gpery Privacy Policy

01. About This Policy

This Privacy Policy ("Policy") describes how gpery ("we", "us", "our") collects, uses, stores, shares, and protects the personal information of individuals ("you", "your", "the Player") who access or use the gpery website located at gpery.net and any associated mobile interfaces or services (collectively, the "Platform").

gpery operates as a Philippines-focused online entertainment platform offering slots, live casino games, sports betting, and bingo to Filipino players nationwide. As a platform operating under PAGCOR regulatory oversight and subject to Philippine law, we are bound by the Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

By registering an account on gpery, accessing the Platform, or submitting any personal information to us, you acknowledge that you have read and understood this Policy and consent to the collection and use of your information as described herein. If you do not agree with any part of this Policy, you must discontinue your use of the Platform.

This Policy applies to all personal data we hold about you, regardless of the channel through which it was collected — including our website, Live Chat, Viber, Messenger, email correspondence, and payment processing interactions.

02. Data We Collect

gpery collects personal information only to the extent necessary for the legitimate operation of the Platform, compliance with Philippine law, and delivery of a safe, enjoyable gaming experience to Filipino players. The categories of data we collect are described below.

2.1 Information You Provide Directly

• Registration Data: Full legal name, date of birth, gender, residential address (province, city/municipality, barangay), email address, and Philippine mobile number.
• Identity Verification (KYC) Documents: Copies of government-issued IDs (Philippine passport, UMID, driver's license, PhilSys National ID, SSS/GSIS card), selfie photos, and proof of address documents submitted to satisfy PAGCOR and AMLA requirements.
• Payment Information: GCash account number, PayMaya account details, bank account numbers (BPI, BDO, Metrobank), or USDT wallet addresses used for deposit and withdrawal transactions. Full payment card numbers are never stored directly on our systems.
• Support Communications: Records of messages sent to our support team via Live Chat, Viber, Messenger, or email — including the content of your inquiries and our responses.
• Responsible Gaming Preferences: Self-exclusion requests, deposit limits, loss limits, session time limits, and cooling-off period settings that you configure within your account.

2.2 Information We Collect Automatically

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, features used, game sessions started and completed, session duration, click patterns, and navigation paths through the Platform.
• Transaction Logs: Records of every deposit, withdrawal, wager placed, game result, bonus claimed, and balance adjustment on your account, with timestamps.
• Geolocation Data: Approximate geographic location derived from your IP address, used to verify that you are accessing gpery from a permitted jurisdiction. We do not collect precise GPS-level location data.
• Cookie & Tracking Data: Data collected via cookies and similar tracking technologies as described in Section 6 of this Policy.

2.3 Information from Third Parties

• Payment Processors: Transaction confirmation data from GCash, PayMaya, and our partner banks to verify deposit and withdrawal status.
• Identity Verification Services: Results from third-party KYC and anti-fraud screening providers used to authenticate your identity and screen against sanctions lists.
• Game Providers: Session and outcome data from licensed game studios (such as Pragmatic Play, PG Soft, Habanero, and Evolution Gaming) whose games are hosted on the Platform.
• PAGCOR / AMLC: In limited circumstances, regulatory bodies may share information with us as part of compliance, investigation, or enforcement processes.

03. How We Use Your Data

gpery uses your personal information for the following purposes. We use only the minimum data necessary for each purpose and do not process your information in ways that are incompatible with the purposes listed here.

You may withdraw consent for promotional communications at any time by contacting our support team or using the unsubscribe mechanism in any marketing email. Withdrawal of marketing consent does not affect transactional communications which are necessary for the operation of your account.

04. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules, gpery processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contractual obligations to you as a registered player — including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Cybercrime Prevention Act, and NPC regulations.
• Legitimate Interests: Processing necessary for gpery's legitimate business interests — including fraud prevention, platform security, responsible gaming enforcement, and general business analytics — where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and non-essential cookies. You have the right to withdraw this consent at any time.
• Vital Interests: In exceptional circumstances, processing may be necessary to protect the vital interests of you or another person (for example, in a responsible gaming emergency).

05. Sharing Your Personal Data

gpery does not sell, rent, or trade your personal information to any third party for commercial purposes. We share your data only in the limited circumstances described below, and only to the extent necessary for each purpose.

5.1 Service Providers and Data Processors

We engage trusted third-party service providers who process data on our behalf under strict contractual data processing agreements. These include:

• Payment processors and e-wallet operators (GCash/GXI, PayMaya/Voyager Innovations, partner banks) for transaction processing
• KYC and identity verification service providers for age and identity checks
• Cloud hosting and data centre providers for Platform infrastructure
• Anti-fraud and cybersecurity vendors for Platform security monitoring
• Customer support platform providers (Live Chat, Viber, Messenger integrations)
• Game studio partners (Pragmatic Play, PG Soft, Habanero, Evolution Gaming) for game delivery and session management

All service providers are contractually bound to use your data only for the specific purpose of providing their services to gpery, to maintain appropriate security standards, and to comply with Philippine data protection law.

5.2 Regulatory and Law Enforcement Disclosures

gpery may be legally required to disclose your personal information to regulatory authorities, law enforcement agencies, or courts of competent jurisdiction in the Philippines. This includes mandatory reporting to the Anti-Money Laundering Council (AMLC) under the AMLA, and compliance reporting to PAGCOR. We will disclose only the minimum information required to satisfy any such legal obligation.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of gpery's business or assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you via email or a prominent notice on the Platform before your data is transferred and becomes subject to a different privacy policy.

06. Cookies & Tracking Technologies

gpery uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, analyse usage patterns, and deliver a personalised experience to Filipino players. Here is a breakdown of the cookie types we use:

When you first visit the gpery Platform, a cookie consent banner will be displayed. You may accept all cookies, accept only necessary cookies, or customise your cookie preferences. You can update your cookie preferences at any time through the cookie settings link in the footer. Please note that disabling functional or analytics cookies may affect the quality of your experience on the Platform.

gpery does not use cookies to serve third-party advertising or to track your activity on websites outside the gpery Platform.

07. Data Retention

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

• Account and identity data: Retained for the duration of your account and for a minimum of 5 years after account closure, in compliance with AMLA record-keeping requirements.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction, as required by AMLA and PAGCOR regulations.
• KYC documents: Retained for a minimum of 5 years after the end of the business relationship, or longer if required by law or ongoing regulatory investigation.
• Support communications: Retained for 2 years from the date of the interaction, or longer if the communication relates to an unresolved dispute or complaint.
• Marketing consent records: Retained until you withdraw consent plus 2 years, to demonstrate compliance with consent requirements.
• Analytics and usage data: Retained in aggregated, anonymised form indefinitely; identifiable usage data retained for 12 months.
• Self-exclusion records: Retained permanently to prevent re-registration by self-excluded players, in line with responsible gaming best practice.

When personal data is no longer required, it is securely deleted or permanently anonymised using industry-standard data destruction methods. Data held in backup systems is deleted in accordance with gpery's backup retention schedule.

08. Your Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal information held by gpery. These rights are available to all registered players who are Philippine residents.

• Right to Be Informed: The right to know what personal data gpery collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right to Access: The right to request a copy of the personal data gpery holds about you, including information on how it has been used and with whom it has been shared.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you. For registered accounts, you may update certain information directly through your account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to gpery's legal retention obligations under AMLA and PAGCOR regulations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to request that it be transmitted directly to another data controller where technically feasible.
• Right to Object: The right to object to processing based on legitimate interests or for direct marketing purposes. If you object to marketing, we will stop sending promotional communications immediately.
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe gpery has processed your data in violation of the Data Privacy Act.

To exercise any of the rights above, please contact gpery's Data Protection Officer at [email protected] with the subject line "Privacy Rights Request." We will acknowledge your request within 5 Philippine business days and respond fully within 30 calendar days. In complex cases, this period may be extended by a further 30 days with prior notice to you.

We may need to verify your identity before processing a rights request to ensure that we do not disclose or modify data in response to an unauthorised request.

09. Data Security

gpery implements a comprehensive set of technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration, loss, or destruction. Our security programme includes the following controls:

• Encryption: All data transmitted between your device and the gpery Platform is encrypted using TLS 1.2 or higher. Personal data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is strictly limited to authorised gpery personnel and service providers who have a legitimate operational need. Role-based access controls are enforced across all internal systems.
• Authentication: gpery supports multi-factor authentication (MFA) for player accounts. We strongly encourage all gpery players to enable MFA in their account security settings.
• Network Security: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and 24/7 security monitoring.
• Penetration Testing: gpery's systems undergo regular independent security testing and vulnerability assessments conducted by certified cybersecurity professionals.
• Staff Training: All gpery personnel who handle personal data receive data protection training and are bound by confidentiality agreements.
• Incident Response: gpery maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, we will notify you and the NPC within 72 hours of becoming aware of the breach, as required by the Data Privacy Act.

10. Children's Privacy

gpery is an online gaming and entertainment platform strictly intended for individuals aged 21 years and above, in accordance with PAGCOR's minimum age requirements for online gambling in the Philippines. gpery does not knowingly collect, store, or process the personal information of any person under the age of 21.

During registration, all applicants are required to confirm their date of birth and consent to an age verification check. Where gpery suspects or determines that an account holder is under 21, the account will be immediately suspended, access to the Platform will be blocked, and all funds deposited will be frozen pending an investigation and appropriate regulatory referral.

If you are a parent or guardian and you believe that a person under 21 in your care has registered an account or submitted personal information to gpery, please contact our support team immediately at [email protected]. We will take prompt action to verify the situation and delete any personal data associated with an underage account.

11. Third-Party Links & Integrations

The gpery Platform may contain references to or integrations with third-party services — including game studios, payment processors, and communication tools. Each of these third parties operates under its own privacy policy and data protection practices. gpery is not responsible for the privacy practices, content, or security of any third-party service.

When you use a third-party payment method such as GCash or PayMaya to transact with gpery, your payment data is handled directly by those providers in accordance with their own privacy policies and BSP (Bangko Sentral ng Pilipinas) regulatory requirements. gpery receives only the minimum information necessary to confirm your transaction — we do not store full payment credentials on our own servers.

We encourage you to review the privacy policies of any third-party service providers you interact with in connection with your use of gpery. gpery does not endorse the data practices of any external party and accepts no liability for any privacy breach or data loss occurring outside the gpery Platform.

12. Policy Updates

gpery reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data practices, Philippine law, NPC guidance, or PAGCOR regulations. When we make material changes to this Policy, we will take reasonable steps to inform you — which may include a notice displayed upon login, an email to your registered address, or a prominent banner on the Platform.

The effective date displayed at the top of this Policy indicates when the most recent version took effect. Your continued use of the gpery Platform following publication of an updated Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you must cease using the Platform and may request account closure in accordance with gpery's Terms & Conditions.

We recommend that you review this Privacy Policy periodically to stay informed about how gpery protects your personal information. The current version is always available at gpery.net/privacy-policy.

13. Contact & Data Protection Officer

gpery has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or formal complaints about how gpery handles your personal data, or if you wish to exercise any of your data subject rights as described in Section 8, you may contact our DPO through any of the following channels:

• Email (Primary Channel): [email protected] — please use the subject line "Privacy Rights Request" or "DPO Inquiry" for the fastest routing to our privacy team
• Live Chat: Available directly on the gpery website, 24 hours a day, 7 days a week — for general privacy questions and initial guidance
• Messenger & Viber: Available for Filipino players who prefer messaging app communication for less formal inquiries

For formal privacy complaints that cannot be resolved through gpery's internal process, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for enforcing the Data Privacy Act of 2012 and protecting the privacy rights of all Filipinos.

gpery is committed to resolving all privacy concerns raised by Filipino players fairly, promptly, and in compliance with Philippine law. We serve players across Manila, Cebu, Davao, Quezon City, Makati, Iloilo, Cagayan de Oro, and every region of the Philippines — and every player's privacy matters to us equally, wherever in the country they are based.