ernphp Privacy Policy

1. Introduction

ernphp ("Company," "we," "us," or "our") operates the online gaming platform accessible at ernphp.org and associated mobile applications (collectively, the "Platform"). This Privacy Policy describes how ernphp collects, processes, stores, and discloses personal information about individuals who register as Players, visit the Platform as guests, or otherwise interact with ernphp's services.

This Policy is issued in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and applicable guidelines issued by the National Privacy Commission ("NPC"). ernphp is a registered personal information controller under the DPA.

By accessing or using the ernphp Platform, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree, please discontinue use of the Platform immediately.

2. Information We Collect

2.1 Registration and Identity Information

When you create an ernphp account, we collect the following personal information:

• Full legal name as it appears on government-issued identification;
• Date of birth (for age verification — you must be 21 or older);
• Philippine mobile number and/or email address;
• Username and encrypted password;
• Residential address in the Philippines.

2.2 Know Your Customer (KYC) Documents

Philippine regulations require ernphp to verify the identity of Players prior to processing withdrawals. KYC documents collected may include:

• Government-issued photo identification (e.g., Philippine National ID, SSS ID, Passport, Driver's License);
• Proof of address (e.g., recent utility bill, bank statement addressed to your registered address);
• Proof of payment method ownership (e.g., screenshot of GCash account showing your registered name).

2.3 Financial Transaction Data

ernphp records all deposit and withdrawal transactions, including amounts in Philippine Peso, timestamps, payment method references (e.g., GCash transaction IDs, BPI reference numbers), and transaction outcomes.

2.4 Gaming Activity Data

We record your gameplay activity on the ernphp Platform, including games played, bet amounts and outcomes, session durations, and interaction with promotions and bonuses.

2.5 Technical and Device Data

When you access ernphp, we automatically collect technical information including your IP address, device type and operating system, browser type and version, session timestamps, and referring URL. This information is used for security monitoring, fraud prevention, and platform performance optimisation.

2.6 Communications Data

If you contact ernphp's support team, we record the content of communications, including live chat transcripts, emails, and any attachments submitted, for quality assurance and dispute resolution purposes.

3. How We Use Your Information

ernphp uses personal data collected from Filipino players for the following purposes:

• Account Management: To create and maintain your ernphp account, authenticate your identity at login, and provide access to Platform services;
• Age and Identity Verification: To verify that you are at least 21 years of age and to comply with KYC obligations under PAGCOR regulations and the Anti-Money Laundering Act;
• Transaction Processing: To process GCash deposits, PayMaya payments, bank transfers, and withdrawals in Philippine Peso;
• Regulatory Compliance: To comply with obligations imposed by PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission;
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling and to administer self-exclusion requests in compliance with ernphp's Responsible Gaming Policy;
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, account compromise, money laundering, and other prohibited activities;
• Customer Support: To respond to your enquiries, complaints, and dispute resolution requests;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have opted in to receive such communications. You may withdraw consent at any time through your account settings;
• Platform Improvement: To analyse aggregated usage data for the purpose of improving ernphp's services, game offerings, and user experience.

4. Legal Basis for Processing

ernphp processes personal data under the following legal bases as prescribed by the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and ernphp, including account administration, game access, and payment processing;
• Legal Obligation: Processing is required to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and NPC guidelines;
• Legitimate Interest: Processing is necessary for ernphp's legitimate interests in operating a secure and compliant gaming platform, including fraud prevention and security monitoring;
• Consent: Where processing is not covered by the above bases — particularly for direct marketing communications — ernphp relies on your explicit consent, which may be withdrawn at any time.

5. Sharing Your Information

ernphp does not sell your personal data to third parties. We may share your information with the following categories of recipients, strictly on a need-to-know basis:

• Payment Service Providers: GCash (GXI), PayMaya, BPI, BDO, Metrobank, and 7-Eleven payment processors, to the extent necessary to execute transactions;
• KYC and Identity Verification Services: Third-party KYC providers engaged to verify identity documents in compliance with regulatory requirements;
• Game Software Providers: ernphp's game content providers receive aggregated, anonymised gameplay data for RTP auditing and performance reporting;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where required by law or regulatory obligation;
• IT and Security Service Providers: Cloud hosting, cybersecurity, and fraud detection providers engaged by ernphp under strict data processing agreements requiring equivalent data protection standards.

All third parties with whom ernphp shares personal data are contractually required to process such data only for specified purposes and in accordance with applicable Philippine data protection law.

6. Cookies and Tracking Technologies

The ernphp Platform uses cookies and similar tracking technologies to provide a functional and personalised experience. Categories of cookies used include:

• Strictly Necessary Cookies: Required for the Platform to function, including session authentication and security tokens. These cannot be disabled without affecting Platform functionality;
• Performance and Analytics Cookies: Collect anonymised data about how players use the Platform, page load performance, and error tracking, used solely for Platform improvement;
• Preference Cookies: Store your Platform preferences such as language and display settings;
• Marketing Cookies: Used only where you have provided consent, to deliver relevant promotional content within the ernphp Platform.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the ernphp Platform.

7. Data Retention

ernphp retains personal data for the following periods:

• Active Account Data: For the duration of your ernphp account, plus a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations;
• KYC Documents: Five (5) years from the date of account closure or the date of the last transaction, whichever is later;
• Transaction Records: Five (5) years from the date of transaction, in compliance with AMLC record-keeping obligations;
• Support Communications: Two (2) years from the date of the last communication, unless retention is required for ongoing dispute resolution;
• Marketing Data: Until consent is withdrawn, or one (1) year of inactivity, whichever comes first.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with ernphp's data retention schedule.

8. Your Data Rights

Under the Data Privacy Act of 2012, Filipino players have the following rights with respect to their personal data held by ernphp:

• Right to Be Informed: The right to know what personal data ernphp holds about you and how it is processed;
• Right of Access: The right to request a copy of the personal data ernphp holds about you;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected;
• Right to Erasure: The right to request deletion of personal data where retention is no longer legally required. Note that data subject to regulatory retention obligations cannot be deleted before the required retention period expires;
• Right to Object: The right to object to processing of your personal data for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to File a Complaint: The right to file a complaint with the National Privacy Commission if you believe your data rights have been violated.

To exercise any of the above rights, please contact ernphp's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." ernphp will respond within fifteen (15) business days.

9. Data Security

ernphp implements industry-standard technical and organisational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ernphp Platform;
• Encryption of personal data at rest within ernphp's secure data infrastructure;
• Access controls limiting employee access to personal data strictly to those with a business need;
• Continuous security monitoring and intrusion detection systems;
• Regular security audits and penetration testing by independent third-party security specialists.

In the event of a personal data breach that poses a risk to the rights of affected individuals, ernphp will notify the National Privacy Commission and affected Players within seventy-two (72) hours of becoming aware of the breach, as required by the DPA and NPC Circular 16-03.

10. Children's Privacy

The ernphp Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine gaming law. ernphp does not knowingly collect personal data from persons under 21 years of age. If ernphp becomes aware that personal data has been collected from an underage individual, such data will be immediately deleted and the associated account closed. If you believe an underage person has registered on ernphp, please contact us immediately at [email protected].

11. Cross-Border Data Transfers

ernphp's primary data infrastructure is located in the Philippines. Where operational requirements necessitate the transfer of personal data to service providers outside the Philippines — including cloud infrastructure providers and KYC verification services — ernphp ensures that such transfers comply with Section 21 of the Data Privacy Act, including the requirement that the receiving jurisdiction provides an adequate level of protection for personal data, or that appropriate contractual safeguards are in place.

12. Changes to This Privacy Policy

ernphp reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered Players via the email address or mobile number on file at least fourteen (14) days before taking effect, and the updated Policy will be published on this page with a revised effective date. Your continued use of the ernphp Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

13. Contact and Data Protection Officer

ernphp has appointed a Data Protection Officer (DPO) in compliance with the Data Privacy Act of 2012. For any privacy-related enquiries, data subject requests, or complaints, please contact:

• Data Protection Officer Email: [email protected] (Subject: "Data Privacy Request")
• Response Time: ernphp targets a response to all privacy requests within fifteen (15) business days
• Support Hours: 24/7 Philippine Standard Time for general support; DPO requests are handled during Philippine business hours

For complaints that are not resolved to your satisfaction through ernphp's internal process, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.