Privacy Policy – eejj Casino Philippines

1. Introduction & Data Controller

eejj Casino, accessible at https://eejj.asia, is the data controller responsible for the personal data collected from users of the eejj platform ("Platform"). eejj is committed to protecting the privacy and security of personal data belonging to Filipino players and all other users, in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and all applicable regulations issued by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy applies to all personal data processed in connection with your use of the eejj Platform, including the website, account registration, gaming activity, payment processing, customer support interactions, and marketing communications.

2. Personal Data We Collect

eejj collects the following categories of personal data, to the extent necessary and proportionate for the stated purposes:

• Identity Data: Full legal name, date of birth, nationality, government-issued ID type and number (passport, SSS, UMID, PhilSys, driver's licence).
• Contact Data: Registered email address, Philippine mobile number, residential address (city/province level).
• Account Data: Username, encrypted password hash, account registration date, account status, and responsible gaming settings.
• Financial Data: Payment method type (e.g., GCash, PayMaya, BPI, BDO, Metrobank), transaction reference numbers, deposit and withdrawal history, and PHP balance records. eejj does not store full GCash PINs, bank account passwords, or card CVV numbers.
• Gaming Data: Game history, bet amounts, session duration, game types played, and bonus redemption records.
• KYC Documentation: Scanned or photographed copies of government-issued IDs, selfie verification images, and — where required by anti-money-laundering regulations — proof of source of funds documentation.
• Technical Data: IP address, device type, operating system, browser type and version, time zone, and session timestamps.
• Communications Data: Records of customer support interactions via live chat and email, including the content of those communications.

3. How We Collect Personal Data

eejj collects personal data through the following means:

• Direct submission: Information you provide during account registration, KYC verification, deposit/withdrawal requests, and support interactions.
• Automated technical collection: Technical data collected automatically when you access the Platform, including IP addresses, browser data, and session activity logs.
• Third-party payment processors: Transaction confirmation data received from GCash, PayMaya, InstaPay, PESONet, and bank partners in connection with deposit and withdrawal processing.
• Identity verification providers: Results of identity and document verification checks conducted through eejj's KYC service partners, where applicable.

4. Legal Basis for Processing

eejj processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing necessary to create and maintain your eejj account and fulfil the services described in the Terms & Conditions.
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, anti-money-laundering obligations under RA 9160 (as amended), and NPC data governance requirements.
• Legitimate interests: Processing for fraud detection, platform security, abuse prevention, and responsible gaming monitoring, where our legitimate interests are not overridden by your fundamental rights.
• Consent: Processing for direct marketing communications (promotional emails and SMS), where you have given explicit, freely-withdrawable consent. Withdrawal of consent does not affect prior processing.

5. How We Use Your Personal Data

eejj uses collected personal data for the following specific purposes:

• Creating, managing, and securing your eejj Account.
• Processing deposits, withdrawals, and all PHP financial transactions on the Platform.
• Conducting KYC identity verification as required by PAGCOR and RA 9160.
• Providing customer support and responding to account queries and disputes.
• Monitoring gaming activity for responsible gaming purposes, including detection of patterns consistent with problem gambling.
• Detecting and preventing fraud, money laundering, multi-accounting, and prohibited conduct as defined in the Terms & Conditions.
• Improving the Platform's features, game library, and user experience based on aggregated, anonymised usage analytics.
• Sending service notifications (account activity, deposit confirmations, withdrawal status updates) via registered email and mobile number.
• Sending promotional communications to Players who have opted in to marketing, subject to the right to opt out at any time.
• Complying with any lawful regulatory, law enforcement, or judicial request for data disclosure.

6. Sharing Your Personal Data

eejj does not sell, rent, or trade your personal data to third parties. eejj may share personal data with the following categories of recipient strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, and PESONet receive the minimum data necessary to process transactions.
• KYC and identity verification providers: Where eejj uses a third-party service for document verification, identity data is shared solely for verification purposes under a data processing agreement.
• Game content providers: Game studios and aggregators receive session data (Player ID, bet amounts) necessary to deliver and settle games fairly.
• Regulatory and law enforcement authorities: eejj will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, and Philippine law enforcement authorities where legally required or where disclosure is necessary to prevent or report a crime.
• Fraud prevention and security services: Technical and identity data may be shared with fraud detection service providers acting as data processors under written agreements incorporating DPA-compliant data protection obligations.

All third-party recipients who process personal data on eejj's behalf are bound by contractual data processing agreements that require them to process data only as instructed by eejj and in compliance with applicable Philippine privacy law.

7. Cookies & Tracking Technologies

eejj uses strictly necessary session cookies to maintain your authenticated session while you are logged in to the Platform. These cookies are essential to the secure operation of the eejj Platform and cannot be disabled without disrupting core functionality.

eejj may additionally use analytical cookies to collect aggregated, anonymised data about how players interact with the Platform. These are not linked to your personal identity and are used solely for platform improvement. You may manage non-essential cookies through your browser settings. Detailed cookie information is available in the Platform's cookie notice displayed on first access.

8. Data Retention

eejj retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law:

• Active accounts: All personal, financial, and gaming data is retained throughout the life of your active eejj Account.
• Closed accounts: Following account closure, eejj retains identity and transaction data for a minimum of seven (7) years, as required by RA 9160 (Anti-Money Laundering Act) and PAGCOR regulatory standards.
• KYC documents: Retained for the period of account operation plus seven (7) years post-closure.
• Customer support records: Retained for three (3) years following resolution of the relevant interaction.
• Marketing consent records: Retained for the duration of the marketing relationship and three (3) years thereafter as proof of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised in accordance with NPC-approved disposal standards.

9. Data Security

eejj implements a layered security architecture to protect personal data against unauthorised access, disclosure, alteration, and destruction. Technical and organisational measures include:

• 256-bit SSL/TLS encryption for all data in transit between user devices and eejj servers.
• AES-256 encryption for personal and financial data at rest on eejj infrastructure.
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis.
• Regular third-party penetration testing and vulnerability assessments.
• Multi-factor authentication for all eejj staff accessing systems containing personal data.
• Automated intrusion detection and real-time security monitoring.

No security system is impenetrable. In the event of a personal data breach likely to cause serious harm, eejj will notify the NPC and affected data subjects within 72 hours, as required by NPC Circular No. 16-03.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, Filipino data subjects have the following rights with respect to their personal data held by eejj:

• Right to be informed: The right to know what personal data eejj collects and how it is used — fulfilled by this Privacy Policy.
• Right of access: The right to request a copy of the personal data eejj holds about you.
• Right to correction: The right to request correction of inaccurate, incomplete, or outdated personal data.
• Right to erasure / right to be forgotten: The right to request deletion of personal data, subject to retention obligations under applicable law.
• Right to object: The right to object to the processing of your personal data for direct marketing or based on eejj's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, machine-readable format where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, contact eejj's Data Protection Officer at [email protected] with the subject line "Data Subject Request." eejj will respond within fifteen (15) business days.

11. Children's Privacy

The eejj Platform is strictly intended for individuals aged 21 years and above, in compliance with PAGCOR regulations. eejj does not knowingly collect personal data from individuals under the age of 21. If eejj discovers that an account has been registered by or on behalf of a person under 21, the account will be immediately closed, all associated data deleted, and any deposits returned in accordance with regulatory requirements.

12. Cross-Border Data Transfers

eejj's primary data processing infrastructure is located within or in proximity to the Philippines. Where eejj uses third-party service providers whose infrastructure is located outside the Philippines (such as certain cloud hosting providers or game studios), eejj ensures that any cross-border transfer of personal data is conducted under contractual arrangements that provide a standard of protection at least equivalent to the Data Privacy Act of 2012, as required by Section 21 of RA 10173 and NPC implementing rules.

13. Third-Party Links

The eejj Platform does not contain links to third-party websites or services outside of the eejj platform ecosystem. This Privacy Policy applies solely to personal data processed by eejj in connection with your use of the eejj Platform at https://eejj.asia.

14. Amendments to This Privacy Policy

eejj reserves the right to update or revise this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or our data processing practices. Material changes will be notified to registered Players via the email address on file at least seven (7) days before the revised policy takes effect. The "Last Updated" date at the top of this document will be revised accordingly. Continued use of the eejj Platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

15. Contact & Data Protection Officer

For any privacy-related queries, data subject rights requests, or concerns about eejj's handling of your personal data, please contact the eejj Data Protection Officer at: [email protected]. Include "Privacy" or "Data Subject Request" in your subject line for priority routing. Our team is available 24/7 and responds to privacy queries within fifteen (15) business days.

If you are not satisfied with eejj's response, you may escalate your complaint to the National Privacy Commission of the Philippines (NPC) through the official NPC channels.