MerryPH Privacy Policy

1. Introduction

MerryPH is committed to protecting the privacy and personal data of all users of the MerryPH platform. We understand that Filipino players trust us with sensitive personal and financial information, and we take that responsibility seriously. This Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

This Policy applies to all personal data collected by MerryPH through the merryph.pro website, the MerryPH mobile application, customer support interactions, and any other channel through which you interact with MerryPH. It covers data collected from registered players, prospective players, and visitors to the MerryPH platform.

Please read this Policy carefully. If you have any questions about how MerryPH handles your personal data, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, MerryPH is the Personal Information Controller (PIC) in respect of the personal data collected through the MerryPH platform. As the PIC, MerryPH determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable data protection laws.

MerryPH has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 14.

3. Data We Collect

MerryPH collects the following categories of personal data:

3.1 Identity & Contact Data

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

3.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine ID (PhilSys National ID, passport, driver's license, SSS ID, GSIS ID, PRC ID, or Voter's ID)
• Selfie or live photo for facial verification purposes
• Proof of address documents where required

3.3 Financial Data

• GCash or PayMaya mobile wallet number
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where used for deposits or withdrawals
• Transaction history including deposits, withdrawals, and bonus credits

3.4 Gaming Activity Data

• Game session history, bet amounts, and game outcomes
• Bonus and promotion usage records
• Responsible gaming settings and self-exclusion records

3.5 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, time spent on platform, and clickstream data
• Login timestamps and session duration

4. How We Collect Your Data

MerryPH collects your personal data through the following means:

• Registration: Information you provide when creating a MerryPH account, including your name, date of birth, email address, and mobile number.
• KYC Verification: Identity documents and verification photos submitted during the Know Your Customer process.
• Deposits & Withdrawals: Payment details provided when making transactions through GCash, PayMaya, or Philippine bank transfers.
• Platform Use: Data automatically collected as you navigate and use the MerryPH website and mobile application, including technical and usage data.
• Customer Support: Information you provide when contacting MerryPH's support team via email, live chat, or other support channels.
• Cookies & Tracking Technologies: Data collected through cookies and similar technologies as described in Section 8 of this Policy.
• Third-Party Verification Services: Data received from identity verification and fraud prevention service providers engaged by MerryPH to assist with KYC compliance.

5. How We Use Your Data

MerryPH uses your personal data for the following purposes:

MerryPH does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have provided explicit consent.

6. Legal Basis for Processing

MerryPH processes your personal data on the following legal bases under the Philippine 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 promotional communications.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and MerryPH — including account management, game access, and payment processing.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to MerryPH, including anti-money laundering (AML) reporting obligations under the AMLA, age verification requirements, and PAGCOR regulatory requirements.
• Legitimate Interests: Where processing is necessary for the legitimate interests of MerryPH, such as fraud prevention, platform security, and improving the quality of our services, provided that such interests are not overridden by your rights and freedoms.

7. Data Sharing & Disclosure

MerryPH does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Identity Verification Providers: Third-party KYC and identity verification service providers engaged to assist MerryPH in verifying player identities and complying with AML obligations.
• Payment Processors: GCash, PayMaya, and Philippine banking partners involved in processing your deposits and withdrawals. These providers process your financial data under their own privacy policies and applicable regulations.
• Regulatory Authorities: The Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law or regulatory directive.
• Fraud Prevention Services: Third-party fraud detection and cybersecurity service providers engaged to protect the integrity of the MerryPH platform.
• IT and Hosting Providers: Cloud hosting and infrastructure providers who process data on behalf of MerryPH under strict data processing agreements that require them to maintain appropriate security measures.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by MerryPH, subject to professional confidentiality obligations.

All third parties with whom MerryPH shares personal data are required to process such data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable Philippine data protection laws.

8. Cookies & Tracking Technologies

MerryPH uses cookies and similar tracking technologies on the merryph.pro website and mobile application to enhance your experience, maintain session security, and collect analytics data. The following types of cookies are used:

• Essential Cookies: Strictly necessary for the operation of the MerryPH platform, including maintaining your login session and ensuring platform security. These cookies cannot be disabled without affecting platform functionality.
• Analytics Cookies: Used to collect anonymized data about how players use the MerryPH platform, including pages visited and features used. This data helps MerryPH improve the platform experience.
• Preference Cookies: Used to remember your platform preferences, such as language settings and display options, to provide a more personalized experience.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats to the MerryPH platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the MerryPH platform. Essential and security cookies cannot be disabled as they are required for the platform to operate securely.

9. Data Retention

MerryPH retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes. The following retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of 5 years following account closure, in accordance with Philippine AML record-keeping requirements.
• KYC Documents: Retained for a minimum of 5 years from the date of the last transaction, as required by the Anti-Money Laundering Act (AMLA) and PAGCOR regulations.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction.
• Gaming Activity Logs: Retained for a minimum of 3 years from the date of each gaming session.
• Customer Support Records: Retained for 3 years from the date of the last support interaction.
• Technical and Usage Data: Retained for up to 12 months, after which it is anonymized or deleted.

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

10. Data Security

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

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and MerryPH servers is encrypted using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Sensitive personal and financial data stored on MerryPH servers is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized MerryPH personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: MerryPH supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security.
• Regular Security Audits: MerryPH conducts regular security assessments and penetration testing to identify and remediate potential vulnerabilities.
• Incident Response: MerryPH maintains a documented data breach response plan and will notify affected players and the NPC in the event of a breach, as required by law.

11. Your Data Subject Rights

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

To exercise any of your data subject rights, please submit a written request to MerryPH's Data Protection Officer using the contact details in Section 14. MerryPH will respond to your request within 15 business days of receipt. In complex cases, this period may be extended by a further 15 business days, and you will be notified of the extension.

If you are not satisfied with MerryPH's response to your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12. Children's Privacy

MerryPH is strictly intended for persons who are 21 years of age or older. MerryPH does not knowingly collect personal data from persons under the age of 21. The registration process includes age verification steps designed to prevent underage individuals from creating accounts.

If MerryPH becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately closed, all funds will be handled in accordance with applicable regulations, and the personal data will be securely deleted as soon as practicable.

13. Updates to This Privacy Policy

MerryPH reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. When material changes are made to this Policy, MerryPH will notify registered players via email or an in-platform notification at least 7 days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how MerryPH protects your personal data. Your continued use of the MerryPH platform following the effective date of any update constitutes your acceptance of the revised Policy.

14. Contact & Data Protection Officer

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

For concerns about your responsible gaming settings or self-exclusion, please visit our Responsible Gaming page. For the full terms governing your use of MerryPH, please review our Terms & Conditions.