ernphp Privacy Policy

1.1 This Policy applies to all personal data processed by ernphp in connection with your use of the Platform, including data collected during registration, gameplay, financial transactions, customer support interactions, and general browsing of ernphp.app.

1.2 This Policy should be read together with the ernphp Terms & Conditions, which govern your overall use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions with respect to the handling of personal data, this Policy prevails.

1.3 This Policy does not apply to third-party platforms, websites, or services that may be linked to or accessible through the ernphp Platform. ernphp is not responsible for the privacy practices of such third parties, and we encourage you to review the privacy policies of any third-party services you engage with.

2.1 For the purposes of the Data Privacy Act of 2012 and its Implementing Rules, ernphp is the personal information controller with respect to all personal data collected and processed through the Platform.

2.2 ernphp operates as a Philippine-market online gaming platform in compliance with applicable Philippine gambling regulations. All data processing activities described in this Policy are conducted within the scope of ernphp's authorised operations.

2.3 Inquiries regarding this Policy and data privacy matters may be directed to the ernphp Data Privacy contact, reachable via the support email displayed in plain text at the conclusion of this Policy.

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

3.2 Where ernphp requires you to provide personal data to comply with a legal or regulatory obligation (such as KYC verification), failure to provide such data may result in ernphp being unable to open, maintain, or process transactions on your account.

4.1 ernphp collects personal data through the following means:

• Direct provision: Data you supply when registering an ernphp account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in surveys or promotions;
• Automated collection: Technical and gameplay data collected automatically through cookies, server logs, and tracking technologies when you access or use the Platform;
• Third-party sources: Identity verification data received from KYC/AML service providers; payment confirmation data received from GCash, PayMaya, and banking partners; fraud and risk signals received from licensed security intelligence providers;
• Regulatory sources: Information received from PAGCOR or other competent Philippine authorities as required by law.

5.1 ernphp processes your personal data on one or more of the following lawful bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract with you — specifically, the ernphp Terms & Conditions — including account management, gameplay facilitation, and financial transactions;
• Legal obligation: Processing required to comply with applicable Philippine law, PAGCOR requirements, anti-money laundering obligations under AMLA (Republic Act No. 9160, as amended), and the Data Privacy Act of 2012;
• Legitimate interests: Processing necessary for ernphp's legitimate interests in fraud prevention, Platform security, and service improvement, where such interests are not overridden by your privacy rights;
• Consent: Processing for optional purposes such as marketing communications, where we have obtained your explicit, prior consent. You may withdraw consent at any time by contacting ernphp support or updating your communication preferences.

6.1 ernphp uses your personal data for the following purposes:

• Account management: Creating and maintaining your ernphp account; authenticating your identity at login; processing password resets and OTP delivery to your Philippine mobile number;
• Platform operation: Enabling gameplay, sports betting, bingo participation, and all other game verticals available on the Platform; recording gaming history; calculating and crediting winnings;
• Financial processing: Processing GCash, PayMaya, and bank deposits and withdrawals; maintaining transaction records; complying with AML obligations;
• Regulatory compliance: Satisfying PAGCOR reporting requirements; age verification; responding to lawful requests from Philippine authorities;
• Fraud and security: Detecting and preventing unauthorized account access, fraudulent transactions, collusion, and other prohibited conduct;
• Responsible gaming: Administering deposit limits, session reminders, cooling-off periods, and self-exclusion; identifying and supporting players showing problem gaming patterns;
• Customer support: Responding to your inquiries, complaints, and support requests via live chat and email;
• Service improvement: Analysing aggregated and anonymised usage data to improve Platform features, game selection, and the overall ernphp experience;
• Marketing (consent-based only): Sending promotional offers, bonus notifications, and ernphp news to players who have opted in to receive such communications.

7.1 ernphp does not sell, rent, or otherwise commercially transfer your personal data to third parties for their own marketing or commercial purposes.

7.2 ernphp may disclose your personal data to the following categories of recipients, strictly to the extent necessary for the purposes described in this Policy:

• Payment service providers: GCash (Mynt), PayMaya (Maya Bank), BPI, BDO, Metrobank, InstaPay operators, and other accredited payment processors — for the purpose of executing your deposits and withdrawals;
• KYC/AML service providers: Licensed identity verification and anti-money laundering compliance technology vendors engaged by ernphp to perform document verification and sanctions screening;
• Game technology providers: Third-party game studios and platform technology partners whose software powers specific games or features on the ernphp Platform. These providers receive only the minimum data required for session management;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and other competent Philippine authorities, where disclosure is required by applicable law or a lawful order;
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by ernphp, subject to confidentiality obligations;
• Corporate successors: In the event of a merger, acquisition, or sale of assets involving ernphp, your personal data may be transferred to the acquiring entity, subject to the same protections described in this Policy.

7.3 Where ernphp engages third-party processors, it does so under contracts that require those processors to handle personal data in accordance with applicable law and ernphp's instructions.

8.1 ernphp uses cookies and similar tracking technologies on the Platform to enhance user experience, maintain login sessions, detect fraud, and analyse Platform performance. The following types of cookies are used:

• Strictly necessary cookies: Essential for Platform operation, including maintaining your authenticated session and enforcing security measures. These cannot be disabled without significantly impairing Platform functionality;
• Functional cookies: Used to remember your preferences, such as language settings and game display preferences;
• Analytics cookies: Used to collect aggregated, anonymised data on how players use the Platform, enabling ernphp to identify and address usability issues;
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and IP-based anomaly identification.

8.2 You may control cookie settings through your browser. Disabling non-essential cookies will not prevent you from accessing core Platform features, but may affect certain personalisation functions.

9.1 ernphp retains personal data for the following periods, or longer where required by applicable law:

9.2 Upon expiry of the applicable retention period, ernphp will securely delete or permanently anonymise your personal data in a manner that prevents reconstruction or identification.

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

• Transmission security: 256-bit SSL/TLS encryption for all data transmitted between your device and the ernphp Platform;
• Storage security: Encryption of sensitive data at rest, including identity documents and financial data;
• Access controls: Role-based internal access controls limiting employee access to personal data on a need-to-know basis; multi-factor authentication for administrative systems;
• Monitoring: Real-time intrusion detection and security event logging; regular vulnerability assessments and penetration testing;
• Staff training: Regular data privacy and security training for all ernphp employees handling personal data;
• Incident response: A documented data breach response procedure including mandatory notification timelines in accordance with the Data Privacy Act.

10.2 In the event of a personal data breach that is reasonably likely to give rise to a real risk of serious harm to affected individuals, ernphp will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals as required by law.

10.3 Notwithstanding the foregoing, no data transmission over the internet or electronic storage system is entirely immune from security risks. ernphp cannot guarantee absolute security, and you assume some risk in transmitting information electronically.

11.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ernphp. These are real, enforceable rights — not formalities.

12.1 The ernphp Platform is strictly restricted to persons aged twenty-one (21) years and above. ernphp does not knowingly collect personal data from individuals under twenty-one (21) years of age.

12.2 If ernphp becomes aware that it has inadvertently collected personal data from an underage individual, it will immediately suspend the relevant account, forfeit any associated balance, and delete the personal data in accordance with its legal obligations.

12.3 If you are a parent or legal guardian and believe that your child has registered on the ernphp Platform, please contact our support team immediately. We will investigate and take appropriate action as quickly as possible.

13.1 ernphp primarily processes personal data within the Republic of the Philippines. Where it is necessary for operational reasons — such as engaging cloud infrastructure providers or licensed KYC technology partners located outside the Philippines — personal data may be transferred to servers or processors in other jurisdictions.

13.2 Any cross-border transfer of personal data by ernphp is conducted in accordance with the requirements of the Data Privacy Act of 2012 and the NPC's implementing guidelines on cross-border transfers. ernphp ensures that adequate protections are in place — such as contractual data processing agreements or the recipient country's recognized data protection framework — before transferring personal data outside the Philippines.

13.3 You may contact ernphp's data privacy team to request information about the safeguards in place for any specific cross-border transfer affecting your personal data.

14.1 ernphp reserves the right to update or amend this Policy at any time to reflect changes in its data processing practices, applicable law, or regulatory requirements.

14.2 Material changes to this Policy will be communicated to registered ernphp users via email to their registered address or via a notification displayed upon login to the Platform. The "Last Updated" date at the top of this Policy will be revised to reflect the date of the most recent amendment.

14.3 Your continued use of the ernphp Platform following notification of a material change constitutes your acknowledgment of the updated Policy. If you do not accept the updated Policy, you should cease using the Platform and may request account closure in accordance with the Terms & Conditions.

15.1 For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by ernphp, please contact our support and data privacy team through the live chat feature available on the Platform, or by writing to us at the plain-text email address below.

15.2 ernphp support and data privacy contact (plain text — not a link):

15.3 ernphp will acknowledge data privacy requests within five (5) business days and will respond substantively within thirty (30) calendar days from the date of receipt, in accordance with the Data Privacy Act of 2012.

15.4 National Privacy Commission (NPC). If you are dissatisfied with ernphp's response to your data privacy inquiry, you have the right to escalate your concern to the National Privacy Commission of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012 and its Implementing Rules.