enjoyph Privacy Policy

1. Introduction

enjoyph ("enjoyph", "we", "us", "our") is committed to protecting the privacy and personal data of all users of the enjoyph online gaming platform ("Platform"). This Privacy Policy ("Policy") describes how we collect, use, store, disclose, and protect personal information in connection with your use of the enjoyph Platform, including our website at enjoyph.app and any related mobile applications or services.

This Policy is written in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. By registering an account or using the enjoyph Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with the enjoyph Terms & Conditions, which govern your use of the Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Personal Data We Collect

enjoyph collects the following categories of personal data from users of the Platform:

2.1 Identity Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify that you are at least 21 years of age);
• Gender (optional, collected during registration);
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS number) — collected during KYC verification.

2.2 Contact Data

• Philippine mobile number (used for account verification, OTP delivery, and communications);
• Email address;
• Residential address (collected during KYC verification).

2.3 Financial Data

• GCash or PayMaya (Maya) account details linked to your enjoyph account;
• Philippine bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) used for deposits and withdrawals;
• Transaction history, including deposit amounts, withdrawal amounts, and dates.

2.4 Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session data, including login timestamps and session duration;
• Cookies and similar tracking technologies (see Section 10).

2.5 Gaming Data

• Game history, including games played, bets placed, and outcomes;
• Bonus and promotion usage history;
• Responsible gaming settings, including deposit limits and self-exclusion status.

2.6 Communications Data

• Records of communications between you and the enjoyph customer support team, including live chat transcripts and email correspondence;
• Feedback and survey responses submitted voluntarily.

3. How We Collect Your Data

enjoyph collects 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 through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; payment data from GCash, PayMaya, and banking partners; fraud prevention data from third-party risk management services.

enjoyph does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, health information, or political or religious affiliations.

4. How We Use Your Personal Data

enjoyph uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your enjoyph account, including verifying your identity and age;
• Service delivery: To provide access to the games, features, and services available on the enjoyph Platform;
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers;
• Regulatory compliance: To comply with PAGCOR licensing requirements, the Data Privacy Act of 2012, and Philippine anti-money laundering (AML) obligations under Republic Act No. 9160 (Anti-Money Laundering Act);
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the Platform;
• Responsible gaming: To monitor gaming activity and enforce responsible gaming tools, including deposit limits and self-exclusion;
• Customer support: To respond to your enquiries, complaints, and support requests;
• Marketing communications: To send you promotional offers, bonuses, and platform updates — only where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time;
• Platform improvement: To analyse usage patterns and improve the enjoyph Platform, including game performance and user experience.

enjoyph will not use your personal data for any purpose incompatible with the purposes listed above without first obtaining your consent or as otherwise required by law.

5. Legal Basis for Processing

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

• Contractual necessity: Processing necessary to perform the contract between you and enjoyph (i.e., the Terms & Conditions), including account management, payment processing, and service delivery;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements and AML obligations;
• Legitimate interests: Processing necessary for enjoyph's legitimate interests, including fraud prevention, platform security, and responsible gaming enforcement, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. Sharing Your Personal Data

enjoyph does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: GCash, PayMaya, and Philippine banking partners, for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements;
• Fraud prevention and risk management providers: Third-party services used to detect and prevent fraudulent activity on the Platform;
• Game content providers: Third-party game studios whose games are available on the enjoyph Platform, to the extent necessary for game operation and dispute resolution;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where required by law or regulatory obligation;
• Legal and professional advisers: Lawyers, accountants, and other professional advisers engaged by enjoyph, subject to professional confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of all or part of enjoyph's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third parties with whom enjoyph shares personal data are required to process such data in accordance with applicable Philippine data protection law and enjoyph's data processing requirements.

7. Data Retention

enjoyph 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.

Specifically:

• Account data and KYC records are retained for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations;
• 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 the resolution of the relevant matter;
• Marketing consent records are retained for as long as you remain a registered user of the Platform, and for three (3) years following account closure.

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

8. Data Security

enjoyph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption of data in transit using industry-standard TLS/SSL protocols;
• Encryption of sensitive data at rest, including financial data and government identification numbers;
• Access controls limiting access to personal data to authorised personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Employee training on data protection and information security practices.

While enjoyph takes data security seriously and implements robust safeguards, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, enjoyph will notify you and the National Privacy Commission (NPC) in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by enjoyph:

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which is the purpose of this Privacy Policy;
• Right of access: The right to request a copy of the personal data enjoyph 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, subject to enjoyph's 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;
• 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 lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact the enjoyph Data Protection Officer via the contact details in Section 13. enjoyph will respond to all data subject requests within thirty (30) days of receipt, in accordance with the requirements of the Data Privacy Act of 2012.

10. Cookies and Tracking Technologies

The enjoyph Platform uses cookies and similar tracking technologies to enhance your experience, analyse Platform usage, and support security functions. The following types of cookies are used on the enjoyph Platform:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management, login authentication, and security functions. These cookies cannot be disabled;
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming limits;
• Analytics cookies: Used to collect anonymised data about how users interact with the Platform, helping enjoyph improve performance and user experience;
• Marketing cookies: Used to deliver relevant promotional content based on your interests and Platform activity. These cookies are only set with your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the enjoyph Platform. For strictly necessary cookies, no opt-out is available as they are essential to Platform operation.

11. Minors and Age Restriction

The enjoyph Platform is strictly intended for adults aged 21 years and above, in compliance with PAGCOR regulations and Philippine law. enjoyph does not knowingly collect personal data from persons under 21 years of age.

If enjoyph becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such data and close the associated account. Any funds held in such an account will be handled in accordance with applicable regulations.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gaming platforms, including the enjoyph Platform.

12. Changes to This Privacy Policy

enjoyph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, enjoyph will notify registered users via the mobile number or email address associated with their account, or by posting a prominent notice on the Platform, at least seven (7) days before the changes take effect.

The date of the most recent revision is indicated at the top of this Policy. Your continued use of the enjoyph Platform following the effective date of any revision constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by enjoyph, please contact our Data Protection Officer:

For responsible gaming concerns, including self-exclusion requests, please visit our Responsible Gaming page or contact support directly via live chat.