2ji Casino Privacy Policy

1.1 This Policy governs the collection, use, storage, disclosure, and protection of personal data relating to registered players, prospective players, and visitors to the 2ji Casino platform (collectively, "Data Subjects" or "you").

1.2 This Policy applies to all personal data processing activities conducted by 2ji in connection with the delivery of its online casino and gaming services, including account management, payment processing, customer support, responsible gaming tools, and platform improvement activities.

1.3 This Policy should be read together with the 2ji Terms & Conditions and Responsible Gaming Policy, which form part of the overall framework governing your use of the platform.

2.1 2ji processes personal data only where a valid legal basis exists under RA 10173. The applicable legal bases are: fulfilment of a contractual obligation with the Data Subject; compliance with a legal or regulatory obligation; protection of legitimate interests; and, where required, freely given and informed consent.

2.2 2ji has designated a Data Protection Officer (DPO) as required under RA 10173. The DPO oversees compliance with this Policy, manages data subject rights requests, and serves as the primary point of contact with the National Privacy Commission. Contact details for the DPO are provided in Section 16.

3.1 2ji collects the following categories of personal data, depending on the nature of your interaction with the platform:

3.2 2ji does not collect sensitive personal information as defined under RA 10173 (including racial or ethnic origin, political opinion, religious belief, health information, or sexual orientation) unless strictly required for regulatory compliance purposes, in which case explicit consent will be obtained.

4.1 2ji collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or submit any form on the 2ji platform;
• Automatically during platform use: Through server logs, session tracking systems, and cookies as described in Section 11;
• From third-party payment processors: Transaction confirmation data from GCash, PayMaya, BDO, BPI, and Metrobank when processing deposits and withdrawals;
• From identity verification providers: Confirmation and risk-scoring data from KYC processing partners used to satisfy PAGCOR and AML compliance requirements;
• From regulatory and fraud-prevention databases: Cross-reference checks against self-exclusion registries and AML watchlists as required by law.

5.1 2ji processes your personal data for the following specific purposes:

• Creating, maintaining, and administering your 2ji account;
• Verifying your identity and eligibility to participate in real-money gaming (KYC/AML compliance);
• Processing deposits, withdrawals, and all financial transactions through supported payment methods including GCash and PayMaya;
• Delivering the gaming services, including game history, session management, and account balance maintenance;
• Operating and personalizing the responsible gaming tools available on your account;
• Detecting, investigating, and preventing fraud, money laundering, bonus abuse, and other prohibited activities;
• Complying with applicable legal, regulatory, and reporting obligations including PAGCOR requirements;
• Providing customer support via live chat and email;
• Sending transactional communications (account confirmations, security alerts, withdrawal notifications);
• Sending marketing communications, where you have provided explicit consent or where a legitimate interest applies;
• Analyzing platform performance and improving the 2ji user experience;
• Enforcing the 2ji Terms & Conditions and defending legal claims.

5.2 Personal data will not be processed for any purpose materially different from those listed above without prior notification and, where required, your explicit consent.

6.1 For each processing activity, 2ji relies on one or more of the following legal bases under RA 10173:

• Contract performance: Processing necessary to provide the services you requested at account registration — including gameplay, payments, and account management;
• Legal obligation: Processing required to comply with AML legislation, PAGCOR requirements, tax reporting obligations, and court or regulatory orders;
• Legitimate interests: Processing for fraud prevention, platform security, abuse detection, and platform improvement — where these interests are not overridden by your data protection rights;
• Consent: Processing for optional marketing communications and non-essential cookies, where your explicit, freely given consent has been obtained and can be withdrawn at any time.

7.1 2ji may share your personal data with the following categories of third parties:

• Payment processors: GCash (Mynt), PayMaya (Maya Philippines), BDO Unibank, Bank of the Philippine Islands, Metrobank, and USDT network providers — solely for the processing of your deposits and withdrawals;
• KYC and AML compliance providers: Accredited identity verification and anti-money laundering screening service providers engaged to satisfy regulatory requirements;
• Gaming software providers: Game studios and live dealer platform providers whose titles are accessible through the 2ji lobby — limited to the session data required to deliver gameplay;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where legally required;
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where necessary to prevent imminent harm or criminal activity;
• Professional advisers: Legal counsel, auditors, and compliance consultants operating under strict confidentiality obligations;
• Platform infrastructure providers: Cloud hosting, cybersecurity, and IT infrastructure vendors engaged under data processing agreements that restrict use to 2ji's specified purposes.

7.2 All third-party service providers engaged by 2ji to process personal data on its behalf are bound by contractual data processing obligations consistent with RA 10173.

8.1 Some of 2ji's service providers may operate or store data outside the Republic of the Philippines. Where personal data is transferred internationally, 2ji ensures that appropriate safeguards are in place consistent with RA 10173 and NPC circulars, including: contractual clauses requiring the recipient to apply equivalent data protection standards; processing only in countries recognized as providing an adequate level of protection; or implementation of binding corporate rules where applicable.

8.2 You may request information about the specific safeguards applied to any international transfer of your data by contacting the 2ji Data Protection Officer at the address in Section 16.

9.1 2ji retains personal data only for as long as is necessary to fulfil the purposes described in Section 5, comply with applicable legal obligations, resolve disputes, and enforce agreements. Specific retention periods are as follows:

• Account and registration data: For the duration of your account plus a minimum of five (5) years after account closure, as required by AML regulations and PAGCOR compliance standards;
• KYC verification documents: A minimum of five (5) years from the date of verification, in line with AMLC record-keeping requirements;
• Financial transaction records: Ten (10) years from the date of each transaction, as required under Philippine financial regulations;
• Gaming activity logs: Five (5) years from the date of activity, for dispute resolution and regulatory audit purposes;
• Marketing and communications data: Until consent is withdrawn or, if processing is on legitimate interest grounds, until the expiry of the relevant limitation period;
• Technical and log data: Ninety (90) days from collection for operational security purposes, unless retained longer in connection with an active investigation.

9.2 Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymized unless retention is required by a continuing legal obligation.

10.1 2ji implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• Encryption in transit: All data transmitted between your device and 2ji servers is encrypted using 256-bit TLS/SSL;
• Encryption at rest: Sensitive personal data stored on 2ji servers is encrypted at the database level using industry-standard encryption algorithms;
• Access controls: Personal data is accessible only to authorized 2ji personnel with a documented business need; access is logged and reviewed regularly;
• Two-factor authentication: Available to all players for account access; mandatory for personnel accessing internal systems containing personal data;
• Regular security assessments: Penetration testing, vulnerability assessments, and security audits are conducted periodically by qualified third-party security professionals;
• Incident response: 2ji maintains a documented data breach response procedure consistent with RA 10173's 72-hour notification obligation to the NPC in the event of a breach affecting personal data.

11.1 The 2ji platform uses cookies and similar tracking technologies to deliver and improve the service. Cookies are small text files placed on your device when you access the platform.

11.2 2ji uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function correctly — including maintaining your login session, enabling the Cashier, and delivering game content. These cannot be disabled without impairing the service;
• Performance cookies: Collect anonymized data on how players use the platform (page load times, error rates, navigation paths) to support ongoing performance optimization;
• Functional cookies: Remember your platform preferences such as language setting, game lobby filters, and notification preferences;
• Analytics cookies: Enable aggregate statistical analysis of platform usage. 2ji uses only privacy-respecting analytics tools that do not share identifiable data with advertising networks.

11.3 Non-essential cookies (performance, functional, analytics) are only placed with your consent, which you may grant or withdraw via the cookie preference center accessible on your first visit to the platform. Withdrawing consent will not affect cookies already placed prior to that point.

11.4 2ji does not use advertising or cross-site tracking cookies. No personal data collected via cookies on 2ji.asia is shared with third-party advertising networks.

12.1 Under Republic Act 10173, you hold the following rights with respect to your personal data held by 2ji:

12.2 To exercise any of the above rights, submit a written request to the 2ji Data Protection Officer using the contact information in Section 16. Requests will be acknowledged within three (3) business days and responded to substantively within fifteen (15) business days of receipt, or such longer period as permitted under RA 10173.

12.3 2ji may require you to verify your identity before processing a data rights request to ensure the security of your personal data.

13.1 2ji may send you promotional communications about offers, new games, bonuses, and VIP events where you have provided explicit consent at registration or in account settings, or where applicable law permits communication on the basis of a prior contractual relationship.

13.2 You may withdraw consent for marketing communications at any time by:

• Updating your notification preferences in Account Settings → Notifications;
• Clicking the unsubscribe link included in any marketing email;
• Contacting 2ji support via live chat or email with a clear opt-out request.

13.3 Withdrawal of marketing consent does not affect transactional communications (such as deposit confirmations, withdrawal notifications, and security alerts), which 2ji may continue to send as these are necessary for the performance of your account contract.

13.4 2ji does not send marketing communications via automated calling systems or fax.

14.1 If you believe that a minor has registered an account at 2ji, please notify us immediately via the contact information in Section 16. We will investigate and act promptly.

15.1 2ji reserves the right to update this Privacy Policy at any time to reflect changes in law, regulatory requirements, or platform practices. Material changes will be communicated to registered players via email and/or a prominent notice on the 2ji platform at least seven (7) calendar days prior to taking effect, unless immediate changes are required by law.

15.2 The effective date at the top of this Policy reflects the date on which the current version came into force. Archived versions of this Policy are available upon request from the DPO.

15.3 Your continued use of the 2ji platform after the effective date of any update constitutes your acknowledgment of the revised Policy. If you do not agree with any changes, you should discontinue use of the platform and may request account closure in accordance with the Terms & Conditions.

16.1 For all privacy-related inquiries, data subject rights requests, and data breach notifications, you may contact the 2ji Data Protection Officer through the following channels:

• Live Chat: 24/7 support available on the 2ji platform — select "Privacy / Data Request" from the support topic menu for fastest routing to the DPO team;
• Email: support@2ji.asia — please include "Privacy Request" in the subject line of your message. Responses are provided within 3 business days of receipt.

16.2 If you believe your data privacy rights have not been adequately addressed by 2ji, you may file a complaint directly with the National Privacy Commission of the Philippines (NPC). The NPC's official complaints process is available through their official government channels.