PHMerry Privacy Policy

01 Introduction

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

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. By accessing or using the PHMerry Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy applies to all registered players, visitors, and any person who interacts with the PHMerry Platform in any capacity. It should be read together with PHMerry's Terms and Conditions, which govern your use of the Platform as a whole.

02 Personal Data We Collect

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

2.1 Identity & Registration Data

• Full legal name
• Date of birth (for age verification — 21+ requirement)
• Government-issued ID number (e.g., Philippine National ID, passport, driver's license)
• Username and account credentials
• Profile photograph (where submitted for verification)

2.2 Contact Data

• Email address
• Mobile phone number
• Residential address (city, province, postal code)

2.3 Financial & Payment Data

• GCash account number or registered mobile number
• PayMaya / Maya Wallet account details
• Bank account details (BPI, BDO, Metrobank, or other approved banks)
• Transaction history, deposit records, and withdrawal records

2.4 Gaming & Activity Data

• Game play history, wager amounts, and outcomes
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool settings and activity

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Cookie identifiers and session tokens
• Pages visited, links clicked, and time spent on the Platform

2.6 Communications Data

• Records of communications with PHMerry customer support
• Feedback, complaints, and dispute records
• Marketing preferences and opt-in/opt-out records

03 How We Collect Your Data

PHMerry collects personal data through the following means:

3.1 Directly From You

The majority of personal data PHMerry holds is provided directly by you when you: register for a PHMerry account; complete identity verification; make a deposit or withdrawal; contact our customer support team; participate in promotions or surveys; or update your account profile settings.

3.2 Automatically Through the Platform

When you access and use the PHMerry Platform, certain technical and behavioral data is collected automatically through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device information, browser type, pages visited, and session activity. See Section 10 for more details on our use of cookies.

3.3 From Third-Party Sources

PHMerry may receive personal data about you from third-party sources in limited circumstances, including:

• Payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank) — to confirm transaction status and verify payment method ownership;
• Identity verification service providers — to assist with Know Your Customer (KYC) compliance;
• Fraud prevention and anti-money laundering (AML) screening services — to detect and prevent financial crime;
• Regulatory authorities — where required by Philippine law or regulatory directive.

04 How We Use Your Personal Data

PHMerry uses the personal data it collects for the following purposes:

PHMerry will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by Philippine law.

05 Legal Basis for Processing

PHMerry processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 (RA 10173) of the Philippines:

• Consent: Where you have given PHMerry your explicit, informed consent to process your personal data for a specific purpose, such as receiving marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Contract Performance: Where processing is necessary to fulfill PHMerry's contractual obligations to you, including operating your account, processing transactions, and providing gaming services.
• Legal Obligation: Where processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering laws, Know Your Customer requirements, and regulatory reporting obligations.
• Legitimate Interest: Where processing is necessary for PHMerry's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your fundamental rights and freedoms.

06 Sharing Your Personal Data

6.1 We Do Not Sell Your Data

PHMerry does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Your personal information is not a product at PHMerry.

6.2 Authorized Third-Party Sharing

PHMerry may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment processors, solely to facilitate deposits and withdrawals;
• Identity Verification Providers: Third-party KYC service providers engaged to assist with age and identity verification;
• Fraud Prevention Services: Providers of anti-fraud and AML screening tools used to protect the integrity of the Platform;
• IT and Infrastructure Providers: Cloud hosting, data storage, and platform infrastructure providers who process data on PHMerry's behalf under strict data processing agreements;
• Customer Support Tools: Third-party helpdesk and live chat software providers used to deliver customer support services;
• Regulatory and Law Enforcement Authorities: Where required by Philippine law, court order, or regulatory directive, PHMerry may disclose personal data to the relevant authorities.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of PHMerry's business, your personal data may be transferred to the relevant successor entity. PHMerry will notify you of any such transfer and ensure that your data continues to be protected in accordance with this Policy.

07 Data Retention

PHMerry retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, PHMerry will securely delete or anonymize your personal data in accordance with its internal data disposal procedures.

08 Data Security

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

• Encryption: All data transmitted between your device and the PHMerry Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption;
• Access Controls: Access to personal data is restricted to authorized PHMerry personnel and service providers on a strict need-to-know basis. All access is logged and audited;
• Secure Payment Processing: PHMerry does not store full payment credentials. All payment data is handled by PCI-DSS compliant payment processors;
• Regular Security Audits: PHMerry conducts regular security assessments and penetration testing to identify and address potential vulnerabilities;
• Incident Response: PHMerry maintains a data breach response plan. In the event of a data breach that poses a risk to your rights, PHMerry will notify affected players and the relevant Philippine authorities in accordance with RA 10173.

09 Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173) of the Philippines, you have the following rights with respect to your personal data held by PHMerry:

To exercise any of these rights, please contact PHMerry's support team at [email protected]. PHMerry will respond to all verified data rights requests within thirty (30) days in accordance with RA 10173. PHMerry may request proof of identity before processing a data rights request to protect against unauthorized access.

10 Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the PHMerry Platform. They allow the Platform to recognize your device, remember your preferences, and provide a more personalized experience. PHMerry also uses similar technologies such as web beacons, pixel tags, and local storage objects.

10.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics Cookies: Help PHMerry understand how players use the Platform, which pages are most visited, and where improvements can be made. Data collected is aggregated and anonymized.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and activity on the Platform. These are only activated with your consent.

10.3 Managing Cookies

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the PHMerry Platform. Strictly necessary cookies cannot be disabled as they are essential for the Platform to operate securely.

11 Minors & Age Policy

The PHMerry Platform is strictly intended for individuals who are 21 years of age or older in accordance with Philippine gambling regulations. PHMerry does not knowingly collect personal data from individuals under the age of 21.

If PHMerry becomes aware that personal data has been collected from a person under 21 years of age, it will take immediate steps to delete that data and close the associated account. All deposits made by underage users will be returned to the original payment method after deducting any amounts wagered, and any winnings will be forfeited.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to PHMerry, please contact us immediately at [email protected] so that we can take appropriate action.

12 International Data Transfers

PHMerry primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, such as cloud infrastructure providers or international fraud prevention services.

Where such transfers occur, PHMerry ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012 and the standards set by the National Privacy Commission of the Philippines. These safeguards may include data processing agreements incorporating standard contractual clauses or transfers to jurisdictions recognized as providing an adequate level of data protection.

13 Changes to This Privacy Policy

PHMerry reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, PHMerry will notify registered players by email or by posting a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is always displayed at the top of this Policy. We encourage you to review this Policy periodically to stay informed about how PHMerry protects your personal data. Continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Policy.

For minor, non-material changes such as typographical corrections or clarifications that do not affect your rights, PHMerry may update the Policy without prior notice, effective immediately upon posting.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way PHMerry handles your personal data, please do not hesitate to reach out to our team. We are committed to addressing all privacy-related inquiries promptly and transparently.