Privacy Policy

1. Who We Are

gemeph operates the online casino and sports betting platform accessible at gemeph.com. For the purposes of this Privacy Policy, gemeph acts as the data controller in respect of the personal data of registered players and visitors to the platform. As data controller, gemeph determines the purposes and means by which your personal data is processed.

If you have any questions about how gemeph handles your personal data, you may contact our Data Privacy Officer at the email address provided in Section 14 of this policy.

2. What Personal Data We Collect

gemeph collects the following categories of personal data from players and platform visitors:

gemeph does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law (for example, self-exclusion records maintained for responsible gaming purposes).

3. How We Collect Your Data

gemeph collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the gemeph platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash, PayMaya, and banking partners.
• Publicly available sources: Information from public databases used for identity verification and anti-money laundering (AML) screening purposes.

4. Why We Use Your Data (Legal Bases)

gemeph processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012 (Republic Act No. 10173):

• Account registration and management: To create and maintain your gemeph account, verify your identity, and provide access to platform services. (Contractual necessity)
• Payment processing: To process deposits, withdrawals, and refunds in Philippine Peso via your chosen payment method. (Contractual necessity)
• KYC and AML compliance: To verify your identity, prevent fraud, and comply with anti-money laundering obligations under Philippine law. (Legal obligation)
• Responsible gaming: To monitor gaming activity, enforce deposit limits, and manage self-exclusion requests in accordance with responsible gaming obligations. (Legal obligation and legitimate interest)
• Customer support: To respond to your enquiries, resolve disputes, and improve our support services. (Contractual necessity and legitimate interest)
• Platform improvement: To analyse usage patterns, fix technical issues, and develop new features on the gemeph platform. (Legitimate interest)
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — only where you have opted in to receive such communications. (Consent)
• Legal compliance: To comply with applicable Philippine laws, regulations, and court orders, including reporting obligations to PAGCOR and other regulatory bodies. (Legal obligation)

5. How We Share Your Data

gemeph does not sell your personal data. We may share your data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners, for the purpose of processing your financial transactions.
• Identity verification providers: Third-party KYC and AML service providers used to verify your identity and screen against sanctions lists.
• Game software providers: Licensed game developers whose games are hosted on the gemeph platform may receive anonymised or pseudonymised usage data for game performance purposes.
• IT and hosting providers: Cloud infrastructure and hosting partners who store and process platform data on gemeph's behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where required by law.
• Law enforcement: Philippine law enforcement agencies, where gemeph is legally required to disclose information in connection with a criminal investigation or court order.

All third-party service providers engaged by gemeph are contractually required to process your personal data only for the specified purpose and in accordance with applicable data protection laws.

6. Cookies and Tracking Technologies

gemeph uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse platform usage. 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 prevent fraudulent use. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and display options to personalise your gemeph experience.
• Analytics cookies: Collect anonymised data about how players use the gemeph platform, which pages are visited most, and where technical errors occur. This data helps us improve the platform.
• Marketing cookies: Used to deliver relevant promotional content within the gemeph platform. These are only activated where you have consented to marketing communications.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the gemeph platform.

7. Data Retention

gemeph retains your personal data for as long as your account is active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing preference records are retained until you withdraw your consent or close your account.
• Technical and usage data collected via cookies is retained for periods specified in our cookie settings, typically between 30 days and 24 months depending on the cookie type.

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

8. Data Security

8.1 gemeph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the gemeph platform.
• Encrypted storage of sensitive data, including financial information and identity documents.
• Role-based access controls ensuring that only authorised gemeph personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits and penetration testing of the gemeph platform infrastructure.
• Two-factor authentication (2FA) available for all player accounts.
• Continuous monitoring for suspicious activity and automated fraud detection systems.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, gemeph will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

9. Your Rights Under Philippine Law

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights in relation to your personal data held by gemeph:

• Right to be informed: You have the right to be informed of how your personal data is collected, used, and shared by gemeph, as set out in this Privacy Policy.
• Right of access: You may request a copy of the personal data gemeph holds about you at any time by contacting our Data Privacy Officer.
• Right to rectification: If any personal data gemeph holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update most account information directly through your gemeph account settings.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to gemeph's legal retention obligations.
• 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 opt out of marketing communications through your account settings or by contacting support.
• Right to data portability: You may request that gemeph provide your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: If you believe gemeph has not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Privacy Officer using the contact details in Section 14. gemeph will respond to all data rights requests within thirty (30) days of receipt.

10. Children and Minors

The gemeph platform is strictly for adults aged 21 years and above, in accordance with Philippine gaming regulations. gemeph does not knowingly collect personal data from individuals under the age of 21. If gemeph becomes aware that personal data has been collected from a minor, that data will be deleted immediately and the associated account will be permanently closed.

If you are a parent or guardian and believe that a minor has registered on the gemeph platform using your details or their own, please contact our support team immediately at [email protected] so that we can take prompt action.

11. International Data Transfers

In some cases, your personal data may be transferred to and processed in countries outside the Philippines — for example, where gemeph's cloud infrastructure providers or game software partners operate servers in other jurisdictions. Where such transfers occur, gemeph ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law, including through the use of contractual data protection clauses with all international data processors.

12. Third-Party Links and Services

The gemeph platform may contain references to third-party payment services (such as GCash and PayMaya) whose own privacy policies govern the processing of your data on their respective platforms. gemeph is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party service you use in connection with your gemeph account.

13. Changes to This Privacy Policy

gemeph reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, gemeph will notify registered players via email or a prominent notice on the platform prior to the changes taking effect. The "Last updated" date at the top of this page will always reflect the most recent revision.

Your continued use of the gemeph platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you must discontinue use of the platform and may request account closure.

14. How to Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way gemeph handles your personal data, please contact our Data Privacy Officer:

Email: [email protected]

Our support team is available 24 hours a day, 7 days a week. Please include your registered account username and a clear description of your query when contacting us. gemeph aims to respond to all privacy-related enquiries within 72 hours.

For complaints that cannot be resolved directly with gemeph, you may contact the National Privacy Commission of the Philippines at privacy.gov.ph.