earph Privacy Policy

earph collects personal data that is necessary to provide you with a safe, compliant, and enjoyable online gaming experience. We collect information in the following categories:

1.1 Registration and Account Information

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

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify the 21+ age requirement)
• Residential address (including barangay, city/municipality, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password
• Preferred currency (Philippine Peso / PHP)

1.2 Identity Verification (KYC) Documents

To comply with PAGCOR regulations and Philippine anti-money laundering laws, earph may request the following documents before processing withdrawals or when required by our compliance team:

• Government-issued photo ID (e.g., Philippine passport, SSS ID, UMID, PhilSys National ID, driver's license, PRC ID, voter's ID)
• Proof of address (e.g., utility bill, bank statement, or barangay certificate issued within the last three months)
• Selfie with ID for liveness verification
• Source of funds documentation where required by law

1.3 Financial and Transaction Data

earph collects data related to your financial transactions on the platform, including:

• Deposit and withdrawal amounts, dates, and methods
• GCash or Maya account reference numbers (we do not store full account credentials)
• Bank account details used for transfers (account name and last four digits only)
• Transaction history and wallet balance records

1.4 Gaming Activity Data

earph maintains detailed records of your gaming activity on the platform, including:

• Games played, bet amounts, and game outcomes
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool settings and self-exclusion records

1.5 Technical and Device Data

When you access the earph platform, we automatically collect certain technical information:

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Session timestamps and login history
• Cookies and similar tracking technologies (see Section 7)
• Referral source (how you arrived at the earph platform)

1.6 Communications Data

If you contact earph customer support, we retain records of those communications, including live chat transcripts, email correspondence, and any information you provide during support interactions. This data is used to resolve your queries and improve our support services.

earph processes your personal data only for legitimate, specified purposes. The table below summarizes the primary purposes for which we use your data and the legal basis for each:

Purpose	Legal Basis
Creating and managing your earph account	Performance of contract
Processing deposits and withdrawals	Performance of contract
Verifying your identity and age (KYC)	Legal obligation (PAGCOR / AMLA)
Detecting and preventing fraud and money laundering	Legal obligation / Legitimate interest
Providing customer support	Performance of contract
Administering bonuses and promotions	Performance of contract
Responsible gaming monitoring and intervention	Legal obligation / Legitimate interest
Sending transactional notifications (deposits, withdrawals, security alerts)	Performance of contract
Sending marketing communications (with your consent)	Consent
Improving platform performance and user experience	Legitimate interest
Complying with regulatory reporting obligations	Legal obligation

2.1 Marketing Communications

earph may send you promotional emails, SMS messages, or in-platform notifications about new games, bonuses, and special offers — but only if you have given your explicit consent to receive such communications during registration or through your account settings. You may withdraw your consent and opt out of marketing communications at any time by updating your notification preferences in your earph account settings or by contacting our support team.

2.2 Automated Decision-Making

earph uses automated systems to detect fraudulent activity, identify problem gambling patterns, and enforce responsible gaming limits. Where an automated decision significantly affects your account (such as a temporary suspension triggered by fraud detection), you have the right to request human review of that decision by contacting our support team.

earph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following limited circumstances:

3.1 Service Providers and Data Processors

earph works with carefully selected third-party service providers who process personal data on our behalf to help us operate the platform. These include:

• Payment processors: GCash, Maya, and banking partners process transaction data necessary to complete deposits and withdrawals.
• Identity verification providers: KYC and document verification partners who help us confirm player identities in compliance with PAGCOR and AMLA requirements.
• Cloud hosting and infrastructure: Secure server and data storage providers who host the earph platform under strict data processing agreements.
• Customer support platforms: Live chat and ticketing system providers who facilitate player support interactions.
• Analytics providers: Platform analytics tools that help us understand how players use earph so we can improve the experience. Analytics data is aggregated and anonymized where possible.

All third-party service providers are contractually bound to process your data only as instructed by earph, to maintain appropriate security standards, and not to use your data for their own purposes.

3.2 Regulatory and Legal Disclosures

earph may be required to disclose your personal data to regulatory authorities, law enforcement agencies, or courts in the Philippines where required by law. This includes disclosures to:

• PAGCOR, in connection with our gaming license obligations and regulatory audits
• The Anti-Money Laundering Council (AMLC), where transactions trigger mandatory reporting thresholds under the Anti-Money Laundering Act
• Philippine law enforcement agencies, pursuant to a valid court order or lawful request
• The National Privacy Commission (NPC), in connection with data breach notifications or regulatory inquiries

3.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of earph's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it.

earph 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. The following retention periods apply:

Data Category	Retention Period
Account registration information	Duration of account + 5 years after closure
KYC / identity verification documents	Duration of account + 5 years after closure (AMLA requirement)
Financial transaction records	10 years (AMLA / BIR requirement)
Gaming activity logs	5 years after last activity
Customer support communications	3 years after resolution
Marketing consent records	Until consent is withdrawn + 1 year
Self-exclusion records	Minimum 6 years after exclusion period ends
Technical / device logs	12 months on a rolling basis

When your data is no longer required, earph will securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data that cannot be used to identify you may be retained indefinitely for statistical and analytical purposes.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by earph:

5.1 Right to Be Informed

You have the right to be informed about how earph collects, uses, stores, and shares your personal data. This Privacy Policy fulfills that obligation. If you have questions about any aspect of our data practices, you may contact our Data Protection Officer (DPO).

5.2 Right to Access

You have the right to request a copy of the personal data earph holds about you. Access requests will be processed within fifteen (15) business days of receipt. We may ask you to verify your identity before fulfilling an access request.

5.3 Right to Rectification

If any personal data earph holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update most of your account information directly through your earph account settings. For changes to identity-verified information (such as your legal name or date of birth), please contact our support team with supporting documentation.

5.4 Right to Erasure

You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other legal basis for processing. Please note that earph may be required to retain certain data for regulatory compliance purposes (see Section 4) even after an erasure request is received. In such cases, we will inform you of the specific legal obligation that prevents full deletion.

5.5 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on earph's legitimate interests, though we may be able to demonstrate compelling grounds to continue processing in certain circumstances.

5.6 Right to Data Portability

Where technically feasible, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format, and to request that it be transmitted to another data controller.

5.7 How to Exercise Your Rights

To exercise any of the rights described above, please contact the earph Data Protection Officer via the customer support team. We will respond to all valid requests within fifteen (15) business days. We may need to verify your identity before processing your request. There is no fee for exercising your data privacy rights, though we reserve the right to charge a reasonable administrative fee for manifestly unfounded or excessive requests.

5.8 Right to Lodge a Complaint

If you believe earph has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to file a complaint is available on the NPC's official website.

earph takes the security of your personal data seriously and implements a comprehensive set of technical and organizational measures to protect it against unauthorized access, disclosure, alteration, or destruction.

6.1 Technical Security Measures

• SSL/TLS Encryption: All data transmitted between your device and the earph platform is encrypted using 256-bit SSL/TLS protocols.
• Data Encryption at Rest: Sensitive personal data stored in earph's databases is encrypted at rest using industry-standard encryption algorithms.
• Password Security: Player passwords are hashed using strong one-way hashing algorithms. earph staff cannot view your password in plain text.
• Two-Factor Authentication (2FA): earph offers optional 2FA for player accounts to provide an additional layer of login security.
• Firewall and Intrusion Detection: earph's infrastructure is protected by enterprise-grade firewalls and continuous intrusion detection and prevention systems.
• Regular Security Audits: earph conducts regular security assessments and penetration testing to identify and remediate vulnerabilities.

6.2 Organizational Security Measures

• Access to personal data is restricted to earph staff who need it to perform their job functions, on a strict need-to-know basis.
• All earph staff with access to personal data are subject to confidentiality obligations and receive regular data privacy training.
• earph maintains a formal data breach response plan and will notify affected players and the NPC in the event of a breach that poses a risk to player rights, in accordance with the Data Privacy Act.

6.3 Your Role in Security

While earph takes extensive measures to protect your data, you also play an important role in keeping your account secure. You should use a strong, unique password for your earph account, enable 2FA where available, never share your login credentials with anyone, and log out of your account when using shared or public devices. If you suspect your account has been compromised, contact earph support immediately.

earph uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze how players use the site. A cookie is a small text file placed on your device when you visit a website.

7.1 Types of Cookies We Use

Cookie Type	Purpose	Can Be Disabled?
Strictly Necessary	Essential for the platform to function — login sessions, security tokens, load balancing	No (required for operation)
Functional	Remember your preferences such as language, game settings, and responsible gaming limits	Yes
Analytics	Understand how players navigate the platform to improve performance and user experience	Yes
Marketing	Deliver relevant promotional content based on your activity (only with your consent)	Yes

7.2 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the earph platform. Instructions for managing cookies are available in the help documentation of all major browsers. Disabling strictly necessary cookies will prevent you from logging in to your earph account.

The earph platform is strictly intended for adults aged 21 years and above. earph does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register for or use the earph platform.

If earph becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe your child has registered on the earph platform, please contact our support team immediately so we can take appropriate action.

earph recommends that households with minors install parental control software to prevent unauthorized access to online gambling platforms.

earph may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform features. When we make material changes to this policy, we will notify registered players via email or a prominent notice on the earph platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how earph protects your personal data. Your continued use of the earph platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy.