earphp Privacy Policy

This Privacy Policy ("Policy") describes how earphp ("earphp," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("Player," "User," or "you") who access or use the earphp online gaming platform, including the website earphp.com and any associated mobile or web applications (collectively, the "Platform").

earphp is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance 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).

1.1 This Policy applies to all personal data collected by earphp in connection with the operation of the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and marketing communications.

1.2 This Policy applies to all registered players, prospective players who browse the Platform without registering, and any individual whose personal data earphp processes in connection with the provision of its services.

1.3 This Policy should be read alongside earphp's Terms and Conditions, which govern the overall relationship between earphp and its players. In the event of any conflict between this Policy and the Terms and Conditions on matters of data privacy, this Policy shall prevail.

2.1 earphp acts as the Data Controller in respect of the personal data it collects and processes. As Data Controller, earphp determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy laws.

2.2 earphp has appointed a Data Protection Officer (DPO) in accordance with the requirements of the National Privacy Commission. The DPO is responsible for overseeing earphp's data protection strategy and ensuring compliance with the Data Privacy Act of 2012.

2.3 For all data privacy-related inquiries, requests, or complaints, you may contact earphp's Data Protection Officer via the customer support live chat available in the earphp app, or by email at: [email protected]

3.1 earphp collects the following categories of personal data in connection with the provision of its services:

3.2 earphp does not intentionally collect sensitive personal information as defined under the Data Privacy Act of 2012 (such as health data, religious beliefs, or political affiliations) unless specifically required for regulatory compliance purposes, in which case your explicit consent will be obtained.

4.1 earphp collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including IP address, device identifiers, browser type, and session data via cookies and similar tracking technologies.
• Third-party sources: Identity verification data from government databases or accredited KYC service providers; fraud prevention data from third-party risk management services; payment data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors.
• Publicly available sources: Information from public records or social media profiles where relevant to fraud prevention or regulatory compliance.

5.1 earphp uses your personal data for the following purposes:

1. To create and manage your earphp account, including verifying your identity and age (21+ requirement).
2. To process deposits, withdrawals, and other financial transactions on the Platform.
3. To comply with anti-money laundering (AML), counter-terrorism financing (CTF), and PAGCOR regulatory requirements.
4. To detect, investigate, and prevent fraud, cheating, and other prohibited conduct on the Platform.
5. To provide customer support and resolve disputes.
6. To personalise your gaming experience and deliver relevant promotions (where you have opted in).
7. To monitor and enforce responsible gaming obligations, including identifying players who may be at risk.
8. To improve the Platform through analytics, user research, and performance monitoring.
9. To send transactional communications such as deposit confirmations, withdrawal notifications, and security alerts.
10. To comply with applicable Philippine laws and respond to lawful requests from government authorities.

6.1 earphp processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfil our obligations under the earphp Terms and Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AML/CTF regulations, tax obligations, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and business analytics, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw this consent at any time.

7.1 earphp does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven, and Cebuana Lhuillier, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Accredited third-party services used to verify your identity and age in compliance with PAGCOR requirements.
• Fraud prevention and AML services: Third-party risk management platforms used to detect and prevent fraudulent activity and money laundering.
• Game software providers: Licensed game developers whose games are hosted on the earphp Platform, who may receive anonymised gameplay data for technical and licensing purposes.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or regulatory directive.
• Professional advisers: Lawyers, auditors, and accountants engaged by earphp, subject to professional confidentiality obligations.

7.2 All third parties with whom earphp shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and earphp's data processing standards.

8.1 earphp retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

8.2 The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AML/CTF requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Gaming history: Retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes.
• Marketing data: Retained until you withdraw consent or for a maximum of two (2) years from your last interaction with earphp marketing communications, whichever is earlier.
• Technical and log data: Retained for up to twelve (12) months for security and fraud prevention purposes.

8.3 Upon expiry of the applicable retention period, earphp will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by earphp:

9.2 To exercise any of the above rights, please contact earphp's Data Protection Officer via the live chat support in the earphp app or by email at: [email protected]. earphp will respond to all verified data subject requests within thirty (30) days of receipt.

9.3 Please note that certain rights may be limited where earphp is required to retain or process your data to comply with legal obligations, including PAGCOR licensing requirements and AML/CTF regulations.

10.1 earphp uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, analyse usage patterns, and deliver relevant content.

10.2 The following types of cookies are used on the earphp Platform:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Performance cookies: Used to collect anonymised data about how players use the Platform, helping earphp identify and fix technical issues and improve performance.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Marketing cookies: Used to deliver relevant promotional content based on your interests and gaming activity. These are only set with your explicit consent.

10.3 You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

11.1 earphp implements appropriate technical and organisational 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 transmitted between your device and the earphp Platform.
• Encrypted storage of all sensitive personal and financial data at rest.
• Multi-factor authentication (MFA) for account access.
• Regular security audits and penetration testing by independent cybersecurity firms.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Comprehensive data breach response procedures in compliance with NPC notification requirements.

11.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, earphp 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 NPC Circular No. 16-03.

12.1 The earphp Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with PAGCOR regulations and Philippine law. earphp does not knowingly collect personal data from individuals under the age of 21.

12.2 If earphp becomes aware that it has inadvertently collected personal data from an individual under 21 years of age, it will immediately suspend the associated account, delete the personal data in question, and return any deposited funds to the payment method on file.

12.3 If you believe that earphp may have collected personal data from a minor, please contact our Data Protection Officer immediately at: [email protected]

13.1 earphp reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. The date of the most recent revision is indicated at the top of this page.

13.2 Where changes are material, earphp will notify registered players via the email address or mobile number on file at least seven (7) days before the changes take effect. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Policy.

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

14.1 For any questions, concerns, or requests relating to this Privacy Policy or earphp's data processing practices, please contact our Data Protection Officer:

14.2 If you are not satisfied with earphp's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012.

14.3 earphp takes all data privacy complaints seriously and is committed to resolving them promptly and fairly. We encourage players to contact us directly in the first instance so that we have the opportunity to address your concern before it is escalated to the NPC.