23jollyph Privacy Policy

1. Introduction & Scope

23jollyph ("we," "us," or "our") operates the online gaming platform accessible at https://23jollyph.one (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered players, visitors, and former account holders across the Philippines.

This Privacy Policy describes how 23jollyph collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform. It also explains the rights you have under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and how to exercise them.

By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the Platform and contact us to close your account.

This policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your relationship with 23jollyph.

2. Information We Collect

23jollyph collects personal information through several channels. The categories of data we collect include:

We collect only the minimum personal data necessary for the purposes described in this policy. We do not collect sensitive personal information such as racial or ethnic origin, political opinions, or health data unless specifically required by law.

3. How We Use Your Information

23jollyph uses your personal information for the following purposes:

• Account management: To create, verify, and maintain your player account, including identity verification and KYC compliance;
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver bonuses and promotions;
• Regulatory compliance: To fulfill our obligations under PAGCOR regulations, anti-money laundering (AML) laws, and the Philippine Data Privacy Act;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, and unauthorized account access;
• Responsible gaming: To monitor gaming patterns and enforce responsible gaming tools such as deposit limits and self-exclusion;
• Customer support: To respond to your inquiries, resolve disputes, and improve our support services;
• Platform improvement: To analyze usage patterns, troubleshoot technical issues, and enhance the overall player experience;
• Marketing communications: To send you promotional offers and updates, where you have provided consent and not opted out.

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 23jollyph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration, including account management and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AML obligations, and tax reporting requirements;
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications. You may withdraw consent at any time by contacting our support team.

5. Sharing Your Information

23jollyph does not sell or rent your personal data to third parties. We may share your information with the following categories of recipients only where necessary and under appropriate data protection agreements:

• Game providers: JILI Games and other licensed game providers may receive limited technical data necessary to deliver their games on our Platform;
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers receive financial data necessary to process your transactions;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law;
• Technology service providers: Cloud hosting, cybersecurity, and analytics providers who process data on our behalf under strict contractual data processing agreements;
• Professional advisors: Legal counsel, auditors, and compliance consultants where necessary for the operation of our business.

All third parties with whom we share personal data are required to maintain appropriate security standards and to use the data only for the specified purpose. We do not transfer personal data outside the Philippines except where required by law or where adequate protections are in place.

6. Cookies & Tracking Technologies

23jollyph uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are:

• Essential cookies: Required for the Platform to function, including session management and security tokens. These cannot be disabled without affecting Platform functionality;
• Preference cookies: Store your language preferences, display settings, and other personalization choices;
• Analytics cookies: Collect anonymized data about how players use the Platform to help us identify areas for improvement. No personally identifiable information is shared with analytics providers;
• Security cookies: Help detect and prevent fraudulent activity and unauthorized access attempts.

We do not use third-party advertising or retargeting cookies. You can manage or disable non-essential cookies through your browser settings. Note that disabling essential cookies may prevent you from accessing certain features of the Platform.

7. Data Security

23jollyph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS 1.3 encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data stored at rest, including passwords and financial information;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing by independent cybersecurity professionals;
• Strict access controls ensuring that only authorized personnel can access personal data, on a need-to-know basis;
• Incident response procedures to detect, contain, and notify affected individuals of any data breaches in accordance with NPC requirements.

While we take all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorized access.

8. Data Retention

23jollyph retains your personal data for as long as necessary to fulfill the purposes described in this policy, subject to the following minimum retention periods required by Philippine law:

• Account and identity data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AML obligations;
• Financial transaction records: Retained for a minimum of five (5) years in compliance with the Anti -Money Laundering Act;
• Gaming activity logs: Retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes;
• Customer support communications: Retained for two (2) years following resolution of the relevant inquiry;
• Marketing consent records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures. Where data is anonymized rather than deleted, it may be retained indefinitely for statistical and analytical purposes as it can no longer be linked to any individual.

9. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 23jollyph:

• Right to be informed: You have the right to know what personal data we collect, how we use it, and with whom we share it — which is the purpose of this Privacy Policy;
• Right of access: You may request a copy of the personal data we hold about you at any time. We will respond to verified access requests within fifteen (15) business days;
• Right to rectification: If any of your personal data is inaccurate or incomplete, you have the right to request correction. You may update basic account details directly through your account settings;
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where your rights override those interests;
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to lodge a complaint: If you believe your data rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer at: [email protected]. We may require you to verify your identity before processing your request.

10. Children & Minors

The 23jollyph Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on our Platform, please notify us immediately at [email protected] so that we can investigate and take appropriate action.

Parents and guardians are encouraged to use parental control tools and to monitor the online activities of minors in their care to prevent underage access to gambling platforms.

11. Changes to This Privacy Policy

23jollyph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes to this policy, we will:

• Update the "Last Updated" date at the top of this page;
• Display a prominent notice on the Platform informing players of the update;
• Where required by law or where changes are significant, notify registered players via their registered email address.

Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how 23jollyph protects your personal data.

12. Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 directly on the Platform
• Support Hours: 06:00–02:00 PST daily

We aim to respond to all privacy-related inquiries within fifteen (15) business days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent authority responsible for enforcing the Data Privacy Act of 2012.

This Privacy Policy was last reviewed and approved in January 2026 and is effective immediately for all users of the 23jollyph Platform.