Privacy Policy – 24merryph

1.Introduction

24merryph ("we," "us," "our," or the "Company") is committed to protecting the privacy and personal data of all individuals who access or use the 24merryph online casino and sports betting platform (the "Platform"), accessible at https://24merryph.one. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). It applies to all personal data collected through the Platform, our mobile interface, customer support channels, and any other means by which you interact with 24merryph.

By registering an account on the 24merryph Platform, making a deposit, or otherwise using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use the Platform.

2.Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, 24merryph acts as the personal information controller with respect to the personal data of its registered players and Platform visitors. As the personal information controller, 24merryph determines the purposes and means of processing your personal data.

All data protection inquiries, requests to exercise your data subject rights, and privacy-related complaints should be directed to the 24merryph Data Protection Officer at the contact details provided in Section 15 of this Policy.

3.Personal Data We Collect

24merryph collects the following categories of personal data from users of the Platform:

4.How We Collect Your Data

24merryph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, log files, and similar tracking technologies when you access and use the Platform;
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from GCash, PayMaya, and banking partners; and publicly available information used for compliance screening.

5.How We Use Your Personal Data

24merryph uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and manage your 24merryph account, including processing your registration, verifying your identity, and managing your account settings;
• Service delivery: To provide you with access to the Platform's games, betting services, live casino, and all other features;
• Payment processing: To process deposits and withdrawals through your chosen payment method, including GCash, PayMaya, and Philippine bank transfers;
• Legal and regulatory compliance: To comply with our obligations under Philippine law, including the DPA, Anti-Money Laundering Act (AMLA), and applicable PAGCOR regulations, including age verification, KYC, and transaction monitoring;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform;
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Marketing and promotions: To send you information about 24merryph promotions, bonuses, and new features, where you have consented to receive such communications;
• Platform improvement: To analyze usage patterns, conduct research, and improve the performance, features, and user experience of the Platform;
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.

6.Legal Basis for Processing

24merryph processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing necessary for the performance of our contract with you, including account registration, payment processing, and service delivery;
• Legal obligation: Processing necessary to comply with our legal obligations under Philippine law, including KYC, AML, and PAGCOR regulatory requirements;
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7.Data Sharing and Disclosure

24merryph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your financial transactions;
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with our compliance obligations;
• Fraud prevention and security providers: Anti-fraud and cybersecurity service providers engaged to protect the Platform and its users;
• Game software providers: Third-party game developers and live casino operators whose games are available on the Platform, to the extent necessary for game operation and dispute resolution;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where required by law or regulatory obligation;
• Professional advisors: Legal counsel, auditors, and other professional advisors engaged by 24merryph in the ordinary course of business, subject to confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of 24merryph's assets, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

8.Cookies and Tracking Technologies

24merryph uses cookies and similar tracking technologies to enhance your experience on the Platform, to analyze usage patterns, and to support our security and fraud prevention measures. A cookie is a small text file placed on your device when you visit the Platform.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management, login authentication, and security functions. These cookies cannot be disabled;
• Performance and analytics cookies: Used to collect information about how visitors use the Platform, including pages visited, time spent, and error messages, to help us improve Platform performance;
• Functionality cookies: Used to remember your preferences and settings, such as language preferences and display options, to provide a more personalized experience;
• Targeting and marketing cookies: Used to deliver relevant promotional content and to measure the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You may control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no opt-out is available as they are essential to the operation of the service.

9.Data Retention

24merryph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements;
• Transaction data: Retained for a minimum of five (5) years from the date of the transaction, in compliance with Anti-Money Laundering Act requirements;
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction;
• Customer support communications: Retained for a period of two (2) years from the date of the communication, unless a longer period is required for dispute resolution or legal proceedings;
• Technical and usage data: Retained for a period of up to two (2) years, after which it is anonymized or deleted.

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

10.Data Security

24merryph implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including financial account details and government ID numbers;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication for administrative access to systems containing personal data;
• Regular security audits, vulnerability assessments, and penetration testing of the Platform;
• Secure data centers with physical access controls, CCTV monitoring, and environmental safeguards;
• Staff training on data privacy and security obligations under the DPA.

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorized access to your account.

11.Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 24merryph:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy;
• Right of access: The right to obtain confirmation of whether 24merryph holds personal data about you, and to receive a copy of that data;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held about you;
• 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 our legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

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

12.Children's Privacy

The 24merryph Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has provided personal data to 24merryph, please contact us immediately at [email protected] so that we can take appropriate action.

13.International Data Transfers

24merryph primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, game software providers or cloud infrastructure partners operating in other jurisdictions.

Where personal data is transferred outside the Philippines, 24merryph ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses consistent with NPC requirements, and that the recipient country provides an adequate level of data protection. Such transfers are carried out only to the extent necessary for the purposes described in this Privacy Policy.

14.Updates to This Privacy Policy

24merryph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. The date of the most recent revision is indicated at the top of this page. When material changes are made, we will notify registered users via the email address or mobile number associated with their account, or by posting a prominent notice on the Platform.

Your continued use of the 24merryph Platform following the posting of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

15.Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the 24merryph Data Protection Officer:

Email: [email protected]

Live Chat: Available through the 24merryph Platform after login, 24/7.

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. Information on how to file a complaint is available on the NPC's official website.

Please include your registered account username and a clear description of your query when contacting us to help us assist you efficiently.