merryph22 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how merryph22 ("merryph22," "the Company," "we," "us," "our"), operator of the online gaming platform at merryph22.co, collects, uses, stores, discloses, and otherwise processes personal data in connection with your use of the merryph22 platform and associated services.

This Policy applies to all personal data submitted to or collected by merryph22 through the merryph22 website, mobile browser interface, customer support channels, and any other means by which you interact with the merryph22 platform. It applies to all registered merryph22 account holders as well as to visitors who have not yet registered.

merryph22 is committed to protecting the privacy and personal data of all Filipino players and website visitors in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and applicable issuances of the National Privacy Commission (NPC) of the Philippines. Our data practices are also shaped by PAGCOR licensing requirements, which impose specific data collection and retention obligations on online gaming operators.

By registering a merryph22 account or using the merryph22 platform, 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 consent, please do not use the merryph22 platform.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012, merryph22 acts as the personal information controller (PIC) with respect to the personal data of all merryph22 players and platform users. merryph22 determines the purposes and means of processing personal data collected through the platform.

merryph22 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. Contact details for the merryph22 DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Registration Data

When you register a merryph22 account, we collect: your full legal name, date of birth, Philippine mobile number, email address, and chosen account password (stored in hashed form — we never store plaintext passwords). This data is required to create and identify your account.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR KYC requirements and the Philippine Anti-Money Laundering Act (AMLA), merryph22 collects government-issued identity documents from all players prior to withdrawal activation. This includes a photo of your government-issued ID (passport, driver's license, PhilSys card, UMID, voter's ID, PRC ID, or similar), a selfie photograph for biometric comparison, and proof of Philippine residential address where required.

3.3 Financial Data

merryph22 collects information necessary to process deposits and withdrawals, including GCash account numbers, Maya wallet identifiers, bank account details (BPI, BDO, Metrobank), and cryptocurrency wallet addresses where applicable. We do not store full debit or credit card numbers on our servers.

3.4 Gaming Activity Data

merryph22 records all gaming activity on the platform, including game sessions played, bet amounts, game outcomes, bonus usage, and win/loss history. This data is required for PAGCOR regulatory reporting, dispute resolution, and responsible gaming monitoring.

3.5 Technical & Device Data

We automatically collect technical data when you access the merryph22 platform, including: IP address, device type and operating system, browser type and version, session timestamps, pages visited, and approximate geographic location derived from IP address.

3.6 Communications Data

We retain records of communications between you and merryph22 support, including Live Chat transcripts and email correspondence, for quality assurance, dispute resolution, and regulatory compliance purposes.

4. How We Use Your Personal Data

merryph22 uses the personal data we collect for the following purposes:

merryph22 does not use your personal data for automated decision-making that produces significant legal effects without human review, except for fraud detection flags which are always reviewed by a qualified member of the merryph22 compliance team before any account action is taken.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, merryph22 processes personal data on the following legal bases:

• Contractual necessity — processing required to perform the merryph22 player agreement, including operating your account, processing transactions, and providing games;
• Legal obligation — processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine law;
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and platform improvement, where these interests are not overridden by your rights and freedoms; and
• Consent — processing for optional activities such as marketing communications, where you have provided explicit, informed, and freely given consent that you may withdraw at any time.

6. Data Sharing & Third-Party Disclosure

merryph22 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following circumstances:

6.1 PAGCOR and Regulatory Authorities

merryph22 is required to share specified player data and gaming activity reports with PAGCOR as a condition of our operating license. We also comply with lawful requests from the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities with jurisdiction over our operations.

6.2 Payment Processors

To process GCash, Maya, BPI, BDO, Metrobank, and other payment method transactions, we share the minimum necessary data with the relevant payment processors. These processors are contractually bound to handle your data securely and only for the purposes of transaction processing.

6.3 Identity Verification Providers

merryph22 uses accredited third-party KYC verification services to assist with government ID authentication and biometric comparison. These providers process your KYC documents under a data processing agreement and are prohibited from using your data for any purpose other than verification on behalf of merryph22.

6.4 Technology and Infrastructure Providers

merryph22 uses cloud infrastructure, cybersecurity, and platform technology providers to operate the platform. These providers act as data processors under our instruction and under contractual data protection obligations consistent with the Philippine DPA.

6.5 Legal and Compliance Contexts

merryph22 may disclose personal data where required by a valid court order, subpoena, or other lawful process issued by a Philippine court or competent authority.

7. Cookies & Tracking Technologies

The merryph22 platform uses cookies and similar tracking technologies to operate and improve the platform experience. The types of cookies we use include:

• Strictly Necessary Cookies — required for account login session management, security token maintenance, and platform functionality. Cannot be disabled without breaking core platform functions.
• Functional Cookies — remember your language and display preferences for a more personalized experience.
• Analytical Cookies — collect anonymized data on how pages are used and which game categories are most accessed, helping merryph22 improve platform performance and content for Filipino players.
• Session Security Cookies — monitor login sessions for suspicious activity consistent with merryph22's fraud detection obligations.

merryph22 does not use third-party advertising cookies or behavioral targeting technologies that track your activity outside the merryph22 platform. You may manage cookie preferences through your browser settings, with the understanding that disabling strictly necessary cookies will affect platform functionality.

8. Data Retention

merryph22 retains personal data for the following minimum periods, or longer where required by applicable law or PAGCOR regulation:

• Account registration data — retained for the life of the account plus five (5) years following account closure, consistent with PAGCOR record-keeping requirements;
• KYC identity verification documents — retained for five (5) years following the completion of the transaction to which they relate, as required by the AMLA;
• Financial transaction records — retained for five (5) years from the date of the transaction, as required by the AMLA and PAGCOR;
• Gaming activity data — retained for five (5) years from the date of the relevant gaming session;
• Customer support communications — retained for two (2) years from the date of the communication; and
• Technical/device logs — retained for twelve (12) months from the date of collection.

Following the applicable retention period, personal data is securely deleted or anonymized in accordance with the merryph22 data retention schedule and the requirements of the Philippine Data Privacy Act.

9. Security Measures

merryph22 implements organizational and technical security measures appropriate to the sensitivity of the personal data we hold, including:

• 256-bit AES SSL/TLS encryption for all data in transit between your device and the merryph22 platform;
• Encryption of sensitive data at rest in merryph22 databases, including government ID images and financial account identifiers;
• Strict role-based access controls limiting employee access to personal data to the minimum necessary for each job function;
• Regular third-party penetration testing and security audits of the merryph22 platform infrastructure;
• Incident response procedures consistent with NPC Circular 16-03 (Personal Data Breach Management) for notification and mitigation in the event of a data breach; and
• Employee privacy and data security training for all merryph22 staff with access to personal data.

No security system is impenetrable. merryph22 will notify affected players and the National Privacy Commission within the legally required timeframes in the event of a personal data breach that is likely to result in harm to the affected individuals.

10. Your Data Rights Under Philippine Law

Under the Philippine Data Privacy Act of 2012, merryph22 players have the following rights with respect to their personal data:

• Right to be Informed — the right to be notified of how your personal data is collected and processed (fulfilled by this Policy);
• Right of Access — the right to request a copy of the personal data merryph22 holds about you;
• Right to Rectification — the right to request correction of inaccurate personal data;
• Right to Erasure or Blocking — the right to request deletion or blocking of personal data that is no longer necessary, was collected unlawfully, or where consent has been withdrawn, subject to merryph22's legal retention obligations;
• Right to Data Portability — the right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to Object — the right to object to processing based on legitimate interests, including direct marketing; and
• Right to Lodge a Complaint — the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe merryph22 has violated your data rights.

To exercise any of these rights, contact the merryph22 Data Protection Officer using the contact details in Section 14. merryph22 will respond to verified rights requests within fifteen (15) days, consistent with NPC guidelines.

11. Children's Privacy

The merryph22 platform is strictly intended for individuals aged 21 years and older. merryph22 does not knowingly collect or process personal data from individuals under 21 years of age. If merryph22 discovers that personal data has been collected from a person under 21 without verified parental or guardian consent, that data will be deleted promptly and the associated account permanently closed. If you are a parent or guardian who believes your child under 21 has registered a merryph22 account, please contact merryph22 support immediately so we can take corrective action.

12. International Data Transfers

merryph22 primarily stores and processes personal data within the Philippines or in cloud infrastructure with data centers in jurisdictions recognized by the National Privacy Commission as providing adequate data protection. Where personal data is transferred to a jurisdiction outside the Philippines — for example, to payment processing partners or technology service providers with international infrastructure — merryph22 ensures such transfers are protected by appropriate safeguards, including data processing agreements incorporating standard contractual clauses consistent with NPC requirements.

13. Changes to This Privacy Policy

merryph22 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or PAGCOR regulatory guidance. When material changes are made, merryph22 will provide advance notice to registered players via email to their registered address and/or a prominent in-platform notification. Continued use of the merryph22 platform following the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. The date of the most recent revision is always displayed at the top of this Policy.

14. Contact & Data Protection Officer

For privacy-related inquiries, data subject rights requests, or to contact the merryph22 Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data rights under Republic Act No. 10173 have been violated. The NPC's contact information is publicly available on their official government website. This Privacy Policy was last reviewed and updated on June 1, 2026.