gilis Privacy Policy

1. Introduction and Scope

This Privacy Policy (the "Policy") describes how gilis (the "Company," "we," "us," or "our"), a Philippine-registered online gaming operator licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR), collects, uses, discloses, stores, and protects personal information obtained from users (the "User," "Player," "you," or "your") of the gilis website located at gilis.cam (the "Website") and associated gaming services.

By creating an account with gilis, accessing the Website, or using any of our gaming services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. This Policy applies to all personal information collected through the Website, mobile applications (if applicable), customer support interactions, payment processing systems, and any other channels through which you interact with gilis.

gilis is committed to protecting your privacy and handling your personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, PAGCOR regulatory requirements, and international data protection best practices. We implement appropriate technical and organizational security measures to safeguard your personal information against unauthorized access, disclosure, alteration, or destruction.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account with gilis, we collect personal information that you voluntarily provide during the registration process and subsequent account management activities. This information includes but is not limited to:

• Identity Information: Full legal name as it appears on your government-issued identification, date of birth, gender, nationality, and government-issued identification numbers (passport number, driver's license number, UMID number, SSS number, or other acceptable Philippine identification);
• Contact Information: Residential address, email address, mobile phone number, and alternative contact details;
• Account Credentials: Username, password, security questions and answers, and account preferences;
• Financial Information: Payment method details including bank account information, e-wallet account identifiers (GCash, PayMaya), credit or debit card numbers, transaction history, deposit and withdrawal records, and betting activity;
• Verification Documents: Copies of government-issued identification, proof of address documents (utility bills, bank statements), selfie photographs for identity verification, and proof of payment method ownership;
• Communication Records: Contents of correspondence with our customer support team, including live chat transcripts, email exchanges, phone call recordings, and feedback submissions.

2.2 Information Collected Automatically

When you access the gilis platform, we automatically collect certain technical information through cookies, web beacons, server logs, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information;
• Usage Data: IP address, geolocation data, pages visited, time spent on each page, clickstream data, referring URLs, search queries, games played, bets placed, and login timestamps;
• Session Information: Session duration, frequency of visits, navigation patterns, and interaction with promotional content;
• Cookie Data: Authentication tokens, language preferences, display settings, and other data stored in browser cookies and local storage.

2.3 Information from Third Parties

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

• Identity Verification Services: Age verification data, identity authentication results, and document verification status from third-party KYC (Know Your Customer) providers;
• Payment Processors: Transaction confirmation data, payment method validation, and fraud screening results from financial institutions and payment service providers (GCash, PayMaya, banks);
• Credit Reference Agencies: Credit checks and fraud detection data where permitted by law and necessary for responsible gaming assessment;
• Publicly Available Sources: Information from public databases, sanctions lists, politically exposed persons (PEP) lists, and adverse media screening to fulfill anti-money laundering obligations.

3. How We Use Your Information

gilis processes your personal information for the following lawful purposes:

3.1 Account Management and Service Delivery

• Creating, maintaining, and managing your gilis account;
• Processing deposits, withdrawals, and other financial transactions;
• Providing access to casino games, sports betting, live dealer tables, and other gaming products;
• Calculating and crediting winnings, bonuses, and promotional rewards;
• Administering loyalty programs and VIP benefits;
• Sending transactional communications including account notifications, payment confirmations, and security alerts.

3.2 Legal and Regulatory Compliance

• Verifying your identity and age to ensure compliance with Philippine law requiring players to be at least twenty-one (21) years of age;
• Fulfilling anti-money laundering (AML) and counter-terrorist financing (CTF) obligations under Philippine law;
• Detecting and preventing fraudulent activity, bonus abuse, collusion, and other prohibited conduct;
• Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC) and other regulatory authorities as required by law;
• Maintaining records for audit and regulatory inspection purposes as mandated by PAGCOR;
• Responding to legal requests, court orders, and government investigations.

3.3 Responsible Gaming and Player Protection

• Monitoring gaming behavior to identify signs of problem gambling;
• Enforcing deposit limits, loss limits, and self-exclusion requests;
• Providing responsible gaming tools and resources;
• Preventing underage gambling and access by self-excluded individuals;
• Conducting affordability assessments where necessary to protect vulnerable players.

3.4 Marketing and Communications (With Your Consent)

• Sending promotional emails about new games, bonuses, tournaments, and special offers;
• Delivering personalized content and recommendations based on your gaming preferences;
• Conducting customer satisfaction surveys and requesting feedback;
• Notifying you of important updates to our services, policies, or terms.

You may opt out of marketing communications at any time by clicking the unsubscribe link in promotional emails, adjusting your account communication preferences, or contacting customer support. Please note that you cannot opt out of transactional or legally required communications.

3.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve Website functionality and user experience;
• Conducting A/B testing to optimize game offerings and promotional campaigns;
• Troubleshooting technical issues and maintaining platform security;
• Developing new features, products, and services based on user feedback and behavior;
• Generating aggregated, anonymized statistical reports for internal business intelligence.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, gilis processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contractual obligations under the Terms and Conditions, including providing gaming services, processing payments, and managing your account;
• Legal Obligation: Processing is required to comply with Philippine law, PAGCOR regulations, anti-money laundering requirements, tax obligations, and other legal duties;
• Consent: You have provided explicit, informed, and freely given consent for specific processing activities such as marketing communications and optional data uses;
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, customer service improvement, and business analytics, provided these interests do not override your fundamental rights and freedoms.

5. How We Share Your Information

gilis does not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information with the following categories of recipients for the purposes described in this Policy:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to support our operations. These providers are contractually bound to process your data only as instructed by gilis and to maintain appropriate security measures:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other financial institutions that process deposits and withdrawals;
• Identity Verification Services: Third-party KYC providers that verify your age, identity, and address;
• Game Providers: Software suppliers such as Ezugi that provide live dealer games and other casino content;
• Cloud Hosting Providers: Infrastructure services that host the gilis platform and store data securely;
• Customer Support Tools: Live chat platforms, ticketing systems, and communication services used to provide customer support;
• Marketing and Analytics Partners: Email service providers, analytics platforms, and advertising networks (only with your consent for marketing purposes).

5.2 Regulatory and Law Enforcement Authorities

We may disclose your personal information to government agencies, regulators, and law enforcement authorities when required by law or necessary to:

• Comply with PAGCOR licensing conditions, audits, and regulatory reporting requirements;
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC);
• Respond to valid legal process including court orders, subpoenas, and search warrants;
• Cooperate with criminal investigations and prosecutions;
• Protect the rights, property, and safety of gilis, our users, and the public;
• Enforce our Terms and Conditions and prevent fraud or other illegal activity.

5.3 Corporate Transactions

In the event of a merger, acquisition, asset sale, bankruptcy, or other corporate restructuring, your personal information may be transferred to the successor entity. We will notify you via email and/or prominent notice on the Website before your information becomes subject to a different privacy policy.

6. Data Security Measures

gilis employs industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmissions between your device and our servers are encrypted using SSL/TLS protocols. Sensitive data stored in our databases is encrypted at rest using AES-256 encryption;
• Access Controls: Personal data is accessible only to authorized personnel who require it to perform their job functions. Access is controlled through role-based permissions and multi-factor authentication;
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and regular security audits. We conduct penetration testing and vulnerability assessments periodically;
• Secure Data Centers: Data is stored in secure, certified data centers with physical security measures including 24/7 surveillance, biometric access controls, and environmental monitoring;
• Employee Training: All gilis staff members receive regular training on data protection principles, security best practices, and confidentiality obligations;
• Incident Response: We maintain an incident response plan to quickly detect, contain, and remediate any data breaches. In the event of a breach affecting your personal information, we will notify you and relevant authorities as required by Philippine law.

While we take extensive precautions to protect your data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

7. Data Retention

gilis retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with legal, regulatory, accounting, and reporting obligations:

• Active Accounts: While your account remains active, we retain all account data, transaction records, and gaming history;
• Closed Accounts: After voluntary account closure, we retain identification documents, transaction records, and communications for a minimum of five (5) years as required by PAGCOR and anti-money laundering regulations;
• Legal Holds: If your account is subject to investigation, dispute, litigation, or regulatory inquiry, we will retain relevant data until the matter is fully resolved;
• Marketing Data: If you opt out of marketing communications, we retain a record of your opt-out preference indefinitely to ensure we do not contact you again;
• Aggregated Data: We may retain anonymized, aggregated data that cannot identify you individually for statistical and analytical purposes without time limit.

Upon expiration of the applicable retention period, we securely delete or anonymize your personal information in accordance with our data retention policy and applicable law.

8. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request confirmation of whether we are processing your personal data and to obtain a copy of that data. You may view most of your account information directly in your account dashboard.

8.2 Right to Correction

You have the right to request correction of inaccurate or incomplete personal information. You can update many account details yourself through your account settings, or contact customer support for assistance.

8.3 Right to Erasure

You have the right to request deletion of your personal data under certain circumstances. Please note that we may be required to retain certain information to comply with legal obligations, even after you request deletion.

8.4 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes or when processing is based on legitimate interests. You may opt out of marketing communications at any time.

8.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible.

8.6 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before consent was withdrawn.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with your request. We will respond within thirty (30) days as required by Philippine law. We may request additional information to verify your identity before processing your request.

9. Cookies and Tracking Technologies

gilis uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Website, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you on repeat visits and remember your preferences.

9.1 Types of Cookies We Use

• Essential Cookies: Required for basic Website functionality including authentication, security, and session management. These cannot be disabled;
• Performance Cookies: Collect anonymous information about how visitors use the Website to help us improve functionality and user experience;
• Functional Cookies: Remember your preferences such as language selection, display settings, and login details;
• Marketing Cookies: Track your browsing behavior to deliver targeted advertising and measure campaign effectiveness (only with your consent).

You can control cookie preferences through your browser settings. However, disabling certain cookies may affect Website functionality and prevent you from using some features. By continuing to use the gilis Website, you consent to our use of cookies as described in this Policy.

10. Third-Party Links and Services

The gilis Website may contain links to third-party websites, services, or content providers (such as game suppliers and payment processors). This Privacy Policy does not apply to those third-party sites, which are governed by their own privacy policies. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

11. International Data Transfers

gilis primarily operates within the Philippines, and your personal information is stored on servers located in the Philippines or in secure data centers within the Asia-Pacific region. In some cases, our service providers may process data in other jurisdictions. When we transfer personal information outside the Philippines, we ensure appropriate safeguards are in place to protect your data in accordance with Philippine law and international data protection standards.

12. Children's Privacy

The gilis platform is intended exclusively for individuals who are at least twenty-one (21) years of age. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected data from a person under 21 years of age, we will immediately delete that information and close the associated account. If you believe a minor has provided personal information to gilis, please contact us immediately at [email protected].

13. Changes to This Privacy Policy

gilis reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. We will post the revised Policy on this page with an updated "Last Updated" date. Material changes that significantly affect your privacy rights will be communicated via email or prominent notice on the Website.

Your continued use of the gilis platform after the effective date of any changes constitutes acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal information.

14. Contact Information and Complaints

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Data Protection Officer:

gilis Data Protection Officer
Email: [email protected]
Available: 24/7 via email and live chat

We take all privacy concerns seriously and will investigate and respond to all complaints in a timely manner. If you are not satisfied with our response, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.