eeji Privacy Policy

1 Introduction

This Privacy Policy ("Policy") sets out how eeji ("eeji," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal information of users ("Player," "User," or "you") of the eeji online gaming platform accessible at eeji.club (the "Platform").

eeji is committed to protecting the privacy and personal data of all Filipino players in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the data protection requirements established by the Philippine Amusement and Gaming Corporation ("PAGCOR") as part of eeji's operating license conditions.

By registering an account, accessing, or using the eeji Platform in any way, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the Platform.

2 Data Controller Identity

For the purposes of the Philippine Data Privacy Act of 2012, eeji acts as the Personal Information Controller ("PIC") in respect of the personal data collected and processed through the Platform. As PIC, eeji determines the purposes and means by which your personal data is processed.

eeji is a PAGCOR-licensed operator registered and operating within the Republic of the Philippines. Where eeji engages third-party service providers to process personal data on its behalf (for example, payment processors and fraud detection systems), those providers act as Personal Information Processors ("PIPs") and are contractually bound to process data only in accordance with eeji's instructions and this Policy.

Questions, requests, or complaints relating to the processing of your personal data may be directed to eeji's designated Data Protection Officer (DPO), whose contact details are provided in Section 16 of this Policy.

3 Categories of Personal Data We Collect

eeji collects the following categories of personal data from players on the Platform:

eeji does not collect sensitive personal information (as defined under the DPA, including racial or ethnic origin, religious beliefs, health records, or sexual orientation) unless specifically required for responsible gaming assessment purposes and only with your explicit, specific consent.

4 How We Collect Your Data

eeji collects personal data through the following channels and methods:

• Account Registration: When you create an eeji account, you provide identity and contact information directly through the registration form on the Platform.
• KYC Verification: When you submit documents for identity and age verification, eeji collects the information contained in those documents and the accompanying selfie photograph.
• Deposits and Withdrawals: Financial data is collected when you initiate transactions on the Platform, including information passed from your chosen payment provider (GCash, Maya, BPI, BDO, Metrobank, etc.).
• Platform Use: Technical data and gaming activity data are collected automatically as you use the Platform, through server logs, session tracking, and Platform analytics systems.
• Customer Support Interactions: When you contact eeji's support team via live chat or email, your communications are recorded and retained as part of the support record for your account.
• Cookies and Tracking Technologies: eeji uses cookies and similar technologies to collect technical data about your browsing behavior on the Platform. See Section 8 for full details.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, eeji processes your personal data on the following legal grounds:

6 How We Use Your Personal Data

eeji uses the personal data collected from Filipino players for the following specific purposes:

• To verify your identity and age as required by PAGCOR regulations and to activate your account for real-money gaming.
• To process and record your deposits, withdrawals, and all in-game wagering transactions on the Platform.
• To detect and prevent fraud, money laundering, unauthorized account access, and other prohibited activities on the Platform.
• To comply with eeji's AML reporting obligations under Philippine law, including the filing of Suspicious Transaction Reports (STRs) where required by the Anti-Money Laundering Act.
• To provide you with customer support and respond to inquiries, complaints, and account assistance requests.
• To monitor your gaming patterns for responsible gaming purposes, and to implement any player-requested or eeji-imposed responsible gaming restrictions on your account.
• To send you promotional communications about eeji's offers, bonuses, and platform updates — but only where you have provided explicit opt-in consent for such communications.
• To analyze Platform usage patterns (on an aggregated, anonymized basis where possible) to improve eeji's services, game offerings, and user experience for Filipino players.
• To respond to lawful demands from PAGCOR, Philippine law enforcement agencies, or courts requiring disclosure of player data.

7 Sharing and Disclosure of Your Data

eeji does not sell, rent, or trade your personal information to third parties. eeji may share your personal data with the following categories of third parties, strictly for the purposes described:

• Payment Service Providers: GCash, Maya, BPI, BDO, Metrobank, 7-Eleven Cliqq, Coins.ph, and cryptocurrency network processors require transaction data to process deposits and withdrawals on your behalf. Data shared is limited to what is required to complete each transaction.
• Identity Verification Providers: eeji uses third-party KYC verification services to validate identity documents and selfie photographs. These providers process KYC data as Personal Information Processors under contract with eeji.
• Fraud and AML Detection Systems: eeji uses third-party risk management and compliance systems to screen transactions and player profiles against AML watchlists and fraud pattern databases.
• Game Providers: Certain game providers (such as PG Soft and Evolution Gaming) may receive limited technical session data necessary to operate their games within the eeji Platform. They do not receive your identity or financial data.
• PAGCOR: As eeji's licensing regulator, PAGCOR may request player data as part of its regulatory oversight functions. eeji is legally obligated to comply with such requests.
• Philippine Law Enforcement and Courts: eeji will disclose personal data in response to lawful court orders, regulatory demands, or law enforcement requests made in accordance with Philippine law.
• IT and Security Service Providers: Third-party technology vendors that provide Platform hosting, cybersecurity monitoring, and technical infrastructure support may process limited technical data as Personal Information Processors under contract.

8 Cookies and Tracking Technologies

The eeji Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and collect technical usage data. The following types of cookies are used:

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may prevent you from logging in or using core Platform features. eeji does not use third-party advertising or behavioral tracking cookies.

9 Data Security

eeji implements a layered set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data transmitted between your device and eeji's servers is encrypted using Transport Layer Security (TLS) protocols. Sensitive stored data, including passwords and financial identifiers, is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to player personal data within eeji's systems is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data receive data privacy training and are bound by confidentiality obligations.
• Infrastructure Security: eeji's Platform is hosted in secure data center environments with physical access controls, redundant power and connectivity systems, and continuous security monitoring.
• Penetration Testing and Audits: eeji conducts regular security assessments and vulnerability scans to identify and remediate potential weaknesses in its technical infrastructure.
• Incident Response: eeji maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, eeji will notify the National Privacy Commission (NPC) within the timeframe required by the DPA and will notify affected players without undue delay.

10 Data Retention

eeji retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine laws and PAGCOR regulations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with eeji's data disposal procedures. Anonymized data (from which you cannot be identified) may be retained indefinitely for statistical and research purposes.

11 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by eeji. These rights may be exercised by contacting eeji's Data Protection Officer at the details provided in Section 16.

eeji will respond to all verified data subject rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further sixty (60) days, in which case eeji will notify you of the extension and the reason for it. Some rights may be limited where legal retention obligations require eeji to retain data beyond what you request for deletion.

12 Children's Privacy and Age Restriction

eeji enforces the 21+ age requirement through mandatory KYC identity verification on all accounts before real-money gaming is permitted. Providing false age information during registration is a breach of eeji's Terms and Conditions and constitutes fraud.

13 Cross-Border Data Transfers

Some of eeji's third-party service providers — including certain KYC verification platforms, game providers such as PG Soft and Evolution Gaming, and cloud infrastructure providers — may process data outside of the Philippines. Where such cross-border transfers occur, eeji ensures that:

• The recipient country provides an adequate level of data protection comparable to Philippine standards, or
• Appropriate contractual safeguards (such as data processing agreements incorporating DPA-equivalent protections) are in place between eeji and the receiving entity, or
• The transfer is necessary for the performance of your contract with eeji (for example, when a game provider outside the Philippines must process your gaming session data to deliver the game).

eeji does not transfer your financial data, full identity documents, or KYC selfie photographs to any entity outside the Philippines except where specifically required for AML compliance reporting and only to duly authorized regulatory or law enforcement bodies.

14 Marketing Communications

eeji may send you promotional communications about new games, bonus offers, and platform updates by SMS or email. eeji will only send marketing communications where you have provided explicit opt-in consent during account registration or through your Account Settings.

You may withdraw your consent to marketing communications at any time by:

• Updating your communication preferences in your eeji Account Settings;
• Clicking the unsubscribe link included in any promotional email from eeji; or
• Contacting eeji's support team at [email protected] and requesting removal from marketing lists.

Withdrawal of marketing consent will be processed within 5 business days. Please note that even after withdrawing marketing consent, eeji will continue to send you transactional communications that are necessary for the operation of your account — such as deposit confirmations, withdrawal notifications, KYC status updates, and security alerts. These are not marketing communications and cannot be opted out of while your account remains active.

15 Updates to This Privacy Policy

eeji reserves the right to update or revise this Privacy Policy at any time to reflect changes in eeji's data processing practices, Philippine data protection law, PAGCOR regulatory requirements, or Platform features. The effective date of the current version is displayed at the top of this Policy.

Where changes to this Policy are material — meaning they significantly affect the way eeji processes your personal data or the rights available to you — eeji will notify you by email to your registered address and/or via a prominent notice on the Platform at least 14 days before the changes take effect.

Your continued use of the eeji Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must stop using the Platform and request account closure before the changes take effect.

All previous versions of this Privacy Policy are available upon request from eeji's Data Protection Officer.

16 Contact Us and Data Protection Officer

eeji has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. The DPO is your primary point of contact for all data privacy matters, including data subject rights requests, privacy complaints, and questions about eeji's data processing practices.

You may contact eeji's DPO and general support team through the following channels:

• Email: [email protected] — mark your email with the subject line "Data Privacy Request" to ensure it is routed to the DPO team
• Live Chat: Available 24/7 through your logged-in eeji account dashboard
• Correspondence Address: Philippines — PAGCOR-Licensed Entity (full registered postal address available to verified account holders upon written request)