10ji Privacy Policy

1. Introduction and Scope

Welcome to the Privacy Policy of 10ji ("10ji," "we," "us," or "our"), the online gaming and sports betting platform accessible at https://10ji.cam (the "Website" or "Platform"). This Privacy Policy describes how 10ji collects, uses, stores, protects, discloses, and otherwise processes your personal information when you access or use our Website, mobile applications, gaming services, and all related products and services (collectively, the "Services").

At 10ji, we are committed to protecting your privacy and ensuring the security of your personal data in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as all relevant Philippine laws and regulations governing data protection and online gaming operations. We recognize the importance of safeguarding the personal information entrusted to us by our players and have implemented comprehensive technical, organizational, and administrative security measures to protect your data against unauthorized access, disclosure, alteration, or destruction.

By registering an account with 10ji, accessing the Website, using our Services, or otherwise providing your personal information to us, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. If you do not agree with any provision of this Privacy Policy, you must immediately cease using the Services and refrain from providing any personal information to us.

2. Information We Collect

2.1 Personal Information You Provide

When you register an account, make deposits, request withdrawals, claim bonuses, or otherwise interact with the Services, we collect personal information that you voluntarily provide to us, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, place of birth, government-issued identification numbers (e.g., passport number, driver's license number, UMID number, SSS number), and copies of identification documents submitted for verification purposes.
• Contact Information: Residential address, email address, mobile phone number, and other contact details.
• Account Credentials: Username, password, security questions and answers, and other authentication information.
• Financial Information: Payment method details (e.g., GCash account number, Maya account number, bank account number, credit/debit card details), billing address, transaction history, deposit and withdrawal records, and source of funds documentation.
• Communication Data: Correspondence sent through customer support channels, live chat conversations, emails, phone calls, and other communications with 10ji staff or automated systems.
• Marketing Preferences: Communication preferences, newsletter subscriptions, and consent for promotional materials.
• Verification Documents: Proof of identity (government-issued ID), proof of address (utility bills, bank statements), selfies with ID, and other documents required for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.

2.2 Information Automatically Collected

When you access or use the Services, we automatically collect certain technical and usage information through cookies, web beacons, log files, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), mobile network information, and hardware model.
• Usage Data: Pages visited, features used, games played, bets placed, bet amounts, win/loss records, session duration, click patterns, navigation paths, and other interactions with the Platform.
• Technical Data: IP address, geolocation data (country, city, region), internet service provider, referring/exit pages, timestamps, and error logs.
• Cookie Data: Session cookies, preference cookies, analytics cookies, and advertising cookies (subject to your consent). For detailed information about cookies, please refer to Section 8 (Cookies and Tracking Technologies).

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: GCash, Maya, banks, and other payment service providers may provide us with transaction verification, payment status updates, and fraud prevention information.
• Identity Verification Services: Third-party identity verification and document authentication services used to verify your identity and prevent fraud.
• Game Providers: Casino game developers and sports betting data providers who supply gaming content and results.
• Marketing Partners: Affiliate networks, advertising platforms, and marketing agencies that refer players to 10ji may provide referral information and campaign performance data.
• Publicly Available Sources: Information from public databases, social media profiles (if you choose to register using social media login), and other publicly accessible sources used for verification and fraud prevention purposes.

3. How We Use Your Information

10ji processes your personal information for the following legitimate purposes in accordance with applicable data protection laws:

3.1 Account Management and Service Delivery

• Create, maintain, and manage your player account.
• Process your registration, login, and authentication.
• Provide access to casino games, sports betting, and other gaming services.
• Process deposits, withdrawals, and financial transactions.
• Manage your bonuses, promotions, and loyalty rewards.
• Maintain your gaming history, transaction records, and account balance.
• Provide customer support and respond to your inquiries.

3.2 Legal and Regulatory Compliance

• Verify your identity and age to ensure compliance with Philippine gaming laws (21+ age requirement).
• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Philippine law.
• Conduct Enhanced Due Diligence (EDD) for high-risk transactions and high-value players.
• Report suspicious transactions to the Anti-Money Launlaundering Council (AMLC) and other regulatory authorities as required by law.
• Maintain records for audit, inspection, and regulatory reporting purposes.
• Respond to lawful requests from government authorities, law enforcement agencies, and courts.
• Comply with tax reporting obligations and other legal requirements.

3.3 Security, Fraud Prevention, and Risk Management

• Detect, prevent, and investigate fraudulent activities, money laundering, bonus abuse, collusion, and other prohibited conduct.
• Monitor account activity for suspicious patterns and unauthorized access.
• Implement security measures to protect the Platform from cyberattacks, hacking attempts, and technical vulnerabilities.
• Verify the authenticity of transactions and prevent chargebacks.
• Enforce our Terms and Conditions and other policies.
• Protect the rights, property, and safety of 10ji, our players, and third parties.

3.4 Marketing and Communications

Subject to your consent and marketing preferences:

• Send promotional emails, SMS messages, push notifications, and other marketing communications about bonuses, promotions, tournaments, new games, and special offers.
• Personalize marketing content based on your gaming preferences, activity history, and demographic information.
• Conduct surveys, request feedback, and invite you to participate in loyalty programs or VIP clubs.
• Display targeted advertisements on the Platform and third-party websites (subject to cookie consent).

You may opt out of marketing communications at any time by clicking the "unsubscribe" link in emails, adjusting your account settings, or contacting customer support. Please note that opting out of marketing communications will not affect transactional or service-related messages (e.g., account notifications, security alerts, withdrawal confirmations).

3.5 Analytics and Service Improvement

• Analyze user behavior, gaming patterns, and Platform performance to improve the Services.
• Conduct statistical analysis, market research, and business intelligence activities.
• Develop new features, games, and services based on player preferences.
• Optimize website design, user experience, and functionality.
• Troubleshoot technical issues and monitor system performance.

3.6 Responsible Gaming and Player Protection

• Implement deposit limits, loss limits, session time limits, and other responsible gaming tools.
• Monitor for signs of problem gambling and intervene when necessary.
• Process self-exclusion requests and maintain exclusion lists.
• Provide access to responsible gaming resources and support services.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and Philippine data protection regulations, we process your personal information based on the following legal grounds:

• Contract Performance: Processing is necessary to fulfill our contractual obligations to provide the Services, process transactions, and manage your account in accordance with our Terms and Conditions.
• Legal Obligation: Processing is required to comply with Philippine laws and regulations, including gaming laws, anti-money laundering laws, tax laws, and data protection laws.
• Consent: You have provided explicit consent for specific processing activities such as marketing communications, use of cookies, and processing of sensitive personal information.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security, service improvement, and business analytics, provided that such interests are not overridden by your fundamental rights and freedoms.
• Vital Interests: In rare circumstances, processing may be necessary to protect the vital interests of you or another person (e.g., emergency situations).

5. How We Share Your Information

10ji does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may disclose your information to the following categories of recipients under strict confidentiality and data protection obligations:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers who process personal information on our behalf to support the Services, including:

• Payment Processors: GCash, Maya, banks, and other payment service providers who facilitate deposits and withdrawals.
• Identity Verification Services: Third-party vendors who verify customer identity, authenticate documents, and conduct KYC/AML checks.
• Game Providers: Casino game developers, live dealer providers, sports betting data suppliers, and gaming platform integrators.
• Cloud Hosting Providers: Data centers and cloud infrastructure providers who host the Platform and store data securely.
• Analytics and Marketing Providers: Analytics platforms (e.g., Google Analytics), email marketing services, SMS gateways, push notification services, and advertising networks.
• Customer Support Services: Live chat providers, helpdesk software, and customer relationship management (CRM) systems.
• Cybersecurity and Fraud Prevention Services: Security monitoring tools, fraud detection systems, and anti-cheat software providers.

All service providers are contractually obligated to protect your personal information, use it only for the purposes specified by 10ji, and comply with applicable data protection laws.

5.2 Regulatory Authorities and Law Enforcement

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

• Comply with legal obligations, court orders, subpoenas, or regulatory requests.
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC) or other financial intelligence units.
• Cooperate with law enforcement investigations involving fraud, money laundering, illegal gambling, or other criminal activities.
• Respond to requests from gaming regulators and licensing authorities.
• Protect the rights, property, or safety of 10ji, our players, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, corporate reorganization, sale of assets, bankruptcy, or other business transaction, your personal information may be transferred to the successor entity or acquiring party, subject to the same data protection obligations outlined in this Privacy Policy.

5.4 Affiliates and Group Companies

We may share your information with our parent company, subsidiaries, affiliates, and related entities within our corporate group for internal administration, service delivery, fraud prevention, and other legitimate business purposes.

6. Data Security Measures

10ji employs comprehensive technical, organizational, and administrative security measures to protect your personal information against unauthorized access, disclosure, alteration, destruction, or loss:

6.1 Technical Security Controls

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard 256-bit SSL/TLS encryption. Sensitive data stored in our databases is encrypted at rest.
• Secure Servers: Personal data is stored on secure servers located in certified data centers with 24/7 physical security, access controls, surveillance, and environmental protections.
• Firewalls and Intrusion Detection: Our network infrastructure is protected by enterprise-grade firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) that monitor for suspicious activity.
• Regular Security Audits: We conduct regular security assessments, vulnerability scans, and penetration testing to identify and remediate potential security risks.
• Secure Payment Processing: All payment transactions are processed through PCI-DSS compliant payment gateways and processors that meet international security standards.

6.2 Organizational Security Measures

• Access Controls: Access to personal data is restricted on a need-to-know basis and granted only to authorized employees and service providers who require access to perform their duties.
• Employee Training: All employees receive mandatory data protection and security awareness training to ensure proper handling of personal information.
• Confidentiality Agreements: Employees and service providers are bound by strict confidentiality obligations and are prohibited from disclosing or misusing personal data.
• Data Protection Officer: We have appointed a Data Protection Officer (DPO) responsible for overseeing data protection compliance and serving as the primary contact for privacy inquiries.
• Incident Response Plan: We maintain a comprehensive data breach response plan to detect, investigate, contain, and report security incidents in accordance with legal requirements.

6.3 Account Security Best Practices

While we implement robust security measures, you also play a critical role in protecting your account. We recommend:

• Choose a strong, unique password that includes uppercase letters, lowercase letters, numbers, and special characters.
• Never share your username, password, or security questions with anyone.
• Log out of your account after each session, especially on shared or public devices.
• Keep your contact information (email, phone number) up to date to receive important security notifications.
• Enable two-factor authentication (2FA) if available to add an extra layer of security.
• Immediately notify customer support if you suspect unauthorized access to your account.
• Be cautious of phishing emails, fake websites, or fraudulent communications claiming to be from 10ji.

7. Data Retention and Deletion

10ji retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests.

7.1 Retention Periods

The specific retention period depends on the type of data and the purpose for which it is processed:

• Account and Transaction Data: Retained for the duration of your account relationship plus seven (7) years after account closure, as required by Philippine anti-money laundering laws and tax regulations.
• Identity Verification Documents: Retained for seven (7) years after account closure or last verification, in accordance with KYC/AML recordkeeping requirements.
• Communication Records: Customer support interactions, emails, and live chat transcripts are retained for five (5) years for quality assurance, dispute resolution, and regulatory purposes.
• Marketing Data: Marketing preferences and consent records are retained until you withdraw consent or request deletion, plus one (1) year to evidence compliance.
• Technical and Usage Data: Log files, IP addresses, and device information are typically retained for 12 to 24 months unless longer retention is required for security or fraud investigation purposes.
• Closed Account Data: After voluntary account closure, your personal information is anonymized or deleted within 90 days, except for data that must be retained for legal, regulatory, or business purposes.

7.2 Secure Deletion

When personal information is no longer needed and retention periods have expired, we securely delete or anonymize the data using industry-standard data destruction methods that prevent recovery or reconstruction.

8. Cookies and Tracking Technologies

10ji uses cookies, web beacons, pixels, local storage, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, personalize content, and deliver targeted advertising. A cookie is a small text file stored on your device that allows us to recognize you and remember your preferences.

8.1 Types of Cookies We Use

• Essential Cookies: Strictly necessary for the operation of the Website, including authentication, session management, security, and fraud prevention. These cookies cannot be disabled without affecting the functionality of the Services.
• Performance Cookies: Collect anonymous information about how visitors use the Platform, such as pages visited, error messages, and load times. This data helps us improve website performance and user experience.
• Functionality Cookies: Remember your preferences, settings, language selection, and customization choices to provide a more personalized experience.
• Marketing and Advertising Cookies: Used to deliver relevant advertisements, track campaign performance, and measure the effectiveness of marketing efforts. These cookies may track your activity across multiple websites.

8.2 Managing Cookie Preferences

You can manage your cookie preferences through your browser settings or our cookie consent tool. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may prevent you from accessing certain features of the Platform.

9. International Data Transfers

While 10ji primarily operates within the Philippines and stores data in Philippine data centers, certain service providers and business partners may process your personal information in other countries. When we transfer data internationally, we ensure that appropriate safeguards are in place to protect your information, including:

• Contractual data protection clauses requiring recipients to provide equivalent levels of protection as required under Philippine law.
• Verification that the recipient country has adequate data protection laws recognized by Philippine authorities.
• Implementation of technical and organizational security measures to protect data in transit and at rest.

10. Your Data Protection Rights

Under the Data Privacy Act of 2012 and Philippine data protection regulations, you have the following rights regarding your personal information:

10.1 Right to Access

You have the right to request access to the personal information we hold about you, including details about how your data is processed, who it is shared with, and how long it will be retained. You can access most of your account information directly through your account settings or by contacting customer support.

10.2 Right to Rectification

You have the right to request correction of inaccurate, incomplete, or outdated personal information. You can update most information directly in your account settings. For verification documents or other sensitive information, please contact our Data Protection Officer.

10.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal information under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, you withdraw consent, or you object to processing. Please note that we may be required to retain certain information for legal, regulatory, or business purposes even after you request deletion.

10.4 Right to Data Portability

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

10.5 Right to Object and Restrict Processing

You have the right to object to certain types of data processing, such as direct marketing, profiling, and processing based on legitimate interests. You may also request restriction of processing in certain circumstances while we investigate your concerns.

10.6 Right to Withdraw Consent

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

10.7 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 13. We will respond to your request within fifteen (15) days as required by Philippine law. In complex cases, we may extend the response time to a maximum of thirty (30) days with notice.

11. Children's Privacy

The Services are not intended for individuals under the age of twenty-one (21) years. 10ji does not knowingly collect, process, or solicit personal information from minors. If we become aware that we have collected personal information from a person under 21 years of age, we will immediately delete that information and close the associated account.

Parents or guardians who believe that a minor has provided personal information to 10ji should immediately contact our Data Protection Officer to request deletion of the information.

12. Changes to This Privacy Policy

10ji reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, business operations, or technological developments. Material changes to this Privacy Policy will be communicated to you via email, Platform notification, or prominent notice on the Website at least seven (7) days before the effective date of the changes.

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

13. Contact Information and Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy, our data processing practices, or your privacy rights, please contact our Data Protection Officer:

We aim to respond to all privacy inquiries within fifteen (15) days. For urgent matters related to data breaches or security incidents, please contact us immediately through live chat or email with "URGENT PRIVACY MATTER" in the subject line.

14. Complaints and Regulatory Authority

If you believe that your data protection rights have been violated or you are not satisfied with our response to your privacy complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines: