greatph Privacy Policy

1. Introduction

greatph ("greatph," "we," "us," or "our") operates the online gaming platform accessible at https://greatph.vip and its associated mobile interfaces (the "Platform"). We are committed to protecting the privacy and personal data of all persons who interact with the Platform ("you" or "Player"). This Privacy Policy ("Policy") describes how greatph collects, uses, stores, discloses, and protects your personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, the National Privacy Commission ("NPC") issuances, and applicable PAGCOR regulatory requirements.

By registering an account, accessing the Platform, or otherwise using our services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

This Policy is to be read in conjunction with the greatph Terms and Conditions and our Responsible Gaming Policy, both of which are incorporated herein by reference.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, greatph is the personal information controller in respect of the personal data collected through the Platform. All inquiries, requests, and complaints relating to personal data processing may be directed to our Data Protection Officer ("DPO") at the contact details set out in Section 14 of this Policy.

3. Personal Data We Collect

greatph collects personal data through multiple channels: directly from you during registration and KYC, automatically through your use of the Platform, and from third parties such as payment providers and identity verification services. The categories of personal data we collect include:

Category	Examples	Collection Method
Identity Data	Full legal name, date of birth, gender, nationality, government ID number and image (PhilSys, passport, driver's license, UMID)	Registration / KYC submission
Contact Data	Philippine mobile number, email address, residential address	Registration form
Financial Data	GCash number, Maya account, bank account details, transaction history, deposit and withdrawal records	Payment processing
Technical Data	IP address, device identifier, browser type and version, operating system, session timestamps, geolocation (city/region level)	Automatic collection via Platform
Usage Data	Games played, bet amounts, session duration, promotion engagement, login history	Automatic collection via Platform
Communications Data	Customer support chat logs, email correspondence, in-app messages	Direct interactions with support team
Responsible Gaming Data	Self-exclusion requests, deposit limit settings, problem gambling screening responses	Account settings / support interactions

greatph does not collect sensitive personal information such as racial or ethnic origin, political opinions, or health data beyond what is strictly necessary for responsible gaming compliance purposes. We do not collect data from children under 21 years of age — see Section 11 for our children's privacy policy.

4. How We Use Your Personal Data

greatph processes your personal data for the following purposes:

• Account management: Creating and maintaining your greatph account, verifying your identity, and enabling you to access Platform features.
• KYC and AML compliance: Verifying your identity and age as required under PAGCOR regulations and Republic Act No. 9160 (Anti-Money Laundering Act), as amended by Republic Act No. 10167 and Republic Act No. 10365.
• Payment processing: Facilitating deposits and withdrawals via GCash, Maya, and other Accepted Payment Methods, and maintaining accurate transaction records.
• Game delivery and fraud prevention: Providing licensed gaming services, detecting and preventing cheating, collusion, bot activity, and financial fraud.
• Responsible gaming: Monitoring player behavior patterns to identify potential problem gambling indicators, enforcing self-exclusion and deposit limits, and fulfilling regulatory obligations under PAGCOR's responsible gaming framework.
• Customer support: Responding to inquiries, resolving disputes, and providing technical assistance.
• Marketing and promotions: Sending you promotional offers, bonus notifications, and Platform updates where you have consented to receive such communications. You may withdraw this consent at any time.
• Platform improvement: Analyzing aggregated usage data to improve game offerings, Platform performance, and user experience.
• Legal and regulatory compliance: Meeting our obligations under Philippine law, PAGCOR regulations, NPC requirements, and responding to lawful requests from government authorities.

5. Legal Bases for Processing

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

• Consent: Where you have given clear, specific consent to processing, such as for marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.
• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you have accepted, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine law, including AML/CTF legislation, PAGCOR regulations, and NPC directives.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring where such interests are not overridden by your rights and freedoms.

6. Disclosure and Sharing of Personal Data

greatph does not sell your personal data to third parties. We share personal data only in the following circumstances and with the following categories of recipients:

• Payment providers: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), GrabPay, and other Accepted Payment Method operators, solely for the purpose of processing deposits and withdrawals.
• Identity verification and KYC service providers: Third-party KYC technology providers that assist in verifying government-issued identification documents. These providers operate under data processing agreements that comply with the Data Privacy Act.
• Game software providers: JILI Games, Pragmatic Play, PG Soft, Evolution Gaming, and other licensed game studios may receive limited technical data required for game delivery and RNG certification. No personally identifiable data is shared beyond what is technically necessary.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission, and other Philippine government authorities as required by law or in response to lawful requests, court orders, or subpoenas.
• Professional advisers: Legal counsel, auditors, and accountants under strict confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of greatph's assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections.

All third-party data processors engaged by greatph are bound by data processing agreements requiring them to maintain data security standards no less protective than those applied by greatph, and prohibiting them from using your data for any purpose other than the specific service they provide to greatph.

7. Cookies and Tracking Technologies

greatph uses cookies, web beacons, pixel tags, and similar tracking technologies on the Platform to enhance your experience, maintain your login session, prevent fraud, and analyze Platform usage. The categories of cookies we use include:

• Strictly necessary cookies: Required for the Platform to function, including session management, security tokens, and load balancing. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and previously visited game categories.
• Analytics cookies: Collect aggregated, anonymized data about how Players use the Platform, which pages are most visited, and where users encounter errors. This data helps us improve the Platform.
• Marketing cookies: Used to deliver relevant promotional content within the Platform. We do not use third-party advertising networks that track you across other websites.

You may manage your cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality, including your ability to remain logged in.

8. Data Retention

greatph retains your personal data for as long as your account remains active and for such further periods as are required by applicable law and PAGCOR regulations. In general:

• Account and identity data is retained for a minimum of five (5) years following account closure, as required by the AMLC and PAGCOR record-keeping obligations.
• Financial transaction records are retained for a minimum of five (5) years following the date of the transaction.
• Customer support communications are retained for three (3) years following resolution of the relevant matter.
• Marketing preference data is retained until you withdraw consent or close your account, whichever is earlier.

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

9. Data Security

greatph employs a layered security architecture to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data fields at rest, including identity documents and payment information, using AES-256 encryption.
• Role-based access controls limiting internal access to personal data to employees with a documented business need.
• Multi-factor authentication required for all administrative access to systems containing personal data.
• Regular third-party penetration testing and security audits of the Platform infrastructure.
• An incident response plan that includes mandatory notification to the NPC and affected Players within 72 hours of discovering a personal data breach that is likely to result in harm.

10. Your Data Privacy Rights

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

• Right to be informed: The right to receive clear information about how your data is collected and processed — as provided in this Policy.
• Right of access: The right to request a copy of the personal data greatph 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 there is no overriding legal or regulatory basis for retention.
• Right to object: The right to object to the processing of your personal data on grounds of legitimate interests, including processing for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe greatph has processed your data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. greatph will respond to all privacy rights requests within fifteen (15) business days of receipt. We may request verification of your identity before processing your request.

11. Children's Privacy

The greatph Platform is strictly for individuals aged 21 years and above. We do not knowingly collect personal data from persons under 21 years of age. If we become aware that we have collected personal data from a person under 21, we will promptly close the associated account, delete the personal data, and report the matter to PAGCOR as required. If you believe a person under 21 has registered an account on the Platform, please contact us immediately at [email protected].

12. Cross-Border Data Transfers

Some of greatph's third-party service providers, including certain game software providers and cloud infrastructure partners, may process or store personal data outside the Philippines. Where such cross-border transfers occur, greatph ensures that adequate safeguards are in place, including contractual data transfer clauses that provide protections equivalent to those required under the Data Privacy Act of 2012. greatph will not transfer your personal data to a country that does not provide an adequate level of data protection without your explicit consent or unless required to do so by law.

13. Changes to This Privacy Policy

greatph may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform operations. Where changes are material, we will provide at least seven (7) days' advance notice to registered Players via their registered mobile number or email address, or by posting a prominent notice on the Platform. The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the changes.

14. Contact and Data Protection Officer

For all privacy-related inquiries, requests to exercise your data rights, or complaints, please contact the greatph Data Protection Officer:

• Email: [email protected]
• Subject Line: "Data Privacy Request – [Your Name]"
• Response Time: Acknowledgment within 2 business hours; substantive response within 15 business days

If you are not satisfied with greatph's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. Information about filing complaints with the NPC is available on the NPC's official website.