal data to those with a legitimate business need, on a role-based least-privilege basis.
• Regular security audits and penetration testing by qualified information security professionals.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, containing, and reporting personal data breaches in accordance with NPC requirements.

While atjili takes all reasonable steps to protect your personal data, no internet-based platform can guarantee absolute security. Players are reminded to maintain the confidentiality of their own login credentials and to enable two-factor authentication on their atjili account for additional protection.

atjili retains personal data for as long as necessary to fulfil the purposes for which it was collected, to maintain the player's account in active status, and to comply with applicable legal and regulatory retention requirements. The following general retention periods apply:

• Account data and identity documents: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements under Republic Act No. 9160 (the Anti-Money Laundering Act) and its amendments.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity records: Retained for three (3) years from the date of each session, unless longer retention is required for dispute resolution or regulatory purposes.
• Customer support communications: Retained for two (2) years from the date of the last communication.
• Marketing preference data: Retained until you withdraw consent for marketing communications.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with an identifiable individual.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by atjili. These rights may be exercised by contacting the atjili Data Protection Officer at the details in Section 15.

To exercise any of these rights, submit a written request to the atjili Data Protection Officer using the contact details in Section 15. atjili will respond to verified data subject requests within thirty (30) calendar days of receipt. Where requests are complex or numerous, this period may be extended by up to a further thirty (30) days with notice to the requestor.

atjili may require identity verification before processing a data subject request to ensure that data is not disclosed to unauthorized parties. Requests that are manifestly unfounded, excessive, or repetitive may be refused or subject to a reasonable processing fee.

The atjili Platform is strictly restricted to individuals aged 21 years and above. atjili does not knowingly collect personal data from individuals below the age of 21. The minimum age is enforced through the registration process, which requires declaration of date of birth, and through identity verification procedures which may be applied at any time.

If atjili becomes aware that personal data has been collected from an individual below the age of 21 without appropriate parental consent (or below such other minimum age as required by applicable law), atjili will take immediate steps to delete that information and close the associated account. If you believe that atjili may have inadvertently collected data from an underage individual, please contact the Data Protection Officer immediately.

Some of atjili's service providers — including cloud infrastructure providers, game studios, and fraud prevention services — may be located outside the Philippines. Where personal data is transferred to a recipient in a country that does not have an equivalent level of data protection law, atjili implements appropriate safeguards to ensure that the personal data remains protected to a standard consistent with the Data Privacy Act of 2012.

Safeguards for international transfers may include standard contractual clauses approved by the National Privacy Commission, binding corporate rules, or transfers to jurisdictions that the NPC has recognized as providing adequate data protection. Players may request information about the specific safeguards applied to their data by contacting the Data Protection Officer.

The atjili Platform may contain references to or integrations with third-party services (for example, payment gateways or game providers). When you interact with a third-party service through the Platform, your use of that service is subject to the privacy policy and terms of the third party, not this Privacy Policy.

atjili is not responsible for the data practices of third parties. Players are encouraged to review the privacy policies of any service provider before sharing personal information with them, including payment service providers such as GCash and Maya.

atjili reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, changes in applicable law, or for other operational reasons. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this document.
• Display a prominent notice on the atjili Platform for a reasonable period before the changes take effect.
• Where required by law, send email notification to registered players at their registered email address.

Continued use of the atjili Platform after the effective date of any amendment to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the revised Policy, you must cease using the Platform and may request account closure.

The current version of this Privacy Policy is always available at atjili.cam/privacy-policy. atjili recommends that players review this Policy periodically.

atjili has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Privacy Policy and applicable data protection law. If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how atjili handles your personal data, please contact:

atjili Data Protection Officer
Email: [email protected] (Subject line: "Data Privacy — DPO Request")

atjili's support team is available 24 hours a day, seven days a week. Data subject rights requests and privacy-related queries are handled by the DPO team and will be acknowledged within 48 hours of receipt. Substantive responses to data subject rights requests will be provided within thirty (30) calendar days in accordance with NPC requirements.