enjoyph Privacy Policy

1 Who We Are

enjoyph ("we," "us," "our") is the operator of the online gaming platform accessible at enjoyph.vip. For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) of the Republic of the Philippines, enjoyph is the Personal Information Controller in respect of the personal data of its Members and website visitors. All inquiries regarding data processing and privacy rights should be directed to enjoyph's designated Data Protection Officer (see Section 13).

2 Personal Data We Collect

2.1 Registration Data

When you create an Account on the enjoyph Platform, we collect:

• Full legal name as it appears on your government-issued identification.
• Date of birth (for mandatory 21+ age verification).
• Residential address in the Philippines.
• Email address.
• Philippine mobile number.
• Username and encrypted password.

2.2 Identity Verification Data

To comply with applicable Know Your Customer (KYC) and Anti-Money Laundering Act (AMLA) requirements, enjoyph may collect:

• Copies of government-issued identification documents (e.g., PhilSys ID, passport, driver's licence, Unified Multi-Purpose ID).
• Proof of residential address (e.g., utility bill, bank statement).
• Source-of-funds documentation for large deposits or withdrawals, in accordance with AMLA thresholds.
• Selfie photograph for liveness verification, where required.

2.3 Financial & Transaction Data

In connection with deposits and withdrawals, we collect:

• GCash account details (mobile number linked to GCash wallet) or PayMaya account details.
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank).
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment reference numbers.

enjoyph does not store full card numbers or complete banking credentials. Payment processing is handled by certified third-party payment processors operating under their own PCI-DSS compliance frameworks.

2.4 Gaming Activity Data

We collect data about your activity on the Platform, including:

• Games played, bets placed, outcomes, and session durations.
• Bonus claims and wagering history.
• Responsible gaming settings (deposit limits, session reminders, self-exclusion status).

2.5 Technical & Device Data

When you access the Platform, we automatically collect:

• IP address and approximate geolocation (country and region level).
• Device type, operating system, and browser type.
• Pages visited, time spent on pages, and click-stream data.
• Cookie identifiers (see Section 7).

2.6 Communications Data

Records of your communications with enjoyph's customer support team — including live chat transcripts and email correspondence — are retained to facilitate ongoing support, resolve disputes, and improve service quality.

3 How We Collect Your Data

enjoyph collects personal data through the following channels:

• Direct collection: Information you provide when registering an Account, completing KYC verification, depositing or withdrawing funds, contacting customer support, or updating your Account settings.
• Automated collection: Technical data collected automatically when you access and navigate the Platform via cookies, web beacons, and server logs.
• Third-party sources: Identity verification and fraud detection partners may provide supplementary data to assist in KYC compliance, age verification, and fraud prevention. Such third parties operate under contractual data processing agreements with enjoyph.
• Payment processors: Transaction confirmation data received from GCash, PayMaya, and banking partners upon processing of deposits and withdrawals.

4 How We Use Your Personal Data

enjoyph uses personal data collected from Members and visitors for the following purposes:

• Account creation and management: To register your Account, verify your identity, authenticate your login, and administer your Member profile.
• Service delivery: To provide access to games, process bets, settle winnings, process deposits and withdrawals, and deliver customer support.
• Age and identity verification: To verify that you meet the mandatory 21+ age requirement and that your identity matches the information on file.
• Fraud prevention and AML compliance: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct in accordance with the Anti-Money Laundering Act of 2001 (RA 9160) and its amendments.
• Regulatory compliance: To fulfil legal obligations, respond to requests from PAGCOR, AMLC, the NPC, or other lawfully empowered Philippine regulatory authorities.
• Responsible gaming: To monitor gaming behaviour for indicators of problem gambling and to administer responsible gaming tools including deposit limits, cooling-off periods, and self-exclusion.
• Communications: To send you transactional notifications (deposit confirmations, withdrawal updates, security alerts) and, where you have consented, promotional communications about offers and events on the Platform.
• Platform improvement: To analyse usage patterns, test new features, and improve the overall experience of the enjoyph Platform for Filipino players.

5 Legal Bases for Processing

enjoyph processes personal data on the following legal grounds under the Data Privacy Act of 2012:

• Consent: Where you have given clear and informed consent to specific processing activities (e.g., receiving marketing emails). You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Contractual necessity: Processing required to fulfil our obligations under the Terms and Conditions agreed at registration — including account management, game provision, and payment processing.
• Legal obligation: Processing required to comply with applicable laws, including KYC/AML requirements, PAGCOR regulations, and orders from lawfully empowered Philippine government authorities.
• Legitimate interests: Processing necessary for the legitimate interests of enjoyph, including fraud prevention, platform security, and service improvement — provided such interests are not overridden by your fundamental rights and freedoms.

6 Data Sharing & Disclosure

enjoyph does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients under strict conditions:

• Payment processors: GCash (Mynt), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank, for the purpose of processing your deposits and withdrawals. Each processor operates under its own privacy policy and applicable financial regulations.
• KYC and identity verification providers: Third-party providers used to verify government IDs and conduct liveness checks, operating under data processing agreements with enjoyph.
• Game content providers: Software providers that supply games available on the Platform may receive technical session identifiers necessary for game delivery. They do not receive your name, contact details, or financial information.
• Customer support platforms: Cloud-based support tools used to manage live chat and email communications, operating under processor agreements and data protection obligations.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other lawfully empowered Philippine government agencies, where disclosure is required by law or regulatory mandate.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid court order, subpoena, or other lawful process.

All third-party service providers engaged by enjoyph are required to implement appropriate technical and organisational security measures and are prohibited from using your data for their own commercial purposes.

7 Cookies & Tracking Technologies

The enjoyph Platform uses cookies and similar tracking technologies to operate the Platform and enhance your experience. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without disrupting Platform functionality.
• Functional cookies: Store your preferences such as preferred language, remembered login, and responsible gaming settings to personalise your experience across sessions.
• Analytics cookies: First-party analytics tools that collect anonymised usage data — pages visited, session duration, features used — to help enjoyph understand how Filipino players use the Platform and identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other security threats.

You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair Platform functionality, including the ability to log in and play games.

8 Data Retention

enjoyph retains personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following retention guidelines:

• Account data: Retained for the duration of your active Account plus a minimum of 5 years following Account closure, in accordance with AMLA record-keeping requirements.
• KYC documents: Retained for a minimum of 5 years from the date of collection or the date of the last transaction, whichever is later, as required by RA 9160 and PAGCOR regulations.
• Transaction records: Retained for a minimum of 5 years in accordance with AMLA obligations.
• Customer support communications: Retained for 3 years from the date of the last interaction, to enable dispute resolution.
• Technical and device data: Retained for 12 months unless required for longer retention for security investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with enjoyph's data disposal procedures.

9 Data Security

enjoyph implements a comprehensive set of technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit AES encryption for data stored at rest; TLS 1.3 for all data transmitted between your browser and the Platform.
• Bcrypt password hashing — plaintext passwords are never stored.
• Role-based access controls ensuring that only authorised enjoyph personnel can access personal data, and only to the extent necessary for their job function.
• Regular internal and third-party penetration testing and vulnerability assessments.
• Incident response procedures aligned with NPC breach notification requirements under the Data Privacy Act.
• Physical security controls at data centre facilities hosting enjoyph infrastructure.

In the event of a personal data breach that poses a real risk of serious harm to data subjects, enjoyph will notify the National Privacy Commission and affected Members within 72 hours of becoming aware of the breach, in compliance with NPC Circular 16-03.

10 Your Rights Under the Data Privacy Act

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

To exercise any of the above rights, contact enjoyph's Data Protection Officer (see Section 13). Requests are acknowledged within 5 business days and resolved within the timeframes prescribed by the Data Privacy Act and NPC regulations.

11 Children's Privacy

The enjoyph Platform is strictly intended for adults aged 21 years and older. enjoyph does not knowingly collect personal data from individuals under 21. If we become aware that personal data has been collected from a person under 21, the Account will be immediately closed, all data will be deleted, and any transactions reversed where possible. If you are a parent or guardian and believe that your child has registered on the Platform, please contact our support team immediately.

12 Changes to This Privacy Policy

enjoyph reserves the right to update 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 Members via their registered email address and/or via a prominent notice on the Platform, at least 7 days before the changes take effect. The "Last updated" date at the top of this Policy will be revised accordingly. Your continued use of the Platform after the effective date of the updated Policy constitutes your acknowledgement of the changes. We encourage you to review this Policy periodically.

13 Contact & Data Protection Officer

For questions about this Privacy Policy, to exercise your data rights, or to raise a data privacy concern, please contact the enjoyph Data Protection Officer:

• Data Protection Officer: enjoyph DPO Office
• Email: [email protected] (subject line: "Privacy / DPO Request")
• Live Chat: Available 24/7 on the Platform — ask to be transferred to the DPO team for data rights requests.

If you are not satisfied with enjoyph's response to your data privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines.