ernph Privacy Policy

1. Introduction

ernph ("ernph," "we," "us," "our") is committed to protecting the privacy and personal data of every player who uses the ernph online gaming platform. This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

This Privacy Policy describes the types of personal information ernph collects from you, the purposes for which that information is processed, the parties with whom it may be shared, the security measures ernph employs to protect it, and the rights available to you as a data subject under Philippine law. Please read this document carefully. If you have questions about how ernph handles your personal data, contact details for our Data Protection Officer (DPO) are provided at the end of this Policy.

2. Personal Data We Collect

ernph collects the following categories of personal data from players and visitors to the ernph Platform:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued Philippine identification document
• Date of birth (used to verify the 21+ age requirement)
• Gender (optional, for personalization purposes)
• Residential address in the Philippines
• Philippine mobile number
• Email address

2.2 Verification & KYC Data

• Copies of government-issued Philippine identification documents (e.g., PhilSys ID, passport, driver's license, SSS/GSIS ID, Voter's ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or liveness verification images where required for identity confirmation

2.3 Financial Data

• GCash or PayMaya/Maya account reference numbers (not full credentials)
• Philippine bank account details for withdrawal processing (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank)
• Debit card details (card number, expiry — stored in tokenized form only)
• Transaction history: deposits, withdrawals, wager amounts, and winnings in Philippine Peso (PHP)

2.4 Gaming & Behavioral Data

• Game session logs, including games played, wager amounts, outcomes, and session duration
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Customer support interaction records

2.5 Technical & Device Data

• IP address and approximate geolocation (province/city level)
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform access timestamps and login history

3. How We Collect Your Data

ernph collects personal data through the following means:

• Direct submission: Information you provide when registering an ernph account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and behavioral data collected automatically as you use the ernph Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from licensed KYC/AML service providers; payment confirmation data from GCash, PayMaya, and Philippine banking partners; fraud detection signals from security service providers.

4. Purpose and Legal Basis for Processing

ernph processes your personal data only for specified, legitimate purposes. The table below summarizes the primary purposes and the corresponding legal basis under the Data Privacy Act of 2012:

Where ernph relies on your consent as the legal basis for processing (e.g., marketing communications, personalization), you have the right to withdraw that consent at any time by updating your communication preferences in your ernph account settings or by contacting our DPO.

5. Sharing Your Personal Data

ernph does not sell your personal data to third parties. ernph may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• KYC and identity verification providers: Licensed third-party providers that assist ernph in verifying player identities and complying with AML obligations.
• Payment processors: GCash, PayMaya/Maya, and Philippine banking partners involved in processing your deposits and withdrawals.
• Game content providers: Licensed game studios and live dealer operators whose games are available on the ernph Platform, to the extent necessary for game operation and dispute resolution.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors who process data on ernph's behalf under strict contractual obligations.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• Legal and professional advisors: Lawyers, auditors, and compliance consultants engaged by ernph, subject to professional confidentiality obligations.

All third-party service providers engaged by ernph are required to process personal data only in accordance with ernph's instructions and applicable Philippine data protection law.

6. Data Retention

ernph retains your personal data for as long as your ernph account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods include:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, in accordance with AML regulations and PAGCOR requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming session logs: Retained for a minimum of two (2) years for dispute resolution and regulatory audit purposes.
• Marketing consent records: Retained for the duration of your consent and for one (1) year thereafter as evidence of consent.
• Customer support records: Retained for two (2) years from the date of the last interaction.

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

7. Data Security

ernph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the ernph Platform.
• Encryption at rest for sensitive personal and financial data stored on ernph's servers.
• Tokenization of payment card details — ernph does not store raw card numbers.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the ernph Platform.
• Multi-factor authentication (MFA) for ernph staff accessing systems containing personal data.
• Incident response procedures aligned with NPC breach notification requirements under the Data Privacy Act.

While ernph takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your ernph login credentials and for notifying ernph immediately if you suspect unauthorized access to your account.

8. Cookies and Tracking Technologies

The ernph Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and analyze Platform usage. The categories of cookies used by ernph include:

• Strictly necessary cookies: Required for the ernph Platform to function. These cannot be disabled. They include session authentication tokens and security cookies.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Collect anonymized data about how players use the ernph Platform to help ernph improve its services. ernph uses privacy-respecting analytics tools that do not share raw user data with third-party advertising networks.
• Marketing cookies: Used only with your consent to deliver relevant ernph promotions. You may withdraw consent at any time via your account settings.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the ernph Platform.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by ernph:

• Right to be informed: The right to know what personal data ernph collects and how it is processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data ernph holds about you.
• Right to rectification: The right to request correction of 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 ernph's legal retention obligations.
• Right to object: The right to object to the processing of your personal data where ernph relies on legitimate interest as the legal basis, including objecting to direct marketing communications.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ernph has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact ernph's Data Protection Officer using the contact details provided in Section 13 of this Policy. ernph will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

10. Minors and Age Verification

The ernph Platform is strictly intended for persons who are 21 years of age or older, in accordance with applicable Philippine gaming regulations. ernph does not knowingly collect personal data from individuals under 21 years of age. Age verification is conducted as part of the account registration and KYC process.

If ernph becomes aware that personal data has been collected from a person under 21 years of age, ernph will promptly close the associated account, void any transactions, and securely delete the personal data of the underage individual. If you believe that a minor has registered an ernph account, please notify our DPO immediately.

11. Responsible Gaming and Data Processing

ernph processes certain personal and behavioral data specifically to support responsible gaming obligations. This includes monitoring gaming patterns to identify signs of problem gambling behavior, administering self-exclusion requests, enforcing deposit and session limits set by players, and complying with any player protection directives issued by PAGCOR.

Self-exclusion data is treated with the highest level of confidentiality. When a player activates self-exclusion on the ernph Platform, that player's data is flagged to prevent re-registration for the duration of the exclusion period. ernph will not use self-exclusion data for marketing purposes.

For more information about the responsible gaming tools available on the ernph Platform, please visit our Responsible Gaming page.

Gambling is addictive. Know when to stop.

12. Changes to This Privacy Policy

ernph reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or ernph's data processing practices. The date of the most recent revision is displayed at the top of this page. Where changes are material, ernph will notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the ernph Platform following notification of changes constitutes your acceptance of the revised Privacy Policy.

13. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or ernph's handling of your personal data, please contact ernph's designated Data Protection Officer:

• Email: [email protected]
• Support Email: [email protected]
• Response Time: Within 15 business days of receipt of your request
• Operating Hours: Monday to Sunday, 8:00 AM – 12:00 midnight Philippine Time

If you are not satisfied with ernph's response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.