Privacy Policy – greatph Online Casino

1. Data Controller

greatph is the data controller responsible for the personal information collected through the greatph platform. As data controller, greatph determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (RA 10173) and all other applicable data protection laws.

If you have any questions or concerns about how your personal data is handled, you may contact our designated Data Protection Officer (DPO) at [email protected].

2. Personal Data We Collect

greatph collects the following categories of personal data from Players:

2.1 Identity & Contact Information

• Full legal name as it appears on a government-issued ID
• Date of birth (to verify the 21+ age requirement)
• Nationality and country of residence
• Email address and mobile phone number
• Residential address (barangay, city, province, ZIP code)

2.2 Identity Verification (KYC) Documents

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, UMID, SSS ID, PhilHealth ID, Voter's ID)
• Proof of address documents (e.g., utility bill, bank statement dated within 90 days)
• Selfie or liveness check images where required for enhanced verification

2.3 Financial Information

• GCash mobile number or PayMaya account details
• BPI, BDO, or Metrobank account details (account name and number only — never full card numbers)
• Transaction history including deposits, withdrawals, and bonus credits in Philippine Peso (PHP)

2.4 Gaming Activity Data

• Game session logs, bet amounts, win/loss records, and game preferences
• Responsible gaming settings including deposit limits and self-exclusion status
• Bonus and promotion usage history

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and platform interaction logs
• Cookie identifiers and similar tracking technologies (see Section 7)

2.6 Communications Data

• Records of your communications with greatph customer support via live chat, email, or other channels
• Survey responses and feedback submitted voluntarily

3. How We Collect Your Data

greatph collects personal data through the following means:

• Direct collection: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the greatph platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and risk signals from payment processors such as GCash and PayMaya; publicly available information where permitted by law.

4. How We Use Your Personal Data

greatph uses your personal data for the following purposes:

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering (AML) regulations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given, and informed consent. You may withdraw consent at any time.

6. Data Sharing & Disclosure

6.1 greatph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data only in the following circumstances:

• Service providers: Trusted third-party vendors who assist in operating the greatph platform, including KYC verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.
• Regulatory and law enforcement authorities: Where required by Philippine law, court order, or regulatory directive, including disclosures to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or law enforcement agencies.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of greatph's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.
• With your consent: In any other circumstances where you have given explicit prior consent to the disclosure.

6.2 greatph requires all third-party service providers to implement appropriate technical and organisational security measures to protect your personal data and to process it only for the specified purposes.

7. Cookies & Tracking Technologies

7.1 greatph uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse platform usage.

7.2 We use the following categories of cookies:

• Strictly necessary cookies: Essential for the platform to function. These cannot be disabled as they are required for login sessions, security, and core functionality.
• Performance and analytics cookies: Help us understand how Players interact with the greatph platform so we can improve user experience. Data collected is aggregated and anonymised where possible.
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits.
• Marketing cookies: Used only with your consent to deliver relevant promotional content. You may opt out at any time via your Account settings.

7.3 You can control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the greatph platform.

8. Data Retention

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

• Account and KYC data: Retained for a minimum of five (5) years following Account closure, as required by Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation.
• Technical and device logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with our internal data disposal procedures.

9. Data Security

9.1 greatph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the greatph platform;
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records;
• Role-based access controls ensuring that only authorised personnel can access personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for internal systems that process personal data;
• Incident response procedures to detect, contain, and notify affected parties of any data breach in accordance with NPC requirements.

9.2 While greatph takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your Account credentials confidential and for notifying us immediately if you suspect any unauthorised access to your Account.

10. Your Data Rights

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

• Right to be informed: You have the right to know what personal data greatph collects about you and how it is used — which is the purpose of this Policy.
• Right of access: You may request a copy of the personal data greatph holds about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You may 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: You may object to the processing of your personal data for direct marketing purposes at any time, with immediate effect.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

10.2 To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

11. Children's Privacy

11.1 The greatph platform is strictly intended for adults aged 21 years and older, in accordance with Philippine law applicable to casino-style online gambling. greatph does not knowingly collect personal data from individuals under the age of 21.

11.2 If greatph discovers or is notified that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated Account, delete the data, and report the matter to the relevant authorities where required.

11.3 If you are a parent or guardian and believe that a minor has registered on the greatph platform, please contact us immediately at [email protected] so that we can take prompt action.

12. International Data Transfers

12.1 greatph primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines — for example, cloud hosting or KYC verification services — greatph ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses that meet the standards required by the Philippine Data Privacy Act.

12.2 greatph will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13. Updates to This Privacy Policy

13.1 greatph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered Players via email or a prominent notice on the greatph platform at least seven (7) days before the changes take effect.

13.2 The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. We encourage you to review this Policy periodically. Your continued use of the greatph platform after the effective date of any amendment constitutes your acceptance of the updated Policy.

14. Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way greatph handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Response Time: Within 30 days for data rights requests; within 5 business days for general privacy inquiries
• Support Hours: 24 hours a day, 7 days a week

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.