smjil Privacy Policy

1. Introduction and Scope

smjil (hereinafter referred to as "we," "us," "our," or "the Company") operates an online gaming platform accessible at https://smjil.cam and associated mobile applications. This Privacy Policy governs the collection, processing, storage, use, disclosure, and protection of personal information provided by users (hereinafter referred to as "you," "your," or "the User") of our platform and services.

By accessing, registering with, or using any services provided by smjil, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you must immediately cease all use of our platform and services and refrain from providing any personal information.

This Privacy Policy supplements and should be read in conjunction with our Terms and Conditions. In the event of any conflict between this Privacy Policy and the Terms and Conditions, the provisions most protective of user privacy shall prevail unless otherwise required by applicable law.

1.1 Legal Framework and Compliance

smjil is committed to full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its implementing rules and regulations, issuances of the National Privacy Commission, and other applicable data protection laws and regulations. We also implement industry best practices aligned with international data protection standards including principles derived from the General Data Protection Regulation (GDPR) where applicable to cross-border data transfers.

As the data controller, smjil determines the purposes and means of processing personal information collected through our platform. We implement appropriate organizational, physical, and technical security measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.

1.2 Data Controller Information

The data controller responsible for your personal information is smjil. For inquiries, requests, or complaints regarding your personal data or this Privacy Policy, you may contact our Data Protection Officer at [email protected] or through our customer support channels available 24/7 via live chat, email, or the contact form on our platform.

2. Information We Collect

2.1 Information You Provide Directly

When you register an account with smjil, use our services, or communicate with us, we collect personal information that you voluntarily provide. This information includes but is not limited to:

• Account Registration Information: Full legal name as it appears on government-issued identification, date of birth, gender, email address, mobile phone number, residential address (street, city, province, postal code), username, password, and security questions.
• Identification and Verification Documents: Government-issued photo identification (passport, driver's license, or national ID card), proof of address documents (utility bills, bank statements, government correspondence), selfie photographs for identity verification, payment method verification documents (credit/debit card images, e-wallet screenshots), and such other documents as may be required for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.
• Financial Information: Payment method details (GCash account information, PayMaya account information, bank account numbers, credit/debit card details), transaction history, deposit and withdrawal records, source of funds documentation, and financial references where required for enhanced due diligence.
• Communication Data: Contents of communications sent through our platform's messaging system, customer support tickets, emails sent to or received from us, live chat transcripts, phone call recordings (where permitted by law and with your consent), feedback and survey responses, and social media interactions.
• Marketing Preferences: Subscription preferences for promotional emails, SMS marketing consent, push notification preferences, and communication channel preferences.

2.2 Information Collected Automatically

When you access and use the smjil platform, we automatically collect certain technical and usage information through various technologies including cookies, web beacons, and similar tracking mechanisms:

• Device Information: Device type and model, operating system and version, browser type and version, screen resolution, device identifiers (such as IMEI, advertising ID), IP address, mobile network information, and device settings.
• Usage Data: Pages viewed, features accessed, time spent on pages, navigation paths through the platform, games played, bets placed, session duration, referring and exit pages, search queries, click-stream data, and interaction patterns.
• Location Information: Approximate geographic location derived from IP address, precise location data (where you have granted permission through mobile device settings), and jurisdiction information for compliance with geographic restrictions and licensing requirements.
• Performance and Diagnostic Data: Error logs, crash reports, performance metrics, loading times, system status information, and technical diagnostics used to maintain and improve platform functionality.

2.3 Information from Third-Party Sources

We may receive information about you from third-party sources to verify your identity, comply with regulatory obligations, prevent fraud, and enhance our services:

• Identity Verification Services: Information from identity verification providers used to authenticate your identity and verify the accuracy of information you have provided.
• Payment Processors: Transaction verification data, payment status information, and fraud detection data from payment service providers such as GCash, PayMaya, and bank payment gateways.
• Credit Reference Agencies: Credit history and financial standing information where required for responsible lending assessment or enhanced due diligence procedures.
• Fraud Prevention Services: Information from fraud detection databases, shared fraud intelligence networks, and industry security consortiums used to identify and prevent fraudulent activities.
• Marketing Partners: Information from affiliate partners and marketing platforms regarding referral sources and campaign performance (where you have consented to such sharing with the third party).
• Social Media Platforms: Public profile information if you choose to register or log in using social media credentials, subject to the privacy settings you have configured on such platforms.

2.4 Sensitive Personal Information

Under Philippine law, certain categories of personal information are considered sensitive and subject to heightened protection. smjil collects the following sensitive personal information only when necessary and with your explicit consent:

• Government-Issued Identification Numbers: Information contained in passports, driver's licenses, national ID cards, and other government-issued identification documents required for identity verification and regulatory compliance.
• Biometric Data: Facial recognition data derived from selfie photographs submitted for identity verification purposes, processed through secure third-party verification services.
• Financial Account Information: Bank account details, payment card information, and e-wallet credentials required for deposit and withdrawal processing.

We implement additional security measures and obtain explicit consent before collecting, processing, or storing sensitive personal information. You may withdraw consent for processing sensitive personal information at any time, subject to our legal and regulatory obligations, by contacting our Data Protection Officer.

3. How We Use Your Information

3.1 Legal Bases for Processing

smjil processes your personal information only where we have a lawful basis to do so. Our legal bases for processing include:

• Contract Performance: Processing necessary to perform our contract with you, including account creation, service provision, transaction processing, and customer support.
• Legal Obligation: Processing required to comply with legal and regulatory obligations including KYC/AML requirements, PAGCOR licensing conditions, tax reporting obligations, and responses to lawful requests from authorities.
• Legitimate Interests: Processing necessary for our legitimate business interests including fraud prevention, security enhancement, platform improvement, business analytics, and direct marketing (where not overridden by your privacy rights).
• Consent: Processing based on your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing conducted prior to withdrawal.

3.2 Purposes of Data Processing

We use your personal information for the following purposes:

Account Management and Service Delivery

• Creating and maintaining your smjil account
• Authenticating your identity and verifying your eligibility to use our services
• Processing deposits, withdrawals, and other financial transactions
• Providing access to games, features, and platform functionality
• Managing your account settings, preferences, and communication choices
• Maintaining records of your gaming activity, transaction history, and account status
• Administering bonuses, promotions, loyalty programs, and VIP benefits

Regulatory Compliance and Legal Obligations

• Verifying your identity and age to ensure compliance with legal age restrictions (21+ requirement)
• Conducting Know Your Customer (KYC) and enhanced due diligence procedures as required by PAGCOR regulations and anti-money laundering laws
• Monitoring transactions for suspicious activity and reporting to relevant authorities as required by law
• Maintaining records as required by gaming regulations, tax laws, and financial regulations
• Responding to lawful requests from regulatory authorities, law enforcement agencies, and courts
• Enforcing our Terms and Conditions and other policies
• Complying with responsible gaming obligations and self-exclusion requirements

Security and Fraud Prevention

• Detecting, preventing, and investigating fraudulent activities, money laundering, and other illegal activities
• Identifying and blocking duplicate accounts and unauthorized access attempts
• Protecting the security and integrity of our platform, systems, and networks
• Investigating disputes, complaints, and potential violations of our policies
• Implementing security measures including multi-factor authentication and anomaly detection
• Maintaining audit trails and security logs for compliance and incident investigation

Customer Support and Communication

• Responding to your inquiries, support requests, and complaints
• Providing technical assistance and troubleshooting support
• Sending transactional communications regarding your account, deposits, withdrawals, and platform updates
• Notifying you of changes to our Terms and Conditions, Privacy Policy, or services
• Conducting customer satisfaction surveys and collecting feedback

Marketing and Promotional Activities

• Sending promotional offers, bonus opportunities, and marketing communications via email, SMS, push notifications, and in-platform messaging (where you have consented)
• Personalizing marketing content based on your preferences, gaming activity, and interests
• Administering contests, tournaments, and promotional campaigns
• Analyzing campaign effectiveness and marketing performance

Platform Improvement and Analytics

• Analyzing usage patterns to improve platform functionality, user experience, and game selection
• Conducting research and development to enhance our services and introduce new features
• Generating aggregated, anonymized statistics and insights for business intelligence
• Testing new features, games, and technologies
• Optimizing platform performance, loading times, and system stability

Responsible Gaming Support

• Implementing deposit limits, loss limits, and session time restrictions you have set
• Processing self-exclusion requests and maintaining exclusion lists
• Identifying patterns that may indicate problem gambling behaviors
• Providing access to responsible gaming resources and support organizations

4. Information Sharing and Disclosure

4.1 Third-Party Service Providers

smjil engages carefully selected third-party service providers to assist in delivering our services and supporting our operations. We share your personal information with these providers only to the extent necessary for them to perform their designated functions, and we require them to maintain confidentiality and implement appropriate security measures:

• Payment Processors: GCash, PayMaya, bank payment gateways, and other financial institutions process deposits and withdrawals on your behalf. They receive transaction information, account identifiers, and such other data as necessary to complete financial transactions.
• Identity Verification Providers: Third-party KYC services verify your identity by comparing information you provide against official databases and document authentication services.
• Game Providers: Licensed game content providers receive limited information necessary to deliver gaming content and track gameplay for regulatory reporting purposes.
• Cloud Infrastructure Providers: Cloud hosting services store and process data on secure servers with industry-standard encryption and access controls.
• Customer Support Platforms: Help desk and live chat software providers process support tickets and communication records to facilitate customer service.
• Marketing and Analytics Services: Email marketing platforms, SMS gateways, analytics tools, and marketing automation services help us deliver promotional content and analyze platform performance (where you have consented to marketing).
• Fraud Detection Services: Specialized fraud prevention providers analyze transaction patterns and behaviors to identify and prevent fraudulent activities.

4.2 Regulatory and Legal Disclosures

smjil may disclose your personal information to regulatory authorities, law enforcement agencies, government bodies, and courts when required by law or when we believe in good faith that such disclosure is necessary to:

• Comply with PAGCOR licensing requirements and gaming regulations
• Respond to lawful requests, subpoenas, court orders, or legal processes
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC) as required by anti-money laundering laws
• Cooperate with tax authorities regarding tax reporting and compliance obligations
• Assist law enforcement investigations of illegal activities, fraud, or violations of law
• Enforce our Terms and Conditions and other legal rights
• Protect the safety, rights, or property of smjil, our users, or the public

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, bankruptcy, or other business transaction involving smjil, your personal information may be transferred to the successor entity or acquiring party. We will provide notice of such transfer and any resulting changes to this Privacy Policy through email notification and prominent notice on our platform.

4.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that does not personally identify you with third parties for research, analytics, industry reporting, and business intelligence purposes. Such data cannot be used to identify individual users and is not subject to the restrictions of this Privacy Policy.

4.5 Third Parties We Do Not Share With

smjil does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We do not share your information with unauthorized third parties or for purposes incompatible with those disclosed in this Privacy Policy, except with your explicit consent or as required by law.

5. Data Security and Protection

5.1 Security Measures

smjil implements comprehensive organizational, physical, and technical security measures designed to protect your personal information against unauthorized access, alteration, disclosure, loss, misuse, or destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard TLS/SSL encryption protocols. Sensitive data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: We implement role-based access controls limiting employee access to personal information on a need-to-know basis. Multi-factor authentication is required for access to systems containing sensitive data.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and continuous security monitoring to detect and prevent unauthorized access attempts.
• Secure Development: We follow secure coding practices and conduct regular security assessments, vulnerability scans, and penetration testing of our systems and applications.
• Data Minimization: We collect and retain only the personal information necessary for the purposes disclosed in this Privacy Policy and delete data when no longer required.
• Employee Training: All employees with access to personal information receive regular training on data protection obligations, security procedures, and privacy best practices.
• Vendor Management: Third-party service providers are contractually obligated to maintain appropriate security measures and are subject to regular security assessments.
• Incident Response: We maintain an incident response plan to promptly detect, contain, investigate, and remediate security incidents, with notification procedures compliant with applicable breach notification laws.

5.2 Account Security Responsibilities

While we implement robust security measures, you also have responsibilities for protecting your account:

• Create a strong, unique password combining uppercase and lowercase letters, numbers, and special characters
• Enable two-factor authentication (2FA) for enhanced account protection
• Never share your login credentials, password, or verification codes with anyone
• Log out of your account when using shared or public devices
• Keep your device's operating system, browser, and security software up to date
• Be cautious of phishing attempts and verify the authenticity of communications claiming to be from smjil
• Immediately notify us of any suspected unauthorized access or security concerns

5.3 Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, smjil will notify affected users and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by the Philippine Data Privacy Act. Notifications will include information about the nature of the breach, affected data categories, potential consequences, and measures taken to address the breach and mitigate harm.

6. Data Retention and Deletion

6.1 Retention Periods

smjil retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Information: Retained for the duration of your account's active status and for five (5) years following account closure to comply with gaming regulations and financial record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years as required by anti-money laundering regulations and tax laws.
• Identity Verification Documents: Retained for five (5) years following account closure or completion of the last transaction, whichever is later, to comply with KYC and AML record-keeping obligations.
• Communication Records: Retained for three (3) years for customer service quality assurance, dispute resolution, and regulatory compliance purposes.
• Marketing Consent Records: Retained until consent is withdrawn and for a reasonable period thereafter to document consent and withdrawal for compliance purposes.
• Technical and Usage Data: Retained for up to two (2) years for security, fraud prevention, and platform improvement purposes, then aggregated and anonymized for longer-term analytics.

6.2 Deletion and Anonymization

Upon expiration of applicable retention periods, or upon your request subject to legal exceptions, smjil will securely delete or anonymize your personal information using methods designed to prevent reconstruction or re-identification. Deletion processes include secure erasure from active databases, secure wiping of backup systems during scheduled purge cycles, and destruction of physical documents in accordance with data protection standards.

6.3 Legal Holds and Exceptions

Notwithstanding standard retention periods, smjil may retain personal information beyond scheduled deletion dates when required for ongoing legal proceedings, regulatory investigations, dispute resolution, enforcement of our rights, or other legitimate legal purposes. Such information will be retained only for the duration necessary for the specific legal purpose and will be subject to enhanced access restrictions.

7. Your Privacy Rights

7.1 Right to Access

You have the right to request access to the personal information we hold about you. Upon receiving a verified request, we will provide you with a copy of your personal data in a structured, commonly used, and machine-readable format within fifteen (15) business days, subject to any applicable legal exceptions.

7.2 Right to Rectification

If you believe that personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request correction or update of such information. You may update certain information directly through your account settings or by contacting customer support.

7.3 Right to Erasure

You may request deletion of your personal information where: (a) the information is no longer necessary for the purposes for which it was collected; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing and there are no overriding legitimate grounds; or (d) the information has been unlawfully processed. This right is subject to legal and regulatory retention obligations.

7.4 Right to Restrict Processing

You may request restriction of processing of your personal information in certain circumstances, including when you contest the accuracy of the information, when processing is unlawful but you oppose deletion, or when you need the information for legal claims but we no longer need it for our purposes.

7.5 Right to Data Portability

You have the right to receive personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit that information to another controller where technically feasible, subject to legal and commercial confidentiality restrictions.

7.6 Right to Object

You may object to processing of your personal information where we rely on legitimate interests as the legal basis for processing. You have an absolute right to object to processing for direct marketing purposes at any time by using the unsubscribe mechanism in marketing communications or by contacting us.

7.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal. Withdrawal of consent may affect our ability to provide certain services.

7.8 Exercising Your Rights

To exercise any of your privacy rights, please contact our Data Protection Officer at [email protected] or through customer support. We will verify your identity before processing requests and will respond within fifteen (15) business days. If we cannot fully comply with your request, we will explain the reasons and any limitations.

7.9 Right to Lodge a Complaint

If you believe that we have violated your privacy rights or applicable data protection laws, you have the right to lodge a complaint with the National Privacy Commission of the Philippines by visiting their website at https://www.privacy.gov.ph or contacting them at their office.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

smjil uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you and remember your preferences:

• Essential Cookies: Necessary for platform functionality including authentication, session management, load balancing, and security features. These cookies cannot be disabled without affecting platform operation.
• Performance Cookies: Collect information about how you use our platform, including pages visited, errors encountered, and loading times. This data helps us improve platform performance and user experience.
• Functional Cookies: Remember your preferences such as language selection, display settings, and customization choices to provide enhanced functionality.
• Analytics Cookies: Help us understand user behavior through aggregated data collection, enabling us to analyze trends and optimize our services.
• Marketing Cookies: Track your browsing activity to deliver relevant advertising and measure campaign effectiveness. These cookies are set only with your consent.

8.2 Managing Cookie Preferences

You can control cookie settings through your browser settings or our cookie consent banner. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may affect platform functionality and your ability to use certain features. You can opt out of marketing cookies at any time through your account privacy settings.

8.3 Third-Party Tracking

Our platform may include tracking technologies from third-party analytics and advertising services. These third parties may collect information about your online activities over time and across different websites. We do not control third-party tracking technologies and recommend reviewing the privacy policies of these services.

9. International Data Transfers

smjil primarily operates within the Philippines and stores data on servers located in the Philippines or within secure data centers in jurisdictions with adequate data protection standards. However, some of our service providers may process data in other countries. When we transfer personal information internationally, we implement appropriate safeguards including standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms to ensure your data remains protected in accordance with Philippine data protection standards.

By using our services, you acknowledge and consent to the transfer of your personal information outside the Philippines where necessary for the purposes described in this Privacy Policy, subject to appropriate safeguards.

10. Children's Privacy

smjil's services are strictly intended for individuals who are at least twenty-one (21) years of age or the legal age of majority in their jurisdiction, whichever is greater. We do not knowingly collect personal information from individuals under the age of twenty-one (21). If we become aware that we have inadvertently collected personal information from a minor, we will take immediate steps to delete such information from our systems and terminate the associated account.

Parents or legal guardians who believe that a minor has provided personal information to smjil should contact us immediately at [email protected] so that we can take appropriate action to remove such information and prevent further access to our services.

11. Changes to This Privacy Policy

smjil reserves the right to modify, update, or replace this Privacy Policy at any time at our sole discretion to reflect changes in our practices, services, legal requirements, or for other operational, regulatory, or legal reasons. Material changes will be communicated through email notification to your registered email address, prominent notice on our platform homepage, or in-platform notification upon your next login.

The "Last Updated" date at the beginning of this Privacy Policy indicates when the most recent revisions were made. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Your continued use of our services following notification of changes constitutes your acknowledgment and acceptance of the revised Privacy Policy.

If you do not agree to the updated Privacy Policy, you must cease using our services and may request closure of your account and deletion of your personal information, subject to legal retention obligations.

12. Contact Information

If you have questions, concerns, requests, or complaints regarding this Privacy Policy or our data protection practices, please contact us through the following channels:

Data Protection Officer: [email protected]

Customer Support: Available 24/7 via live chat, email at [email protected], or through the contact form on our platform.

Mailing Address: Data Protection Officer, smjil, Philippines

We are committed to addressing your privacy concerns promptly and transparently. We will acknowledge receipt of your inquiry within forty-eight (48) hours and provide a substantive response within fifteen (15) business days.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

National Privacy Commission
Website: https://www.privacy.gov.ph
Email: [email protected]