xbjili Privacy Policy

1 Introduction

xbjili ("xbjili," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our online gaming platform. We understand that trust is the foundation of any relationship between a player and their gaming platform, and we take our data protection obligations seriously.

This Privacy Policy ("Policy") describes how xbjili collects, uses, stores, shares, and protects personal data relating to registered players, prospective players, and visitors to the xbjili website (collectively, "you" or "Data Subject"). It has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy should be read together with our Terms & Conditions, which govern your overall use of the xbjili platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, xbjili acts as the Personal Information Controller (PIC) with respect to the personal data of its players and website visitors. As PIC, xbjili determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

xbjili has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at any time using the contact details provided in Section 14 of this Policy.

3 Data We Collect

xbjili collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include the following:

xbjili does not intentionally collect sensitive personal information (as defined under RA 10173) such as health data, religious beliefs, or political affiliations, unless specifically required by law or regulation (e.g., for responsible gaming assessments).

4 How We Collect Data

xbjili collects personal data through the following channels:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Technical data collected automatically when you visit xbjili.cc, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 9);
• Third-party sources: Identity verification data from KYC/AML service providers; payment data from GCash, PayMaya, BPI, BDO, and Metrobank; fraud prevention data from security partners;
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with licensing compliance or investigations.

5 Purpose & Legal Basis for Processing

xbjili processes your personal data only where a lawful basis exists under the Philippine Data Privacy Act. The primary purposes and their corresponding legal bases are as follows:

• Account registration and management — necessary for the performance of our contract with you (Terms & Conditions);
• Identity verification (KYC) and age verification — compliance with legal obligations under Philippine gaming regulations and AMLA;
• Processing deposits and withdrawals — necessary for the performance of our contract with you;
• Fraud prevention and security monitoring — legitimate interests of xbjili and compliance with legal obligations;
• Responsible gaming monitoring and intervention — compliance with regulatory requirements and protection of your vital interests;
• Customer support — necessary for the performance of our contract with you;
• Marketing communications — based on your explicit consent, which you may withdraw at any time;
• Legal and regulatory compliance — compliance with applicable Philippine laws, including AMLA reporting obligations;
• Platform improvement and analytics — legitimate interests of xbjili, subject to your rights under this Policy.

6 Data Sharing & Disclosure

xbjili does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay — to process your deposits and withdrawals;
• KYC/AML service providers: Identity verification and anti-money laundering screening partners engaged by xbjili;
• Game software providers: Third-party game studios whose games are available on the xbjili platform, to the extent necessary for game operation and dispute resolution;
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection partners operating under strict data processing agreements;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where required by law;
• Legal and professional advisors: Lawyers, auditors, and compliance consultants engaged by xbjili, subject to professional confidentiality obligations;
• Business successors: In the event of a merger, acquisition, or sale of xbjili's business, your data may be transferred to the successor entity, subject to equivalent privacy protections.

All third-party service providers engaged by xbjili are required to process your personal data only on xbjili's documented instructions and in accordance with applicable Philippine data protection law.

7 Data Retention

xbjili retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act;
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent;
• Technical and log data: Retained for up to twelve (12) months from collection.

Upon expiry of the applicable retention period, xbjili will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless retention is required for ongoing legal proceedings or regulatory investigations.

8 Data Security

xbjili implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and xbjili servers;
• Encryption at rest for sensitive data stored in xbjili databases;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Two-factor authentication (2FA) available for all player accounts;
• Regular security audits and penetration testing of the xbjili platform;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

9 Cookies & Tracking Technologies

xbjili uses cookies and similar tracking technologies on the xbjili.cc website to enhance your experience, maintain your session, and analyze platform usage. The types of cookies we use are as follows:

• Strictly necessary cookies: Essential for the operation of the xbjili platform, including session management and security. These cannot be disabled;
• Functional cookies: Remember your preferences, such as language settings and responsible gaming limits;
• Analytics cookies: Help xbjili understand how players use the platform so we can improve it. Data collected is aggregated and anonymized where possible;
• Security cookies: Used for fraud detection and prevention purposes.

xbjili does not use third-party advertising or behavioral tracking cookies. You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may affect the functionality of the xbjili platform.

10 Your Data Privacy Rights RA 10173

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by xbjili. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

xbjili will respond to all verified data privacy requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with prior notice to you.

11 Minors & Age Policy

xbjili employs age verification procedures during the KYC process to confirm that all registered players meet the minimum age requirement of twenty-one (21) years, in accordance with Philippine gaming regulations. If you believe that a minor has registered on xbjili, please contact our support team immediately.

12 Cross-Border Data Transfers

In the course of operating the xbjili platform, your personal data may be transferred to and processed in countries outside the Philippines — for example, where our game software providers or cloud infrastructure partners are located. xbjili ensures that any such cross-border transfer of personal data is carried out in compliance with Section 21 of the Philippine Data Privacy Act and the NPC's rules on cross-border data flows.

Specifically, xbjili will only transfer personal data outside the Philippines where:

• The recipient country provides an adequate level of data protection as determined by the NPC; or
• Appropriate safeguards are in place, such as contractual clauses approved by the NPC; or
• The transfer is necessary for the performance of our contract with you (e.g., processing a payment through an international payment network).

13 Changes to This Policy

xbjili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, xbjili will notify registered players by email or through a prominent notice on the xbjili platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically. Your continued use of the xbjili platform following the effective date of any revised Policy constitutes your acknowledgment of the changes.

14 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or xbjili's handling of your personal data, please contact our Data Protection Officer. Our support team is available 24/7 via live chat on the xbjili platform, and our DPO will respond to formal data privacy requests within the timeframes stated in this Policy.

If you are not satisfied with xbjili's response to your data privacy complaint, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.