smjili Privacy Policy

1 Introduction

smjili ("we," "us," "our") is committed to protecting the privacy and personal data of all players and visitors who use the smjili platform at smjili.one. This Privacy Policy describes our practices regarding the collection, use, storage, and disclosure of personal information in connection with your use of smjili's website, games, and related services.

This Privacy Policy applies to all smjili players based in the Philippines and is designed to comply with the Data Privacy Act of 2012 (Republic Act No. 10173) and the implementing rules and regulations issued by the National Privacy Commission (NPC).

By registering for a smjili account or using any smjili service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, please do not use the smjili platform.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, smjili acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and platform visitors.

smjili is responsible for determining the purposes and means of processing your personal data. If you have any questions, concerns, or requests relating to your personal data, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.

3 Data We Collect

smjili collects the following categories of personal data from players and platform visitors:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — 21+ requirement)
• Email address
• Mobile phone number
• Residential address (city, province, postal code)
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Government-issued ID (e.g., Philippine passport, SSS ID, PhilSys ID, driver's licence)
• Selfie or facial photograph for identity matching
• Proof of address documentation where required

3.3 Financial Data

• GCash or Maya account reference (masked)
• Bank account details for bank transfer transactions (masked)
• Transaction history: deposits, withdrawals, and gaming activity

3.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and features used on smjili
• Game play history and wagering records

3.5 Communications Data

• Records of your communications with smjili customer support
• Feedback, survey responses, and promotional opt-in preferences

4 How We Collect Data

smjili collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion.
• Automatically: Through cookies, web beacons, and server logs when you access and use the smjili platform. See Section 8 for details on our cookie practices.
• From third parties: From payment processors (GCash, Maya, banks) to confirm transaction details; from identity verification service providers during KYC; and from fraud prevention and anti-money laundering screening services as required by Philippine regulations.

5 How We Use Your Data

smjili uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your smjili player account.
• Identity verification: To verify your age (21+) and identity in compliance with Philippine gaming and anti-money laundering regulations.
• Payment processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card.
• Gaming services: To provide access to smjili's games, track your gaming history, and calculate winnings and bonuses.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the smjili platform.
• Responsible gaming: To monitor gaming patterns and enforce responsible gaming tools such as deposit limits and self-exclusion.
• Legal compliance: To comply with applicable Philippine laws, regulations, and regulatory directions, including reporting obligations to gaming and financial regulators.
• Platform improvement: To analyse usage patterns and improve the smjili platform, user experience, and game offerings.
• Marketing communications: To send you promotional offers, bonus notifications, and smjili news — only where you have opted in to receive such communications.

smjili will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by law.

6 Legal Basis for Processing

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

• Contractual necessity: Processing is necessary to perform the contract between you and smjili (i.e., to operate your account and provide gaming services).
• Legal obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, gaming regulations, and tax reporting obligations.
• Legitimate interests: Processing is necessary for smjili's legitimate interests in fraud prevention, platform security, and responsible gaming enforcement, provided these interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, smjili relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

smjili does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, and partner banks receive transaction data necessary to process your deposits and withdrawals.
• Game providers: Licensed third-party game studios that supply games on the smjili platform may receive anonymised or pseudonymised gameplay data for game operation and audit purposes.
• Identity verification providers: KYC and age verification service providers receive identity documents and photographs solely for the purpose of verifying your identity.
• Fraud and AML screening services: Anti-fraud and anti-money laundering service providers may receive transaction and identity data as required by Philippine regulations.
• Regulatory authorities: smjili may disclose personal data to Philippine gaming regulators, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, or courts where required by law or a valid legal order.
• Professional advisers: Legal, accounting, and auditing firms engaged by smjili may access personal data on a confidential, need-to-know basis.

All third parties with whom smjili shares personal data are required to maintain appropriate data security standards and to use the data only for the specified purpose.

8 Cookies & Tracking

smjili uses cookies and similar tracking technologies on the smjili platform. Cookies are small text files stored on your device that help us provide a functional and personalised experience.

smjili uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options to improve your smjili experience.
• Analytics cookies: Collect anonymised data about how players use the smjili platform, helping us identify areas for improvement. No personally identifiable information is included in analytics data.

smjili does not use third-party advertising cookies, cross-site tracking pixels, or social media tracking technologies. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may affect platform functionality.

9 Data Retention

smjili retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following retention periods:

• Active account data: Retained for the duration of your smjili account and for a minimum of 5 years after account closure, as required by Philippine anti-money laundering regulations.
• KYC and identity documents: Retained for a minimum of 5 years after the end of the business relationship, in compliance with AMLC requirements.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction.
• Customer support communications: Retained for 3 years from the date of the last communication.
• Marketing consent records: Retained until you withdraw consent, plus 1 year for compliance documentation purposes.

After the applicable retention period, personal data is securely deleted or anonymised in accordance with smjili's data disposal procedures.

10 Data Security

smjili implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data in transit between your device and smjili's servers.
• Encryption at rest for sensitive personal and financial data stored on smjili's systems.
• Access controls: Personal data is accessible only to smjili staff and authorised third parties who have a legitimate need to access it, on a strict need-to-know basis.
• Multi-factor authentication for smjili staff accessing internal systems containing personal data.
• Regular security audits and penetration testing of the smjili platform.
• Incident response procedures: In the event of a personal data breach, smjili will notify affected players and the National Privacy Commission within the timeframes required by the Data Privacy Act of 2012.

While smjili takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your smjili login credentials confidential and for notifying us immediately if you suspect unauthorised access to your account.

11 Your Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by smjili:

• Right to be informed: The right to know what personal data smjili collects and how it is used — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data smjili holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to smjili's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe smjili has violated your data privacy rights.

To exercise any of these rights, please contact smjili's Data Protection Officer using the contact details in Section 15. smjili will respond to all valid requests within 15 business days. We may need to verify your identity before processing your request.

12 Children's Privacy

smjili's platform is strictly for adults aged 21 years and above, in accordance with Philippine gaming law. smjili does not knowingly collect personal data from individuals under the age of 21.

If smjili becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all data will be deleted, and any funds will be returned to the source payment method after verification. If you believe a minor has registered on smjili, please contact our support team immediately.

13 International Data Transfers

smjili's primary data processing infrastructure is located within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or game studios operating internationally.

Where such transfers occur, smjili ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012 and NPC regulations. smjili will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or a valid legal basis.

14 Changes to This Policy

smjili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. When material changes are made, smjili will notify registered players via email or an on-platform notification at least 7 days before the changes take effect, where practicable.

The current version of this Privacy Policy, including the effective date and version number, is always available on this page. We encourage you to review this Policy periodically. Continued use of smjili after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

15 Contact Us

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

• Email: [email protected]
• Support: Via the live chat feature on the smjili platform (available 24/7)
• Response time: smjili aims to respond to all privacy-related enquiries within 15 business days.

If you are not satisfied with smjili's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy was last reviewed and updated on 1 January 2026 (Version 2.4). smjili reserves all rights not expressly granted herein.