Effective Date: January 1, 2025
1. Introduction and Scope
This Privacy Policy ("Policy") describes how anjili ("anjili," "we," "us," or "our") collects, uses, processes, discloses, stores, transfers, and protects personal information and personal data in connection with your access to and use of the anjili online gaming platform, website, mobile applications, and all associated services (collectively, the "Platform"). This Policy applies to all users, visitors, and players who access or use the Platform from the Republic of the Philippines and other permitted jurisdictions. By creating an account with anjili, accessing the Platform, or using any of our services, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.
anjili is committed to protecting your privacy and complying with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as other applicable Philippine data protection laws and regulations promulgated by the National Privacy Commission (NPC). We recognize the importance of maintaining the confidentiality, integrity, and security of your personal information, and we implement appropriate organizational, technical, and physical security measures to safeguard the personal data we collect and process.
This Privacy Policy should be read in conjunction with our Terms and Conditions, Responsible Gaming Policy, and any other policies, terms, or notices provided to you in connection with specific services or features offered on the Platform. If there is any conflict between this Privacy Policy and any other agreement or policy, the terms most favorable to your privacy rights shall prevail. We reserve the right to modify, update, or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal or regulatory requirements, or business operations. Any material changes will be communicated to you through email notification or prominent notice on the Platform, and your continued use of the Platform following such notification constitutes your acceptance of the revised Privacy Policy.
2. Information We Collect
2.1 Information You Provide Directly
When you register for an anjili account, we collect personal information that you voluntarily provide to us during the registration process and throughout your use of the Platform. This information includes, but is not limited to:
- Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers as required for identity verification and regulatory compliance.
- Contact Information: Email address, mobile phone number, residential address, postal code, and any other contact details you provide for account management and communication purposes.
- Account Credentials: Username, password, security questions and answers, and any other authentication information necessary for accessing and securing your account.
- Financial Information: Payment method details including bank account numbers, e-wallet information (GCash, Maya), credit or debit card numbers (last four digits only), payment processor account details, transaction history, deposit and withdrawal records, and billing information.
- Verification Documents: Copies of government-issued identification documents (passport, driver's license, national ID), proof of address documents (utility bills, bank statements), proof of payment method ownership, selfie photographs for facial verification, and any other documentation required for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.
- Communication Content: Messages, inquiries, feedback, complaints, and correspondence you send to our customer support team through live chat, email, or other communication channels, including any attachments or supporting documentation.
- Marketing Preferences: Your communication preferences, subscription choices for promotional materials, consent records for marketing communications, and opt-in or opt-out decisions regarding various types of notifications.
2.2 Information Collected Automatically
When you access and use the anjili platform, we automatically collect certain information about your device, browsing behavior, and interactions with the Platform through the use of cookies, web beacons, pixels, log files, and similar tracking technologies. This automatically collected information includes:
- Device Information: Device type, model, manufacturer, operating system and version, browser type and version, screen resolution, unique device identifiers (such as IMEI, UDID, or advertising ID), hardware configuration, and other technical specifications of your device.
- Usage Information: Pages viewed, features accessed, links clicked, search queries entered, games played, bet amounts and outcomes, session duration, frequency of visits, navigation paths, in-game behavior, feature usage patterns, and other interactions with Platform content and functionality.
- Technical Data: IP address, Internet Service Provider (ISP), geolocation data (country, region, city level based on IP address), referring and exit pages, timestamps of access, clickstream data, error logs, system performance data, and other technical information generated during your use of the Platform.
- Cookie Data: Information stored in cookies and similar technologies placed on your device, including session identifiers, user preferences, authentication tokens, language settings, security parameters, and advertising identifiers. For more information about our use of cookies, please refer to our Cookie Policy available on the Platform.
2.3 Information from Third-Party Sources
anjili may receive personal information about you from third-party sources in order to verify your identity, prevent fraud, comply with legal obligations, or enhance our services. These third-party sources include:
- Payment Processors: Financial institutions, banks, e-wallet providers (GCash, Maya), payment gateway services, and other payment processing entities that facilitate deposit and withdrawal transactions on the Platform.
- Identity Verification Services: Third-party identity verification and authentication service providers that conduct KYC checks, document verification, facial recognition, biometric verification, and fraud detection screening on our behalf.
- Gaming Providers: Licensed game content providers and live dealer service providers who supply gaming content on the Platform and may share information about your gaming activity, bet history, and gameplay interactions.
- Regulatory Authorities: Government agencies, gaming regulators such as the Philippine Amusement and Gaming Corporation (PAGCOR), law enforcement authorities, and other regulatory bodies that may provide information relevant to compliance, investigations, or legal obligations.
- Credit Reference Agencies: Credit bureaus and fraud prevention agencies that provide information for identity verification, fraud detection, creditworthiness assessment, and risk management purposes, to the extent permitted by law.
- Marketing Partners: Affiliate partners, advertising networks, and marketing service providers who may share information about referrals, campaign performance, conversion data, and attribution information when you access the Platform through promotional channels.
3. How We Use Your Information
anjili processes your personal information for specific, explicit, and legitimate purposes in connection with the operation of the Platform and the provision of our gaming services. We use your personal information for the following purposes:
3.1 Account Management and Service Provision
- Creating, maintaining, and administering your anjili user account and profile.
- Processing your registration, verifying your identity and age, and completing account setup procedures.
- Providing access to gaming services, features, and functionalities available on the Platform.
- Processing, recording, and settling bets, wagers, and gaming transactions.
- Managing deposits, withdrawals, and financial transactions through various payment methods.
- Calculating, crediting, and paying winnings and bonuses to your account balance.
- Maintaining accurate records of your gaming activity, transaction history, and account balance.
- Providing customer support, responding to inquiries, resolving complaints, and addressing technical issues.
3.2 Compliance and Legal Obligations
- Verifying your identity, age (21+ requirement), and eligibility to use the Platform in accordance with legal and regulatory requirements.
- Conducting Know Your Customer (KYC) procedures, Anti-Money Laundering (AML) checks, and fraud prevention screening as required by PAGCOR regulations and Philippine law.
- Detecting, preventing, and investigating fraudulent activity, unauthorized access, security breaches, and violations of our Terms and Conditions.
- Complying with legal obligations, regulatory requirements, court orders, subpoenas, and requests from law enforcement or government authorities.
- Maintaining records and documentation required by gaming regulators, tax authorities, and other government agencies.
- Enforcing our Terms and Conditions, policies, and user agreements, including investigating and resolving disputes and violations.
- Implementing responsible gaming measures, processing self-exclusion requests, and identifying problem gambling behavior.
3.3 Platform Improvement and Analytics
- Analyzing user behavior, preferences, and engagement patterns to understand how users interact with the Platform and identify areas for improvement.
- Conducting research, statistical analysis, and data analytics to optimize Platform performance, functionality, and user experience.
- Testing new features, games, and services before full deployment to ensure quality, stability, and user satisfaction.
- Monitoring system performance, identifying technical issues, troubleshooting problems, and maintaining Platform security and stability.
- Personalizing your experience by tailoring content, recommendations, and features based on your preferences, gaming history, and behavior.
- Developing and implementing security measures, fraud detection algorithms, and risk management systems to protect the Platform and users.
3.4 Marketing and Communications
- Sending transactional communications related to your account, including registration confirmation, deposit notifications, withdrawal confirmations, security alerts, and account updates.
- Providing customer support communications, responding to inquiries, and following up on requests or issues you have raised.
- Sending promotional materials, marketing communications, newsletters, special offers, bonuses, and announcements about new games or features, provided you have consented to receive such communications.
- Conducting surveys, requesting feedback, and gathering user opinions to improve our services and understand user satisfaction.
- Administering promotions, contests, tournaments, and loyalty programs, including notifying winners and distributing prizes.
4. Legal Basis for Processing
Under the Data Privacy Act of 2012 and applicable Philippine law, anjili processes your personal information based on the following legal grounds:
- Consent: You have provided explicit, informed, and freely given consent for specific processing activities, such as receiving marketing communications or participating in optional features. You may withdraw your consent at any time through your account settings or by contacting us.
- Contract Performance: Processing is necessary to perform our contract with you under the Terms and Conditions, including providing gaming services, processing transactions, and managing your account.
- Legal Obligation: Processing is required to comply with legal obligations imposed by Philippine law, gaming regulations, tax laws, anti-money laundering requirements, or other applicable legal frameworks.
- Legitimate Interests: Processing is necessary for our legitimate business interests or the legitimate interests of third parties, such as fraud prevention, security monitoring, Platform improvement, and risk management, provided such interests do not override your fundamental rights and freedoms.
5. Information Sharing and Disclosure
anjili does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your personal information with the following categories of recipients under specific circumstances and for legitimate purposes:
5.1 Service Providers and Business Partners
We engage third-party service providers, vendors, contractors, and business partners to perform functions and provide services on our behalf. These entities may have access to your personal information to the extent necessary to perform their contracted services, including:
- Payment processors, banks, and financial institutions for processing deposits, withdrawals, and financial transactions.
- Identity verification and KYC service providers for conducting background checks, document verification, and fraud screening.
- Gaming content providers and platform operators who supply games and live dealer services available on the Platform.
- Cloud hosting providers, data storage services, and IT infrastructure vendors who host and maintain our systems and databases.
- Customer support service providers who assist with handling user inquiries, technical support, and complaint resolution.
- Marketing and analytics service providers for email delivery, SMS messaging, campaign management, and user behavior analysis.
- Security service providers for fraud detection, risk assessment, cybersecurity monitoring, and threat prevention.
All service providers are contractually obligated to protect the confidentiality and security of your personal information, use it only for the specific purposes for which it was disclosed, and comply with applicable data protection laws.
5.2 Regulatory Authorities and Law Enforcement
We may disclose your personal information to government authorities, regulatory bodies, law enforcement agencies, courts, and other public authorities when required or permitted by law, including:
- Complying with legal obligations, subpoenas, court orders, regulatory requests, or government investigations.
- Reporting to PAGCOR and other gaming regulators as required for licensing, compliance, and oversight purposes.
- Cooperating with law enforcement investigations related to fraud, money laundering, terrorism financing, or other criminal activity.
- Responding to requests from tax authorities for reporting and verification of gaming winnings and financial transactions.
- Protecting our legal rights, property, and interests, or defending against legal claims and proceedings.
5.3 Business Transfers
In the event of a merger, acquisition, reorganization, sale of assets, bankruptcy, or other corporate transaction involving anjili, your personal information may be transferred to the acquiring entity or successor organization as part of the business assets. We will notify you of any such transfer and any choices you may have regarding your personal information.
6. Data Security and Protection
anjili implements comprehensive organizational, technical, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, destruction, or loss. Our security measures include, but are not limited to:
- Encryption: Use of industry-standard SSL/TLS encryption protocols to secure data transmission between your device and our servers, and encryption of sensitive data stored in our databases.
- Access Controls: Implementation of strict access control policies, role-based permissions, multi-factor authentication, and regular review of user access privileges to limit data access to authorized personnel only.
- Network Security: Deployment of firewalls, intrusion detection systems, anti-malware software, and network monitoring tools to protect our systems from cyberattacks, unauthorized access attempts, and security threats.
- Secure Data Centers: Storage of data in secure, access-controlled data centers with physical security measures including surveillance cameras, security personnel, and environmental controls.
- Regular Security Audits: Conducting periodic security assessments, vulnerability scans, penetration testing, and third-party security audits to identify and remediate potential security weaknesses.
- Employee Training: Providing regular data protection and security awareness training to all employees and contractors who have access to personal information.
- Incident Response: Maintaining an incident response plan and procedures for detecting, responding to, and recovering from data security breaches or incidents.
Despite our security measures, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information using commercially acceptable means, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account.
7. Data Retention
anjili retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and protect our legitimate business interests. Specific retention periods vary depending on the type of information and the purpose for which it is processed:
- Account Information: Retained for the duration of your active account and for a period after account closure as required by gaming regulations, tax laws, and anti-money laundering requirements, typically five (5) to ten (10) years.
- Transaction Records: Retained for periods specified by Philippine tax law, accounting standards, and regulatory requirements, typically five (5) to ten (10) years from the date of the transaction.
- KYC and Verification Documents: Retained for periods required by anti-money laundering regulations and gaming license conditions, typically five (5) years or longer as mandated by law.
- Communication Records: Customer support communications and correspondence retained for periods necessary to resolve disputes, improve services, and comply with legal obligations, typically three (3) to five (5) years.
- Marketing Communications: Contact information for marketing purposes retained until you withdraw consent or opt out of receiving promotional communications, after which it will be suppressed or deleted.
When personal information is no longer needed for the purposes for which it was collected and there is no legal requirement to retain it, we will securely delete, anonymize, or destroy such information in accordance with our data retention and disposal policies.
8. Your Privacy Rights
Under the Data Privacy Act of 2012, you have certain rights regarding your personal information held by anjili. You may exercise the following rights by contacting our Data Protection Officer using the contact information provided in this Policy:
- Right to Information: The right to be informed about the collection, use, and processing of your personal information, as described in this Privacy Policy.
- Right of Access: The right to obtain confirmation of whether we are processing your personal information and to request a copy of the personal information we hold about you.
- Right to Rectification: The right to request correction of inaccurate, incomplete, or outdated personal information in our records.
- Right to Erasure: The right to request deletion of your personal information under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected, or when you withdraw consent.
- Right to Object: The right to object to the processing of your personal information for direct marketing purposes or when processing is based on legitimate interests.
- Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another controller.
- Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.
Please note that certain rights may be subject to limitations or exceptions under applicable law. We will respond to your requests within the timeframes required by the Data Privacy Act of 2012 and may need to verify your identity before processing your request.
9. Cookies and Tracking Technologies
anjili uses cookies, web beacons, pixels, local storage, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, deliver personalized content, and measure the effectiveness of our marketing campaigns. Cookies are small text files stored on your device when you visit the Platform. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device until deleted or expired).
You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete cookies, or alert you when cookies are being sent. However, disabling cookies may affect the functionality of certain features on the Platform and may prevent you from accessing certain areas or services. For more detailed information about our use of cookies and how to manage your cookie preferences, please refer to our Cookie Policy.
10. Third-Party Links and Services
The anjili platform may contain links to third-party websites, services, applications, or content that are not owned, operated, or controlled by anjili. This Privacy Policy applies only to information collected by anjili through the Platform and does not apply to any third-party websites or services. We are not responsible for the privacy practices, content, or security of any third-party websites or services. We encourage you to review the privacy policies of any third-party websites or services you visit or use.
11. Children's Privacy
The anjili platform and gaming services are intended solely for users who are twenty-one (21) years of age or older. We do not knowingly collect, process, or solicit personal information from individuals under the age of 21. If we become aware that we have collected personal information from a minor, we will take immediate steps to delete such information and terminate the associated account. If you believe that we may have collected information from a minor, please contact us immediately at the contact details provided below.
12. International Data Transfers
Your personal information may be transferred to, stored, and processed in jurisdictions outside the Philippines where our service providers, partners, or affiliated entities are located. When we transfer personal information internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include contractual clauses, adequacy determinations, or other legally recognized transfer mechanisms.
13. Changes to This Privacy Policy
anjili reserves the right to modify, update, or revise this Privacy Policy at any time to reflect changes in our data processing practices, legal or regulatory requirements, technological developments, or business operations. Any material changes to this Privacy Policy will be communicated to you through email notification, prominent notice on the Platform, or pop-up notification when you log in to your account. The "Last Updated" date at the top of this Policy will indicate when the most recent revisions were made. Your continued use of the Platform following notification of changes constitutes your acceptance of the revised Privacy Policy.
14. Contact Information and Data Protection Officer
If you have any questions, concerns, complaints, or requests regarding this Privacy Policy, our data processing practices, or your privacy rights, please contact our Data Protection Officer or customer support team using the following information:
- Data Protection Officer Email: [email protected]
- Customer Support Email: [email protected]
- Live Chat: Available 24/7 through the Platform
- Customer Support Hours: 24 hours a day, 7 days a week (Philippine Standard Time)
We will make reasonable efforts to respond to your inquiries and requests promptly and in accordance with applicable legal timeframes. If you are not satisfied with our response or believe that your data protection rights have been violated, you have the right to file a complaint with the National Privacy Commission of the Philippines.
How anjili Protects Your Privacy
Core principles guiding our data protection practices
Data Minimization
We collect only the personal information necessary to provide our services, comply with legal obligations, and maintain account security.
Secure Storage
Your data is encrypted during transmission and at rest, stored in secure data centers with strict access controls and monitoring.
Transparency
We clearly explain what information we collect, why we collect it, how we use it, and who we share it with in plain language.
User Control
You have the right to access, correct, delete, or export your personal data. Manage your privacy preferences through your account settings.
Legal Compliance
We comply with the Data Privacy Act of 2012, PAGCOR regulations, and all applicable Philippine data protection laws and standards.
Limited Retention
We retain your data only as long as necessary for legitimate purposes and delete or anonymize it when no longer needed.
Questions About Your Privacy?
Our Data Protection Officer and customer support team are available 24/7 to address your privacy concerns, answer questions, and assist with data access requests.
Contact Our Privacy Team