Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how vvvjl ("vvvjl," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you" or "Player") who access or use the vvvjl online gaming platform at vvvjl.app, including all related mobile applications, features, and services (collectively, the "Platform").

vvvjl is committed to protecting your privacy and to complying with all applicable Philippine data protection laws, including Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission ("NPC"). Where applicable, vvvjl also observes the data protection requirements of the Philippine Amusement and Gaming Corporation ("PAGCOR") under whose regulatory framework the Platform operates.

By registering an account on vvvjl or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. 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, vvvjl is the personal information controller in respect of the personal data collected through the Platform. All data processing activities carried out by vvvjl are conducted in accordance with the principles of transparency, legitimate purpose, and proportionality as mandated by the DPA.

Where vvvjl engages third-party service providers to process personal data on its behalf, such providers act as personal information processors and are bound by data processing agreements that require them to implement appropriate technical and organizational security measures and to process personal data only on documented instructions from vvvjl.

03 Personal Data We Collect

vvvjl collects the following categories of personal data:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (used to verify the 21+ age requirement)
• Philippine mobile number and email address
• Residential address in the Philippines
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license, UMID, SSS, PRC, or Voter's ID number)

3.2 Financial Data

• GCash or Maya account details (registered mobile number and account name)
• Philippine bank account details (account name, account number, bank name) for withdrawal processing
• Debit card details where applicable (card number is tokenized and never stored in plain text)
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Source of funds documentation where required by anti-money laundering regulations

3.3 Gaming Activity Data

• Game session logs, including games played, bet amounts, win/loss records, and session duration
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

3.4 Technical & Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, browser type and version
• Pages visited, features used, and time spent on the Platform
• Login timestamps and session identifiers
• Cookie identifiers and similar tracking technologies (see Section 9)

3.5 Communications Data

• Records of your communications with vvvjl customer support, including live chat transcripts and email correspondence
• Survey responses and feedback submitted through the Platform
• Marketing communication preferences

04 How We Collect Your Data

vvvjl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey.
• Automatically — through cookies, web beacons, server logs, and similar technologies when you access and use the Platform (see Section 9).
• From third-party payment processors — GCash, Maya, and Philippine banking partners may share transaction confirmation data with vvvjl to facilitate deposits and withdrawals.
• From identity verification providers — vvvjl may use third-party KYC and identity verification services to validate the documents you submit. These providers process your data on vvvjl's behalf under data processing agreements.
• From regulatory authorities — PAGCOR and other competent Philippine authorities may share information with vvvjl as required by law, including self-exclusion registry data.

05 Purpose & Legal Basis for Processing

The table below sets out the purposes for which vvvjl processes your personal data and the corresponding legal basis under the Data Privacy Act of 2012:

06 Sharing Your Personal Data

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

• Payment processors: GCash, Maya, and Philippine banking partners receive the minimum data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party providers engaged to verify your identity and documents process your data solely on vvvjl's instructions under data processing agreements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or court order.
• IT and platform service providers: Cloud hosting, cybersecurity, and analytics providers who process data on vvvjl's behalf under contractual data protection obligations.
• Professional advisers: Lawyers, auditors, and accountants who are bound by professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of vvvjl's assets, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

All third-party processors engaged by vvvjl are required to implement appropriate technical and organizational security measures and to process personal data only for the specified purpose and in accordance with vvvjl's documented instructions.

07 Data Retention

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

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with RA 9160 (AMLA), as amended.
• Gaming activity logs: Retained for three (3) years from the date of each session, or longer if required for regulatory reporting or dispute resolution.
• Customer 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 preferences: Retained until you withdraw your consent or close your account, whichever is earlier.
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with vvvjl's data disposal procedures.

08 Security Measures

vvvjl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the vvvjl Platform
• Encryption at rest for sensitive personal and financial data stored on vvvjl servers
• Tokenization of payment card details — raw card numbers are never stored on vvvjl systems
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Multi-factor authentication for internal systems that process personal data
• Regular security assessments, penetration testing, and vulnerability scanning
• Incident response procedures aligned with NPC Circular 16-03 (Personal Data Breach Management)

09 Cookies & Tracking Technologies

vvvjl uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and support security functions. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled. They include session authentication tokens, CSRF protection tokens, and load-balancing cookies.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations. Disabling these may affect Platform functionality.
• Analytics cookies: Collect aggregated, anonymized data about how players use the Platform to help vvvjl improve its services. These are only set with your consent.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in to your vvvjl account. vvvjl does not use third-party advertising or behavioral tracking cookies.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by vvvjl. To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 14.

vvvjl will respond to all verified data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice to you.

11 Minors

The vvvjl Platform is strictly intended for persons who are at least twenty-one (21) years of age. vvvjl does not knowingly collect personal data from individuals under 21 years old. Age verification is conducted as part of the account registration and KYC process. If vvvjl becomes aware that personal data has been collected from a person under 21, 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 an account on vvvjl, please contact our Data Protection Officer immediately at the details in Section 14.

12 Cross-Border Data Transfers

vvvjl primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers located outside the Philippines (for example, cloud infrastructure providers or international KYC verification services), vvvjl ensures that such transfers are conducted in compliance with Section 21 of the Data Privacy Act of 2012 and the NPC's rules on cross-border data transfers. This includes ensuring that the recipient country provides an adequate level of data protection, or that appropriate contractual safeguards (such as standard contractual clauses approved by the NPC) are in place.

13 Policy Amendments

vvvjl reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days before taking effect. The "Last Updated" date at the top of this Policy will be revised accordingly. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

14 Contact & Data Protection Officer

vvvjl has appointed a Data Protection Officer ("DPO") in accordance with Section 21(c) of the Data Privacy Act of 2012. To exercise your data subject rights, raise a privacy concern, or submit a data subject request, please contact:

• Data Protection Officer, vvvjl
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 inside your account dashboard

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.