Privacy Policy — eeeph

1. Who We Are

eeeph is an online casino and sports betting platform serving Filipino players across the Philippines — from Metro Manila (Makati, Quezon City, Manila) to Cebu, Davao, and beyond. eeeph operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to Philippine law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR).

As a regulated online gaming operator, eeeph is legally obligated to collect and process certain categories of personal data for identity verification, anti-money laundering compliance, regulatory reporting, and responsible gaming purposes. This policy explains in plain terms what data we collect, why we need it, how we protect it, and what rights you have over it.

2. Personal Data We Collect

eeeph collects personal data in the following categories:

We do not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for KYC or AML compliance and with appropriate legal basis.

3. How We Collect Personal Data

eeeph collects personal data through the following means:

• Direct submission — information you provide during account registration, KYC verification, withdrawal requests, and support interactions.
• Automated collection — technical data collected automatically when you access the eeeph platform, including via cookies, log files, and session tracking technology.
• Third-party verification — identity and financial data verified through accredited KYC providers and payment processors such as GCash and Maya.
• Regulatory sources — in limited circumstances, data shared with eeeph by PAGCOR or other regulatory authorities as part of compliance obligations.

4. How We Use Your Personal Data

eeeph uses your personal data for the following purposes:

• Account registration and management — to create and maintain your eeeph account, verify your identity, and provide access to platform services.
• Service delivery — to process bets, casino game play, deposits, and withdrawals; to credit winnings and bonuses to your account.
• Identity and age verification (KYC) — to comply with PAGCOR requirements confirming that all Players are 21 years of age or older and are who they claim to be.
• Anti-money laundering (AML) compliance — to monitor transactions for suspicious activity in accordance with the Anti-Money Laundering Act (RA 9160, as amended) and PAGCOR AML directives.
• Fraud and security — to detect, prevent, and investigate fraudulent activity, account compromise, collusion, or prohibited conduct on the platform.
• Responsible gaming — to monitor gaming behaviour and identify players who may be at risk, and to enforce deposit limits, self-exclusion, and cooling-off periods you have set.
• Customer support — to respond to your enquiries, resolve disputes, and improve our support services.
• Marketing communications — to send you relevant promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Legal and regulatory compliance — to fulfil reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, eeeph processes your personal data under the following legal bases:

• Contractual necessity — processing required to perform the contract between you and eeeph (account provision, game play, payments).
• Legal obligation — processing required to comply with PAGCOR regulations, AML legislation, and other applicable Philippine law.
• Legitimate interests — processing necessary for eeeph's legitimate interests in fraud prevention, security, and platform improvement, where such interests are not overridden by your rights.
• Consent — for marketing communications and any processing not falling within the above categories. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 eeeph does not sell your personal data to third parties. We share personal data only in the following circumstances:

• Service providers — with carefully selected third-party processors who assist in platform operations, including payment processors (GCash, Maya, BPI, BDO, Metrobank), KYC verification providers, cloud infrastructure providers, and customer support platforms. All processors are contractually bound to process data only on eeeph's instructions and to maintain appropriate security standards.
• Regulatory authorities — with PAGCOR, the Anti-Money Laundering Council, the National Privacy Commission, and other Philippine government bodies where disclosure is required by law or regulatory mandate.
• Law enforcement — where required by a valid court order, warrant, or other lawful authority issued under Philippine law.
• Business transfers — in the event of a merger, acquisition, or transfer of eeeph's business assets, personal data may be transferred to the successor entity, subject to equivalent privacy protections.

6.2 eeeph does not transfer personal data outside the Philippines except where necessary for payment processing via internationally operated services (e.g., card scheme processors), in which case equivalent data protection safeguards are maintained through contractual mechanisms.

7. Data Retention

7.1 eeeph retains personal data for the period necessary to fulfil the purposes described in this policy, subject to the following minimum retention periods mandated by Philippine law:

• KYC and identity records — minimum five (5) years from account closure, in accordance with AMLC requirements.
• Transaction records — minimum five (5) years from the date of transaction.
• Gaming and betting records — minimum three (3) years from the date of the relevant gaming session.
• Account data — retained for the duration of the account and for a minimum of three (3) years following account closure.
• Marketing consent records — until consent is withdrawn, plus a reasonable period thereafter for evidentiary purposes.

7.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents re-identification.

8. Security Measures

eeeph implements a comprehensive set of technical and organisational security measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data in transit between your device and eeeph servers.
• Encryption at rest for stored personal data, including financial records and identity documents.
• Hashed password storage — your login password is stored only as a cryptographic hash. eeeph staff cannot view your plaintext password.
• Multi-factor authentication — OTP verification on login from unrecognised devices and on high-value withdrawal requests.
• Access controls — personal data is accessible only to eeeph staff with a legitimate operational need, under role-based access control policies.
• Security monitoring — continuous monitoring for unauthorised access attempts, anomalous login activity, and data breach indicators.
• Regular security assessments — periodic vulnerability assessments and penetration testing of platform infrastructure.

9. Cookies and Tracking Technologies

9.1 eeeph uses cookies and similar tracking technologies on the platform. Cookies are small text files stored on your device that help us deliver and improve our services.

9.2 Types of cookies used:

• Strictly necessary cookies — required for platform functionality, including session management and security. These cannot be disabled without breaking core platform features.
• Functional cookies — remember your preferences (language, game settings, remembered login) to improve your experience.
• Analytics cookies — collect aggregated, anonymised data about how Players use the platform to help us improve navigation, performance, and content. No individual Player is identifiable from analytics data.
• Marketing cookies — used only where you have consented, to personalise promotional content shown within the eeeph platform.

9.3 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair platform functionality. Disabling other categories will not affect your ability to use eeeph's core gaming services.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by eeeph:

• Right to be informed — to be notified of how your personal data is being processed (which this policy fulfils).
• Right of access — to request a copy of the personal data eeeph holds about you.
• Right to rectification — to request correction of inaccurate or incomplete personal data.
• Right to erasure ("right to be forgotten") — to request deletion of your personal data, subject to eeeph's retention obligations under PAGCOR and AML regulations, which may require us to retain certain data regardless of an erasure request.
• Right to data portability — to receive your personal data in a structured, machine-readable format.
• Right to object — to object to processing based on legitimate interests, including profiling for direct marketing purposes.
• Right to withdraw consent — to withdraw consent for processing based on consent at any time, without affecting prior lawful processing.
• Right to lodge a complaint — to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe eeeph has mishandled your personal data.

To exercise any of these rights, contact eeeph's Data Protection Officer at [email protected]. eeeph will respond to data subject requests within fifteen (15) business days.

11. Children's Privacy

The eeeph platform is strictly for persons aged 21 years and above, in compliance with PAGCOR regulations governing online gambling in the Philippines. eeeph does not knowingly collect personal data from anyone under 21 years of age. If eeeph becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended and all associated data will be securely deleted.

If you believe a minor has registered on the eeeph platform, please contact eeeph's Data Protection Officer immediately at [email protected].

12. Changes to This Privacy Policy

eeeph reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Material changes will be notified to registered Players via their registered mobile number or email address at least seven (7) days before the updated policy takes effect.

The "Last updated" date at the top of this policy reflects the date of the most recent revision. Continued use of the eeeph platform after the effective date of any revision constitutes acceptance of the updated policy. If you do not accept the revised policy, please discontinue use of the platform and contact support to close your account.

13. Contact and Data Protection Officer

For all privacy-related enquiries, data subject rights requests, or to contact eeeph's designated Data Protection Officer, please use the following channels:

• Email: [email protected] — please use subject line "Privacy / DPO Request"
• Live Chat: Available 24/7 via the eeeph platform website — ask to be connected to the Privacy team.
• Response time: eeeph aims to acknowledge data subject requests within 2 business days and provide a substantive response within 15 business days.

Complaints that are not resolved to your satisfaction may be escalated to the National Privacy Commission of the Philippines, which has jurisdiction over data privacy disputes involving Philippine data subjects.