ggames Privacy Policy

01 Introduction

Welcome to the ggames Privacy Policy. ggames ("we," "us," "our," or "ggames") operates the online gaming platform accessible at ggames.one and through the ggames mobile application (collectively, the "Platform"). We are committed to protecting the privacy and personal data of every player who uses our Platform.

This Privacy Policy describes:

• The categories of personal data we collect from you;
• The purposes for which we process your personal data;
• The legal bases on which we rely to process your data;
• How long we retain your data and how we keep it secure;
• Your rights as a data subject under Philippine law; and
• How to contact us or our Data Protection Officer (DPO) with any privacy-related concerns.

By registering an account on ggames or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the Platform and contact us to close your account.

02 Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, ggames is the Personal Information Controller (PIC) in respect of the personal data collected through the Platform.

As the Personal Information Controller, ggames determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data protection law.

Where ggames engages third-party service providers to process personal data on its behalf (for example, payment processors or identity verification providers), those parties act as Personal Information Processors (PIPs) and are contractually bound to process your data only on ggames' instructions and in compliance with applicable law.

03 Personal Data We Collect

ggames collects the following categories of personal data, depending on how you interact with the Platform:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued ID details (e.g., Philippine National ID, passport, driver's license, SSS/GSIS ID, PhilHealth ID, or Voter's ID).
• Contact Data: Philippine mobile number, email address, and residential address.
• Account Data: Username, encrypted password, account preferences, and communication preferences.
• Financial Data: GCash account details, PayMaya / Maya account details, bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details (card number masked, expiry date), transaction history, deposit and withdrawal records.
• Gaming Data: Game history, bet amounts, win/loss records, session duration, responsible gaming tool settings (deposit limits, loss limits, self-exclusion status).
• Technical Data: IP address, device type and model, operating system, browser type and version, mobile network information, and unique device identifiers.
• Usage Data: Pages visited, features used, time spent on the Platform, click-through data, and navigation paths.
• Communications Data: Records of your communications with ggames support, including live chat transcripts, email correspondence, and support ticket history.
• Verification Data: Selfies or photographs submitted for identity verification, and any additional documentation submitted during Know Your Customer (KYC) processes.

04 How We Collect Your Data

ggames collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or updating your account profile.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, through cookies, web beacons, log files, and similar tracking technologies (see Section 8).
• Third-Party Sources: Identity verification data from licensed KYC and anti-money laundering service providers; fraud prevention data from fraud detection services; payment data from payment processors including GCash and PayMaya.
• Regulatory Sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory bodies in connection with our compliance obligations.

05 How We Use Your Personal Data

ggames processes your personal data for the following purposes:

• Account Management: To register and maintain your player account, verify your identity, and manage your account settings and preferences.
• Service Delivery: To provide access to games, process bets, calculate and pay out winnings, and deliver the core features of the Platform.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card, and to maintain accurate financial records.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and all other applicable Philippine laws and regulations, including mandatory reporting obligations.
• Identity Verification & Fraud Prevention: To verify your age (21+), identity, and source of funds; to detect, investigate, and prevent fraud, money laundering, and other illegal activity.
• Responsible Gaming: To monitor gaming behavior, enforce responsible gaming tools (deposit limits, loss limits, self-exclusion), and identify players who may be at risk of problem gambling.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and security of the Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest to do so. You may opt out of marketing communications at any time through your account settings.
• Legal Claims: To establish, exercise, or defend legal claims in connection with the Platform or your account.

06 Legal Basis for Processing

Under the Data Privacy Act of 2012, ggames relies on the following legal bases to process your personal data:

• Contractual Necessity: Processing necessary to perform our contract with you (the Terms & Conditions), including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with our legal and regulatory obligations under PAGCOR regulations, AMLA, and other applicable Philippine law.
• Legitimate Interests: Processing necessary for our legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and certain non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

07 Sharing Your Personal Data

ggames 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 Processors: GCash (Mynt – Globe Fintech Innovations, Inc.), PayMaya / Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: Licensed KYC and AML service providers engaged to verify your identity and comply with anti-money laundering regulations.
• Game Providers: Third-party game software providers whose games are available on the Platform, to the extent necessary to deliver game services.
• IT & Security Providers: Cloud hosting, cybersecurity, and fraud detection service providers who process data on our behalf under strict contractual data processing agreements.
• 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.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors, where necessary for legal compliance or the defense of legal claims.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of ggames' business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third parties with whom ggames shares personal data are required to maintain the confidentiality and security of your data and to use it only for the specified purposes.

08 Cookies & Tracking Technologies

ggames uses cookies and similar tracking technologies on the Platform to enhance your experience, analyze usage, and support security and fraud prevention. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming tool configurations, to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players use the Platform, helping us identify areas for improvement. Used with your consent.
• Marketing Cookies: Used to deliver relevant promotional content within the Platform. Used with your consent.

You can manage your cookie preferences through your account settings or your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

09 Data Retention

ggames retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AMLA obligations.
• Financial & Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act and its implementing regulations.
• KYC & Identity Verification Data: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Support Communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications, after which it will be deleted or anonymized within thirty (30) days.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with ggames' data disposal procedures. Where data is anonymized, it may be retained indefinitely for statistical and analytical purposes.

10 Data Security

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

• Encryption: All data transmitted between your device and the ggames Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. Sensitive data at rest, including financial data and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized ggames personnel and service providers on a strict need-to-know basis. All access is logged and regularly audited.
• Two-Factor Authentication: ggames supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security.
• Penetration Testing: The Platform undergoes regular security assessments and penetration testing by independent cybersecurity professionals to identify and remediate vulnerabilities.
• Incident Response: ggames maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, ggames will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, as required by the Data Privacy Act of 2012.
• Staff Training: All ggames personnel who handle personal data receive regular data privacy and security training.

11 Your Data Subject Rights

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

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data ggames holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you. You may update most of your account information directly through your account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal and regulatory retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• 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 Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that ggames has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 15. ggames will respond to all verified data subject requests within fifteen (15) business days of receipt, as required by the Data Privacy Act and its Implementing Rules and Regulations.

Please note that certain rights are subject to limitations where processing is required for compliance with legal obligations, the performance of a contract, or the establishment, exercise, or defense of legal claims.

12 Children's Privacy and Age Restriction

The ggames Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. ggames does not knowingly collect personal data from persons under the age of 21.

If ggames becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to:

• Suspend and permanently close the relevant account;
• Refund any real-money balance to the payment method used for deposit, subject to verification;
• Securely delete all personal data associated with the underage account, except where retention is required by law.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account on ggames, please contact our support team immediately so that we can take appropriate action.

13 Third-Party Links and Services

The ggames Platform may contain references to third-party services, such as payment providers (GCash, PayMaya) and game software providers. While ggames takes care to work only with reputable partners, we are not responsible for the privacy practices of third-party services.

When you interact with a third-party service in connection with the Platform — for example, when completing a GCash payment — your personal data may be processed by that third party in accordance with their own privacy policy. We encourage you to review the privacy policies of any third-party services you use in connection with ggames.

ggames does not control and is not responsible for the content, privacy policies, or practices of any third-party websites or services that are not operated by ggames.

14 Changes to This Privacy Policy

ggames reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, we will notify you through one or more of the following methods:

• A prominent notice displayed on the Platform;
• A notification sent to your registered email address or mobile number;
• An in-app notification via the ggames mobile application.

The updated Privacy Policy will display the revised "Last Updated" date at the top of this page. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how ggames protects your personal data. If you have any concerns about changes to this policy, please contact our Data Protection Officer.

15 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 ggames, please contact our Data Protection Officer (DPO):

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.