vipph1 Privacy Policy

1 Introduction

vipph1 ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every Filipino player who uses our online gaming platform. This Privacy Policy ("Policy") describes how vipph1 collects, processes, stores, shares, and protects personal information in connection with your use of the vipph1 website and all associated services.

This Policy applies to all registered players, visitors, and any other individuals whose personal data is processed by vipph1 in the course of operating the Platform. By registering an account or using any part of the vipph1 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

vipph1 acts as the Personal Information Controller ("PIC") in respect of the personal data it collects and processes. We are committed to full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission ("NPC") of the Philippines.

2 Personal Data We Collect

vipph1 collects the following categories of personal data from players and users of the Platform:

We collect only the minimum personal data necessary for the purposes described in this Policy. We do not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required by law or regulation, such as for AML compliance purposes.

3 How We Collect Your Data

vipph1 collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated Collection: Technical and usage data collected automatically when you access or use the Platform, including through cookies, web beacons, and similar tracking technologies;
• Third-Party Sources: Information received from payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention agencies, and regulatory bodies where permitted by law;
• Public Sources: Publicly available information used for identity verification or fraud prevention purposes, where applicable.

4 How We Use Your Personal Data

vipph1 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your vipph1 player account, including processing your registration and verifying your identity;
• Service Delivery: To provide you with access to games, process deposits and withdrawals, and deliver the full range of vipph1 services;
• Regulatory Compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations under Republic Act No. 9160 (as amended), and other applicable Philippine laws and regulations;
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit limits and self-exclusion requests, and fulfil our duty of care to players;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other security threats;
• Customer Support: To respond to your enquiries, resolve disputes, and provide assistance through our 24/7 support team;
• Marketing & Promotions: To send you information about vipph1 promotions, bonuses, and new features, where you have consented to receive such communications;
• Platform Improvement: To analyse usage patterns, conduct research, and improve the functionality and user experience of the vipph1 Platform.

5 Legal Basis for Processing

vipph1 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications;
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and vipph1, including operating your account and processing transactions;
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to vipph1, including PAGCOR regulations, AML laws, and NPC directives;
• Legitimate Interests: Where processing is necessary for the legitimate interests of vipph1, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.

6 Data Sharing & Disclosure

vipph1 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements;
• Game Providers: Licensed game software providers whose games are available on the vipph1 Platform, to the extent necessary for game operation and dispute resolution;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities, where required by law;
• IT & Security Service Providers: Cloud hosting, cybersecurity, and technical support providers engaged to operate and secure the Platform;
• Professional Advisers: Legal, accounting, and compliance advisers, subject to professional confidentiality obligations.

7 Cookies & Tracking Technologies

vipph1 uses cookies and similar tracking technologies to enhance your experience on the Platform, ensure security, and gather analytics data. The types of cookies we use include:

• Essential Cookies: Strictly necessary for the Platform to function, including session management and security cookies. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings and game preferences, to personalise your experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping us improve our services.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns, where you have consented.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. By continuing to use the vipph1 Platform, you consent to our use of cookies as described in this Policy.

8 Data Retention

vipph1 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AML regulatory requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Republic Act No. 9160 (Anti-Money Laundering Act);
• Gaming History: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes;
• Marketing Data: Retained until you withdraw your consent or request erasure, whichever is earlier;
• Technical & Log Data: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with our data disposal procedures.

9 Data Security

vipph1 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the vipph1 Platform;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Multi-factor authentication options for player accounts;
• Regular security audits, penetration testing, and vulnerability assessments;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Continuous monitoring of Platform systems for suspicious activity and potential security incidents.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, vipph1 will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

10 Your Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by vipph1:

• Right to be Informed: The right to be informed of how your personal data is collected, processed, and used, as set out in this Policy;
• Right of Access: The right to request a copy of the personal data vipph1 holds about you;
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at the details provided in Section 14. We will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines.

11 Children's Privacy

The vipph1 Platform is strictly intended for persons aged twenty-one (21) years and above, in accordance with Philippine law and PAGCOR regulations. vipph1 does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the vipph1 Platform, please contact us immediately at the details provided in Section 14.

12 Cross-Border Data Transfers

In certain circumstances, vipph1 may transfer your personal data to service providers or partners located outside the Philippines, such as cloud infrastructure providers or international game software suppliers. Any such cross-border transfer of personal data will be conducted in accordance with Section 21 of the Data Privacy Act of 2012 and relevant NPC guidelines, ensuring that the recipient country or organisation provides an adequate level of data protection.

Where required, vipph1 will implement appropriate safeguards such as standard contractual clauses or binding corporate rules to protect your personal data during any international transfer.

13 Updates to This Privacy Policy

vipph1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via the contact details associated with their account and post a prominent notice on the Platform.

The date of the most recent revision is indicated at the top of this page. We encourage you to review this Policy periodically. Your continued use of the vipph1 Platform following the posting of any updated Policy constitutes your acceptance of the revised terms.

14 Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by vipph1, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on the Platform
• Response Time: Within fifteen (15) business days for formal data subject requests

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your privacy concern.