merryph23 Privacy Policy

merryph23 is the data controller responsible for the personal information collected through the merryph23 platform. As data controller, merryph23 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable data protection laws, including the Philippine Data Privacy Act of 2012.

merryph23 has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection strategy and implementation, and for serving as the point of contact for data subjects and the National Privacy Commission. Contact details for the DPO are provided in Section 13 of this Policy.

merryph23 collects personal data that is necessary for the operation of the platform, compliance with legal obligations, and the provision of a safe and fair gaming environment. The categories of personal data we collect include:

merryph23 does not collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for KYC and AML compliance purposes.

merryph23 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your merryph23 Account, including processing your registration, verifying your identity, and managing your account settings.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya/Maya, bank transfer, and debit card, and to maintain accurate financial records.
• KYC & AML Compliance: To verify your identity and age (21+), comply with anti-money laundering (AML) obligations, and meet PAGCOR regulatory requirements.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit limits and self-exclusion requests, and provide responsible gaming tools.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze aggregate usage data and improve the merryph23 platform, game library, and user experience.
• Legal Compliance: To comply with applicable laws, regulations, court orders, and regulatory directives, including those issued by PAGCOR and the NPC.
• Marketing Communications: To send you promotional offers and updates about merryph23, where you have provided consent. You may opt out of marketing communications at any time.

merryph23 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms and Conditions), including account management, payment processing, and game provision.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including KYC/AML requirements, PAGCOR regulations, and tax obligations.
• Legitimate Interests: Processing is necessary for merryph23's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, processing is based on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

merryph23 does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Processors: GCash (Mynt), PayMaya/Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, etc.) to process your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services used to process and validate your KYC documents.
• Game Providers: Licensed game providers whose games are available on the merryph23 platform may receive limited technical data necessary to deliver their games.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, and other competent Philippine authorities, where required by law or regulatory directive.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors, subject to strict confidentiality obligations.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under data processing agreements.

All third-party service providers engaged by merryph23 are contractually required to process personal data only in accordance with merryph23's instructions and applicable data protection laws.

merryph23 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account & Identity Data: Retained for the duration of your account and for a minimum of 5 years after account closure, in compliance with AML and PAGCOR record-keeping requirements.
• KYC Documents: Retained for a minimum of 5 years from the date of verification, or longer if required by law.
• Financial & Transaction Records: Retained for a minimum of 5 years from the date of each transaction, in compliance with Philippine tax and AML laws.
• Gaming History: Retained for a minimum of 3 years for responsible gaming monitoring and dispute resolution purposes.
• Support Communications: Retained for 2 years from the date of the last communication.
• Marketing Consent Records: Retained until you withdraw consent, plus 1 year for compliance documentation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with merryph23's data disposal procedures.

merryph23 uses cookies and similar tracking technologies to operate and improve the platform. The following types of cookies are used:

• Essential Cookies: Required for the platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without affecting platform functionality.
• Analytics Cookies: Used to collect aggregate, anonymized data about how players use the merryph23 platform, helping us identify areas for improvement. No personally identifiable information is collected via analytics cookies.
• Preference Cookies: Used to remember your platform settings and preferences, such as language and display options.

merryph23 does not use third-party advertising cookies or cross-site tracking technologies. You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling essential cookies may affect your ability to use certain features of the merryph23 platform.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by merryph23:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — which this Policy fulfils.
• Right of Access: The right to request a copy of the personal data merryph23 holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by merryph23.
• 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 merryph23's legal retention obligations.
• 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 data controller.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact the merryph23 Data Protection Officer at the details provided in Section 13. merryph23 will respond to all data rights requests within 15 business days, in accordance with NPC guidelines.

merryph23 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• AES-256 encryption for all personal data stored at rest.
• TLS 1.3 encryption for all data transmitted between your device and the merryph23 platform.
• Multi-factor authentication (MFA) for all internal staff access to systems containing personal data.
• Role-based access controls ensuring that only authorized personnel can access personal data on a need-to-know basis.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• 24/7 security monitoring and intrusion detection systems.
• Regular staff training on data protection and information security best practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, merryph23 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with the Data Privacy Act and NPC Circular No. 16-03.

The merryph23 platform is strictly intended for individuals who are 21 years of age or older, in compliance with Philippine law. merryph23 does not knowingly collect personal data from individuals under 21 years of age.

If merryph23 becomes aware that personal data has been collected from an individual under 21, the relevant account will be immediately suspended, all associated data will be deleted, and any funds will be returned to the source payment method after verification.

If you are a parent or guardian and believe that your child has registered on the merryph23 platform, please contact our support team immediately at [email protected]. We will investigate and take appropriate action within 24 hours.

merryph23 primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or game technology partners — merryph23 ensures that such transfers are subject to appropriate safeguards in accordance with the Data Privacy Act and NPC regulations.

These safeguards may include standard contractual clauses, data processing agreements, or transfers to jurisdictions that the NPC has recognized as providing an adequate level of data protection. merryph23 will not transfer your personal data to any jurisdiction that does not provide adequate protection without your explicit consent or a valid legal basis.

merryph23 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, merryph23 will notify registered players via email or a prominent notice on the platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the merryph23 platform after the effective date of any update constitutes your acceptance of the revised Policy. If you do not agree with the updated Policy, you must cease using the platform and may request account closure.

We encourage you to review this Policy periodically to stay informed about how merryph23 protects your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the merryph23 Data Protection Officer:

Data Protection Officer — merryph23
Email: [email protected]
General Support: [email protected]

For complaints regarding data privacy violations, you may also contact the National Privacy Commission (NPC) of the Philippines:

NPC Website: privacy.gov.ph
NPC Complaints: [email protected]

merryph23 will acknowledge all data-related inquiries within 3 business days and provide a full response within 15 business days.