vipmyapp Privacy Policy

1 Introduction

1.1 vipmyapp ("vipmyapp," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and users of the vipmyapp platform. This Privacy Policy ("Policy") describes how vipmyapp collects, uses, stores, shares, and protects personal information in connection with your use of the vipmyapp website and services.

1.2 This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission ("NPC").

1.3 By registering a vipmyapp account or using any vipmyapp service, 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 agree to this Policy, you must not use the vipmyapp platform.

1.4 This Policy should be read together with vipmyapp's Terms & Conditions and Responsible Gaming Policy.

2 Data We Collect

2.1 vipmyapp collects the following categories of personal data from players and users of the platform:

2.2 vipmyapp does not collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance purposes. Where sensitive personal information is collected, vipmyapp applies heightened security and access controls.

3 How We Collect Data

3.1 vipmyapp collects personal data through the following means:

• Direct interactions: Data you provide when registering a vipmyapp account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Data collected automatically when you access the vipmyapp platform, including cookies, web beacons, log files, and similar tracking technologies (see Section 7);
• Third-party sources: Data received from payment processors (e.g., GCash, PayMaya, Philippine banks), identity verification service providers, fraud prevention services, and regulatory authorities where permitted by law;
• Publicly available sources: Data from public records or databases where relevant to KYC or AML compliance obligations.

4 How We Use Your Data

4.1 vipmyapp uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your vipmyapp account, including verifying your identity and age (21+ requirement);
• Service delivery: To provide access to vipmyapp games, process deposits and withdrawals, and deliver customer support;
• Legal and regulatory compliance: To comply with obligations under the DPA, PAGCOR regulations, Anti-Money Laundering Act (AMLA), and other applicable Philippine laws;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and unauthorized access to the vipmyapp platform;
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion;
• Communications: To send you account-related notifications, transaction confirmations, and — where you have opted in — promotional communications about vipmyapp offers;
• Platform improvement: To analyze usage patterns and improve the vipmyapp platform's performance, features, and user experience;
• Dispute resolution: To investigate and resolve complaints, disputes, or legal claims involving your vipmyapp account.

4.2 vipmyapp will not use your personal data for purposes incompatible with those listed above without first obtaining your consent or establishing another lawful basis for processing.

5 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform the contract between you and vipmyapp (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, AMLA obligations, and NPC directives;
• Legitimate interests: Processing necessary for vipmyapp's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications. You may withdraw consent at any time by contacting vipmyapp support.

6 Data Sharing & Disclosure

6.1 vipmyapp may share your personal data with the following categories of recipients:

• Payment processors: GCash, PayMaya/Maya, and Philippine banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals;
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements;
• Game providers: Software providers whose games are available on the vipmyapp platform, to the extent necessary to deliver the gaming service;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or regulatory obligation;
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where vipmyapp reasonably believes disclosure is necessary to prevent fraud or illegal activity;
• Professional advisers: Lawyers, auditors, and accountants engaged by vipmyapp, subject to professional confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of vipmyapp's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

6.2 All third parties with whom vipmyapp shares personal data are required to process such data in accordance with the DPA and vipmyapp's data protection standards.

7 Cookies & Tracking Technologies

7.1 vipmyapp uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the vipmyapp website.

7.2 vipmyapp uses the following types of cookies:

• Strictly necessary cookies: Essential for the vipmyapp platform to function, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings) to improve your vipmyapp experience.
• Analytics cookies: Collect anonymized data about how players use the vipmyapp platform to help us improve performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity and unauthorized access to vipmyapp accounts.

7.3 You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the vipmyapp platform.

8 Data Retention

8.1 vipmyapp retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation.

8.2 The following general retention periods apply:

• Account data: Retained for the duration of your vipmyapp account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act;
• KYC and identity documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction;
• Communications and support records: Retained for a minimum of three (3) years from the date of the communication;
• Technical and usage data: Retained for up to two (2) years from collection, unless a longer period is required for security or legal purposes.

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

9 Data Security

9.1 vipmyapp implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption of data in transit using industry-standard Transport Layer Security (TLS) protocols;
• Encryption of sensitive data at rest using AES-256 or equivalent encryption standards;
• Role-based access controls limiting access to personal data to authorized vipmyapp personnel on a need-to-know basis;
• Regular security assessments, vulnerability scanning, and penetration testing of the vipmyapp platform;
• Multi-factor authentication requirements for vipmyapp administrative systems;
• Staff training on data protection obligations and information security best practices.

9.2 While vipmyapp takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. vipmyapp cannot guarantee absolute security of data transmitted over the internet.

9.3 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, vipmyapp will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

9.4 You are responsible for maintaining the security of your vipmyapp login credentials. If you suspect that your account has been compromised, please contact vipmyapp support immediately.

10 Your Rights

10.1 As a data subject under Philippine law, you have the following rights:

• Right to be informed: The right to be informed of how your personal data is being collected and processed by vipmyapp, as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data vipmyapp holds about you, along with information about how it is being processed;
• Right to rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data vipmyapp holds about you;
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, or where processing is unlawful, subject to vipmyapp's legal retention obligations;
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, including processing for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible;
• Right to damages: The right to claim compensation for any damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data;
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe vipmyapp has violated your data privacy rights.

10.2 vipmyapp will respond to data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice to you.

10.3 vipmyapp may decline requests where fulfilling them would conflict with its legal obligations, including PAGCOR licensing requirements or AMLA record-keeping obligations.

11 Children's Privacy

11.1 If vipmyapp becomes aware that it has inadvertently collected personal data from an individual under the age of 21, it will take immediate steps to delete such data and close the associated account in accordance with its Terms & Conditions.

11.2 Parents and guardians who believe that their child under the age of 21 has provided personal data to vipmyapp are encouraged to contact vipmyapp support immediately so that appropriate action can be taken.

12 Changes to This Policy

12.1 vipmyapp reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or vipmyapp's data processing practices.

12.2 Where changes are material, vipmyapp will notify registered players by email or by posting a prominent notice on the vipmyapp platform prior to the changes taking effect. The date of the most recent revision is indicated at the top of this page.

12.3 Your continued use of the vipmyapp platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised Policy, you must cease using the vipmyapp platform and may close your account in accordance with the Terms & Conditions.

13 Contact Us

13.1 If you have any questions, concerns, or requests regarding this Privacy Policy or vipmyapp's data processing practices, please contact our Data Protection Officer (DPO) or customer support team.

13.2 If you are not satisfied with vipmyapp's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through their official channels.