smjil Privacy Policy

01Who We Are

smjil is an online gaming platform operating at smjil.net, offering slots, live casino games, sports betting, bingo, sabong, fishing games, and related entertainment services to Filipino players across the Philippines — from Metro Manila and the Visayas to Mindanao and all provincial areas.

For the purposes of this Privacy Policy, smjil acts as the data controller in respect of personal data collected from members and website visitors. As data controller, smjil determines the purposes and means of processing your personal data in accordance with Republic Act No. 10173 (Data Privacy Act of 2012) and its implementing rules.

References to "smjil," "we," "us," or "the Platform" in this policy refer to the smjil online gaming platform. References to "you," "your," or "member" refer to any individual who accesses smjil, registers an account, or whose personal data is processed by smjil in connection with the platform.

02Personal Data We Collect

smjil collects the following categories of personal data from members and, in limited cases, from website visitors:

smjil does not intentionally collect special categories of sensitive personal data (such as health data, political opinions, religious beliefs, or biometric data beyond what is inherent in a photo ID) unless specifically required to do so by applicable Philippine law or regulatory direction.

03How We Collect Your Data

3.1 Directly from you. The majority of personal data smjil holds is provided directly by members during the account registration process, KYC verification, deposit and withdrawal transactions, customer support interactions, and when members update their account profile or communication preferences.

3.2 Automatically through the platform. When you access smjil, our servers automatically collect technical data including your IP address, device identifiers, browser information, and session activity. This data is collected using server logs, cookies, and similar tracking technologies as described in Section 7 of this policy.

3.3 From third-party service providers. smjil may receive personal data about you from third parties in limited circumstances — for example, identity and age verification data from KYC service providers, transaction confirmation data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank, and fraud-risk signals from anti-fraud service providers. All such third parties are contractually obligated to handle your data in accordance with applicable data protection law.

3.4 From publicly available sources. In connection with our AML (Anti-Money Laundering) compliance obligations, smjil may cross-reference member identity information against publicly available government databases, sanctions lists, and politically exposed persons (PEP) registers as required by Philippine law.

04Purposes of Processing

smjil processes your personal data for the following specific purposes:

• Account creation and management — to register your smjil account, authenticate your identity at login, and maintain the accuracy of your member profile.
• KYC and age verification — to verify that you are aged 21 or above and to confirm your identity as required by PAGCOR and Philippine AML regulations.
• Payment processing — to process deposits from and withdrawals to your GCash, PayMaya, bank account, or card, and to maintain accurate transaction records.
• Platform delivery — to provide access to smjil games including slots, live casino, bingo, sports betting, sabong, fishing games, and all other platform features.
• Responsible gaming — to monitor gaming activity for signs of problem gambling, enforce member-requested deposit and loss limits, and administer cool-off periods and self-exclusion requests.
• Fraud prevention and security — to detect and prevent unauthorized account access, bonus abuse, money laundering, duplicate account creation, and other prohibited conduct.
• Regulatory compliance — to fulfill smjil's obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Customer support — to respond to member queries, complaints, and support requests through live chat and email.
• Marketing communications — to send promotional offers, bonus notifications, and platform updates to members who have consented to receive such communications.
• Platform improvement — to analyze aggregated and anonymized usage data to improve smjil's games, features, and user experience.

05Legal Basis for Processing

smjil processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 (RA 10173):

5.1 Contractual necessity. Processing your identity, contact, financial, and gaming data is necessary to perform the contract between you and smjil — that is, to operate your member account, process payments, and deliver gaming services to you.

5.2 Legal obligation. smjil is legally required to collect and retain certain personal data to comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160 as amended), and other applicable Philippine laws. This includes KYC verification data, transaction records, and AML monitoring activity.

5.3 Legitimate interests. smjil processes technical data (IP addresses, device identifiers, session logs) on the basis of legitimate interests in maintaining platform security, preventing fraud, detecting duplicate accounts, and ensuring the integrity of the gaming environment for all Filipino members.

5.4 Consent. smjil processes your data for marketing communications exclusively on the basis of your freely given, specific, and informed consent. You may withdraw this consent at any time through your account settings or by contacting smjil support, without affecting the lawfulness of processing carried out prior to withdrawal.

06Data Sharing & Third Parties

6.1 No data selling. smjil does not sell, rent, or commercially transfer your personal data to any third party for that party's own commercial or marketing purposes. This is an absolute commitment.

6.2 Service providers. smjil shares personal data with carefully selected third-party service providers who process data on smjil's behalf and under smjil's instructions, including:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, Visa/Mastercard networks, and USDT infrastructure providers, for the purpose of processing deposits and withdrawals.
• KYC verification providers — third-party identity verification services used to validate government-issued Philippine IDs and confirm member age.
• Game content providers — licensed game studios and providers whose games are offered through smjil; these providers may receive anonymized session data for RNG audit and game performance purposes.
• Fraud prevention services — providers who assist smjil in detecting fraudulent activity, money laundering, and platform abuse.
• Cloud infrastructure and hosting providers — secure cloud service providers used to host smjil's platform and data infrastructure.

All third-party service providers are subject to written data processing agreements that restrict their use of member data to the purpose for which it was shared and require them to implement appropriate security measures.

6.3 Regulatory and law enforcement disclosure. smjil may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and other competent authorities where smjil is legally required or compelled to do so. smjil will not voluntarily disclose member data to government authorities beyond what is legally required.

6.4 Business transfers. In the event of a merger, acquisition, or sale of all or part of smjil's business, member personal data may be transferred to the acquiring entity as part of that transaction. Affected members will be notified in advance of any such transfer and of any change in the applicable privacy policy.

07Cookies & Tracking Technologies

7.1 What are cookies? Cookies are small text files placed on your device by a website when you visit it. smjil uses cookies and similar technologies (such as local storage tokens and session identifiers) to operate the platform, maintain your login session, remember your preferences, and analyze platform usage.

7.2 Types of cookies smjil uses:

• Strictly necessary cookies — these are essential for the smjil platform to function. They maintain your login session, enable game loading, and ensure payment processes work correctly. These cookies cannot be disabled without breaking core platform functionality.
• Functional cookies — these remember your language preferences, responsible gaming settings, and display preferences to improve your smjil experience.
• Analytics cookies — these collect anonymized data about how members navigate smjil, which games are most popular, and where technical errors occur. This data is used to improve platform performance. Analytics data is aggregated and does not identify individual members.
• Security cookies — these assist in detecting unusual account activity, preventing unauthorized login attempts, and identifying potentially fraudulent sessions.

7.3 Managing cookies. You may configure your browser to refuse or delete cookies. Note that disabling strictly necessary cookies will prevent you from logging into smjil and using core platform features. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

7.4 No third-party advertising trackers. smjil does not use third-party advertising cookies, cross-site tracking pixels, or behavioral advertising technology on its platform. The cookies smjil uses are limited to those necessary for platform operation, security, and internal analytics.

08Data Retention

8.1 Active accounts. Personal data is retained for the duration of your smjil account and for a defined period after account closure, as set out below.

8.2 Retention periods by category:

8.3 Secure deletion. Upon expiry of the applicable retention period, smjil will securely delete or irreversibly anonymize your personal data so that it can no longer be associated with you as an individual.

09Data Security

9.1 Technical measures. smjil implements the following technical security controls to protect member personal data:

• 256-bit SSL/TLS encryption for all data in transit between your device and smjil servers.
• Encryption of sensitive data at rest, including financial data and KYC documents.
• Multi-factor authentication (MFA) available for member account login.
• Firewalls, intrusion detection systems, and DDoS mitigation for platform infrastructure.
• Automated monitoring for suspicious login activity, including logins from unfamiliar IP addresses or devices.
• Regular penetration testing and security audits of platform infrastructure.

9.2 Organizational measures. Access to member personal data within smjil is restricted on a strict need-to-know basis. smjil staff who handle personal data receive data protection training, are subject to confidentiality obligations, and access member data only through secure, authenticated systems with comprehensive audit trails.

9.3 Data breach response. In the event of a personal data breach that poses a risk to member rights and freedoms, smjil will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected members without undue delay, in accordance with RA 10173 requirements.

9.4 Your responsibility. While smjil implements robust technical and organizational security measures, you also play an important role in protecting your account. Keep your smjil login credentials confidential, do not share your password or OTP with anyone, and notify smjil support immediately if you suspect unauthorized access to your account.

10Your Data Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to the personal data smjil holds about you. To exercise any of these rights, contact smjil support at [email protected]. smjil will respond to all valid data rights requests within 30 calendar days.

11Minors & Age Restriction

11.1 Strict 21+ policy. smjil is strictly an adults-only platform. The minimum age to access and use smjil is 21 years old, in line with Philippine gaming regulations. smjil does not knowingly collect personal data from persons under the age of 21.

11.2 Age verification. All smjil members are required to complete KYC age verification as part of the account registration and verification process. Any account where the member cannot satisfactorily verify that they are aged 21 or above will be immediately suspended and any balance held in the account will be returned to the member's payment method.

11.3 Discovery of underage use. If smjil becomes aware, at any time, that a member is under the age of 21, smjil will immediately suspend and permanently close the account, void all transactions carried out through the account, and return any real-money funds deposited to the payment method used for those deposits. smjil reserves the right to refer the matter to PAGCOR and relevant Philippine authorities.

11.4 Parental guidance. If you are a parent or guardian and believe a minor in your household may have accessed smjil, please contact smjil support immediately at [email protected]. We recommend that parents use device-level parental control software and ensure that smjil login credentials are kept private and inaccessible to minors.

12International Data Transfers

12.1 Primary data location. smjil's primary data processing infrastructure is located within the Asia-Pacific region, with core operational data stored on servers accessible within the Philippines or in jurisdictions with equivalent data protection standards.

12.2 Third-party provider transfers. Some smjil service providers — including game content studios, KYC verification providers, and cloud infrastructure partners — may process member data in jurisdictions outside the Philippines. Where such transfers occur, smjil ensures that appropriate safeguards are in place, including contractual clauses requiring the recipient to process data in accordance with standards equivalent to RA 10173 and smjil's own privacy commitments.

12.3 Member notification. smjil will not transfer personal data to international recipients in circumstances that would materially reduce the level of protection you are entitled to under Philippine data protection law, without first obtaining your informed consent or establishing an adequate legal mechanism for the transfer.

13Changes to This Privacy Policy

13.1 Right to update. smjil reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or platform features. The effective date at the top of this page will always reflect the date of the most recent revision.

13.2 Notification of material changes. When smjil makes material changes to this Privacy Policy — changes that significantly affect how your personal data is collected, used, or shared — smjil will notify active members via email to the address registered on your account and/or via a prominent notice on the smjil platform, at least 14 days before the changes take effect.

13.3 Continued use. Your continued use of smjil after the effective date of any updated Privacy Policy constitutes your acknowledgment of, and agreement to, the revised terms. If you do not agree with the updated policy, you must discontinue use of smjil and may request account closure by contacting support.

13.4 Policy archive. Prior versions of this Privacy Policy are available upon request by contacting smjil support. smjil maintains a version history of all privacy policy revisions for regulatory compliance purposes.

14Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way smjil handles your personal data, please contact the smjil Data Protection team:

If you are not satisfied with smjil's response to your data protection inquiry, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which can be reached through its official government website and contact channels.

This Privacy Policy was last reviewed and approved by the smjil Data Protection Office in January 2026 and is effective as of January 1, 2026.