vlpph Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how vlpph ("the Company", "we", "us", "our") collects, processes, stores, and discloses personal information obtained from users ("Player", "User", "you") who access or use the vlpph website, mobile platform, and associated gaming services available at vlpph.net.

vlpph is committed to safeguarding the privacy of all Filipino players and complying with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC), as well as the data governance requirements set by the Philippine Amusement and Gaming Corporation (PAGCOR).

This Policy applies to all personal information collected through the vlpph platform, regardless of the device or channel used to access it, including desktop browsers, mobile browsers, and any future vlpph mobile applications.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, vlpph acts as the personal information controller in respect of the personal data it collects from players using the vlpph platform. vlpph has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection matters within the organisation and ensuring ongoing compliance with applicable privacy laws.

Our designated Data Protection Officer can be contacted at the email address provided in Section 13 of this Policy. All data subject rights requests, privacy concerns, and data breach notifications should be directed to the DPO in the first instance.

Personal Data We Collect

3.1 Information You Provide Directly

When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotion, vlpph may collect the following categories of personal data:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification number (e.g., SSS, UMID, PhilHealth, passport number).
• Contact Data: Residential address (including barangay, city, province — whether you're in Manila, Cebu, Davao, Quezon City, or elsewhere), email address, and mobile number.
• Financial Data: GCash or Maya mobile wallet number, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records, and account balance information.
• Identity Verification Documents: Copies of government-issued photo IDs, proof of address documents (utility bills, bank statements), and selfie photographs submitted for KYC purposes.
• Communications Data: Records of correspondence with our customer support team, including live chat transcripts, email exchanges, and any feedback or complaints submitted.

3.2 Data Collected Automatically

When you access the vlpph platform, we automatically collect certain technical and behavioural data, including:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, bet amounts and outcomes, session duration, click-through behaviour, search queries within the platform, and navigation patterns.
• Location Data: General geographic location derived from your IP address, used to verify eligibility and comply with PAGCOR jurisdictional requirements.
• Cookie and Tracking Data: Information collected via cookies, web beacons, pixel tags, and similar tracking technologies as described in Section 7 of this Policy.

3.3 Data from Third Parties

vlpph may receive personal data about you from third-party sources, including identity verification and KYC service providers, fraud detection and anti-money laundering screening services, payment processors and e-wallet providers (such as GCash and Maya), and publicly available sources such as government registries or sanctions lists.

How We Use Your Personal Data

vlpph processes your personal data for the following purposes:

vlpph will not use your personal data for any purpose that is incompatible with the purposes described above without first obtaining your consent or establishing another lawful basis for processing.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, vlpph processes your personal data on the following legal bases:

• Contractual Necessity: Processing your identity, contact, and financial data is necessary to perform our contract with you — specifically to provide you with a vlpph account and deliver gaming services.
• Legal Obligation: vlpph is required by PAGCOR regulations, anti-money laundering laws (Republic Act No. 9160, as amended), and other applicable Philippine legislation to collect and retain certain data, including KYC documents and transaction records.
• Legitimate Interests: vlpph processes usage and technical data based on our legitimate interest in operating a secure, fraud-free platform and improving our services for Filipino players.
• Consent: Where we send you marketing communications or use non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw this consent at any time.

Data Sharing & Disclosure

6.1 Service Providers

vlpph shares your personal data with carefully selected third-party service providers who assist us in delivering our platform. These include KYC and identity verification providers, payment processors and e-wallet operators (GCash, Maya, BPI, BDO), game software providers, cloud hosting and IT infrastructure providers, and customer support platform operators. All service providers are bound by data processing agreements that require them to process your data only on our instructions and in accordance with applicable privacy law.

6.2 Regulatory Authorities

vlpph may disclose your personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other competent Philippine government authorities where required by law, court order, or regulatory directive. We will notify you of any such disclosure where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of vlpph's assets, your personal data may be transferred to the successor entity. We will provide advance notice of any such transfer and ensure that your data continues to be protected in accordance with this Policy.

6.4 No Sale of Data

Cookies & Tracking Technologies

vlpph uses cookies and similar tracking technologies on its platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and understand how you interact with our platform.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: These are essential for the vlpph platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Performance & Analytics Cookies: These cookies help us understand how players use the platform — which games are most popular, which pages are visited most frequently, and where technical issues occur. This data is used in aggregate and anonymous form to improve the vlpph experience.
• Functional Cookies: These remember your preferences, such as your preferred language, display settings, and game lobby filters, so you don't have to re-enter them each visit.
• Marketing Cookies: Used only with your consent, these cookies help us deliver relevant promotional content about vlpph bonuses and new game releases based on your interests and platform activity.

7.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most browsers allow you to block or delete cookies at any time. Please note that disabling certain cookies may affect the functionality of the vlpph platform. For detailed guidance on managing cookies in your specific browser, consult your browser's help documentation.

Data Retention

vlpph retains your personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with our legal obligations. The following retention periods apply:

• Account and KYC Data: Retained for the duration of your active account relationship with vlpph, and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and anti-money laundering legislation.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Customer Support Communications: Retained for two (2) years from the date of each interaction, or longer if the communication relates to an unresolved dispute.
• Usage and Technical Data: Retained for up to thirteen (13) months from collection for analytics purposes, after which it is aggregated or anonymised.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.

Upon expiry of the applicable retention period, vlpph will securely delete or anonymise your personal data in accordance with our internal data disposal procedures.

Your Data Rights

Under the Philippine Data Privacy Act of 2012, all vlpph players have the following rights in respect of their personal data:

• Right to be Informed: The right to be notified of how your data is collected and processed — which this Policy fulfils.
• Right of Access: The right to obtain a copy of the personal data vlpph holds about you, together with information about how it is used.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or updated. You can update basic profile information directly within your vlpph account dashboard.
• 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 on grounds relating to your particular situation where processing is based on legitimate interests.
• 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 controller where technically feasible.
• 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 infringed.

To exercise any of the above rights, please contact our Data Protection Officer as set out in Section 13. vlpph will acknowledge your request within three (3) business days and provide a substantive response within fifteen (15) business days, as required by the Data Privacy Act.

Data Security

vlpph implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the vlpph platform.
• AES-256 encryption for sensitive data stored at rest in our databases.
• Multi-factor authentication requirements for all vlpph administrative access.
• Regular third-party penetration testing and vulnerability assessments conducted by certified security professionals.
• Role-based access controls ensuring that vlpph employees can only access personal data necessary for their specific job functions.
• Continuous monitoring of our platform infrastructure for anomalous activity and potential security incidents.
• Regular staff training on data protection obligations and secure handling of personal information.

In the event of a personal data breach that poses a risk to your rights and freedoms, vlpph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay in accordance with the Data Privacy Act.

Children's Privacy

The vlpph platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. vlpph does not knowingly collect personal data from any person under the age of 21.

If vlpph becomes aware that personal data has been collected from an individual under the age of 21, the account will be immediately suspended, all associated data will be deleted, and any funds held in the account will be handled in accordance with applicable regulatory requirements. If you have reason to believe that a minor has registered an account with vlpph, please contact our support team immediately.

Amendments to This Policy

vlpph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable legislation, or PAGCOR regulatory requirements. When material changes are made, we will update the "Last Updated" date at the top of this page and, where the changes are significant, notify registered players via email or an in-platform notification.

Your continued use of the vlpph platform following the publication of an updated Privacy Policy constitutes your acknowledgment of and agreement to the revised terms. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.

Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or vlpph's handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please use "Data Privacy Request" or "DPO Enquiry" in your subject line so we can route your message correctly.
• Response Time: We acknowledge all privacy-related enquiries within three (3) business days and aim to resolve them within fifteen (15) business days.
• Live Chat: Available 24/7 on the vlpph platform for general support queries.

If you are unsatisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines at [email protected]. For matters relating to responsible gaming or account self-exclusion, please visit our Responsible Gaming page.