earnpho Privacy Policy

1. About This Policy

This Privacy Policy describes how earnpho ("we", "us", "our", or "the Platform") collects, uses, stores, and discloses personal information about individuals ("you", "your", "Player") who access or use the earnpho website at https://earnpho.net and all related services offered through the platform.

earnpho is committed to protecting the privacy and personal data of every Filipino player who chooses to use our online casino and sports betting services. This Policy has been prepared in accordance with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy should be read together with the earnpho Terms & Conditions, which also form part of the overall agreement between you and earnpho.

2. Data We Collect

earnpho collects personal data that is necessary and proportionate to the purposes of operating a licensed online gaming platform in the Philippines. The categories of personal data we collect include, but are not limited to, the following:

2.1 Identity & Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth (for age verification — you must be at least 21 years old)
• Residential address, city, and postal code (e.g., Quezon City, Makati, Cebu, Davao)
• Valid email address and mobile number
• Nationality and citizenship details where required for regulatory compliance

2.2 Verification & KYC Documents

• Government-issued photo identification (e.g., Philippine National ID, passport, driver's licence, UMID, SSS, PhilHealth, or voter's ID)
• Proof of address documents (e.g., utility bill, bank statement issued within 90 days)
• Proof of payment method (e.g., GCash account name/number, bank account details for BPI, BDO, or Metrobank)
• Selfie or live photo verification images where required

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, amounts, and timestamps
• Payment method details (e.g., GCash reference numbers, PayMaya account identifiers, bank transfer references)
• Account balance history and bonus credit/debit records
• Information required for anti-money laundering (AML) compliance reporting

2.4 Gaming & Behavioural Data

• Game session records including game type, stakes, results, duration, and frequency
• Sports betting selections, odds accepted, and settlement records
• Responsible gaming tool usage (deposit limits set, cooling-off periods, self-exclusion requests)
• Customer support interactions and complaint records

2.5 Technical & Device Data

• IP address and approximate geolocation at the time of login and gameplay
• Device type, operating system, and browser version
• Session identifiers and authentication tokens
• Cookie data and similar tracking technology outputs (see Section 7)

3. How We Collect Your Data

earnpho collects your personal data through the following channels and methods:

• Direct collection: When you register an Account on earnpho, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a survey or promotion.
• Automated collection: When you access and navigate the earnpho platform, our systems automatically collect technical and device data including your IP address, session data, and cookie information.
• Third-party sources: earnpho may receive data about you from third-party identity verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, or Metrobank), fraud prevention services, and regulatory databases where we are required to conduct due diligence checks.
• Regulatory obligations: In certain circumstances, earnpho may be required by PAGCOR or other Philippine regulatory authorities to collect and verify specific information about you as a condition of maintaining its operating licence.

4. How We Use Your Data

earnpho uses your personal data for the following purposes:

• To create and manage your earnpho Account and verify your identity and eligibility to use the platform.
• To process deposits, withdrawals, and in-platform transactions securely and accurately.
• To provide and improve the casino games, live dealer tables, slots, bingo, and sports betting services available on earnpho.
• To conduct age verification and KYC checks as required by PAGCOR regulations and applicable Philippine anti-money laundering law.
• To detect, investigate, and prevent fraud, collusion, money laundering, and other prohibited conduct on the platform.
• To administer bonuses, promotions, and tournament rewards in accordance with the applicable promotional terms.
• To send you account-related notifications, transaction confirmations, and service updates via your registered email address or mobile number.
• To send you promotional communications and personalised offers where you have consented to receive marketing, and to allow you to opt out at any time.
• To support responsible gaming by monitoring gaming patterns and providing access to earnpho's responsible gaming tools where appropriate.
• To comply with our legal, regulatory, and reporting obligations under Philippine law, including obligations to PAGCOR and the Anti-Money Laundering Council (AMLC).
• To handle customer support queries, complaints, and dispute resolution processes.
• To perform analytics and platform improvement activities using aggregated, anonymised data.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, earnpho processes your personal data on the following legal grounds:

• Contractual necessity: Processing is necessary to fulfil our contractual obligations to you under the earnpho Terms & Conditions, including Account management, transaction processing, and service delivery.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act.
• Consent: Where processing is not covered by the above grounds — in particular for direct marketing communications — earnpho relies on your freely given, specific, and informed consent. You may withdraw this consent at any time.
• Legitimate interests: In limited circumstances, earnpho may process your data where it is in our legitimate interests to do so (for example, for fraud prevention, platform security, or improving our services), provided that those interests are not overridden by your data protection rights.

6. Sharing Your Data

earnpho does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your data with the following categories of recipients strictly as necessary to operate the platform and comply with applicable law:

6.1 Service Providers

earnpho works with trusted third-party service providers who assist in delivering our platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification and KYC providers, cloud infrastructure and hosting providers, game software suppliers, and customer support tools. All such providers are contractually bound to process your data only on earnpho's instructions and in accordance with applicable data protection law.

6.2 Regulatory & Law Enforcement Authorities

earnpho is required by Philippine law to disclose certain personal data and transaction information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent authorities upon lawful request or as required by applicable reporting obligations. Such disclosures are made only to the extent required by law.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of earnpho's business assets, your personal data may be transferred to the relevant successor entity, subject to the same level of data protection as described in this Privacy Policy. You will be notified of any such transfer in advance where practicable.

6.4 Professional Advisers

earnpho may share your data with its legal counsel, auditors, and other professional advisers where necessary for the conduct of legal proceedings, compliance audits, or regulatory investigations, subject to appropriate confidentiality obligations.

7. Cookies & Tracking Technologies

earnpho uses cookies and similar tracking technologies to operate and improve the platform, personalise your experience, and analyse platform usage. The following types of cookies are used:

• Strictly necessary cookies: Required for the basic functioning of the earnpho platform, including session management, login authentication, and security features. These cannot be disabled without affecting core functionality.
• Functional cookies: Used to remember your preferences, language settings, and customisation choices to provide a more personalised experience on earnpho.
• Analytics cookies: Help earnpho understand how players navigate and use the platform, enabling us to identify areas for improvement and measure the effectiveness of features. Data collected is aggregated and anonymised where possible.
• Security and fraud prevention cookies: Assist earnpho in detecting and preventing fraudulent activity, collusion, and other forms of platform abuse.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may limit your access to some features of the earnpho platform. earnpho does not use cookies to serve third-party advertising on behalf of external advertisers.

8. Data Retention

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

• Account and identity data: Retained for the duration of your earnpho Account, and for a minimum period of five (5) years following Account closure, in line with PAGCOR regulatory record-keeping requirements and the AMLA.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine anti-money laundering regulations.
• KYC and verification documents: Retained for the duration of your Account and for five (5) years following Account closure or the last transaction date, whichever is later.
• Customer support and communications: Retained for up to three (3) years from the date of the interaction, or longer where the subject matter relates to an ongoing dispute or legal proceeding.
• Marketing preferences: Retained until you withdraw consent or request erasure, subject to any overriding legal retention obligations.

When personal data is no longer required for its original purpose and no legal obligation exists to retain it, earnpho will securely delete, anonymise, or destroy it in accordance with our internal data disposal procedures.

9. Data Security

earnpho implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• SSL/TLS encryption for all data transmitted between your device and the earnpho platform.
• Encryption of sensitive data at rest, including payment information and identity documents.
• Strict access controls ensuring that only authorised earnpho personnel with a legitimate need can access your personal data.
• Regular security assessments, penetration testing, and vulnerability management procedures.
• Multi-factor authentication options for Player Accounts and mandatory for internal administrative access.
• Secure data disposal procedures for personal data that is no longer required.

While earnpho takes all reasonable steps to protect your data, no digital transmission or storage system is completely secure. You are responsible for maintaining the security of your Account credentials and for notifying earnpho promptly if you suspect any unauthorised access to your Account.

10. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by earnpho. You may exercise these rights at any time by contacting our Data Protection Officer at [email protected]:

• Right to be informed: You have the right to be informed about how earnpho collects, uses, and processes your personal data. This Privacy Policy fulfils that obligation.
• Right of access: You may request a copy of the personal data earnpho holds about you, along with information about how it is being used.
• Right to correction: You may request that earnpho corrects any personal data about you that is inaccurate, incomplete, or out of date.
• Right to erasure: In certain circumstances, you may request that earnpho deletes your personal data. This right is subject to overriding legal and regulatory retention obligations.
• Right to object: You may object to earnpho's processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to earnpho's legal basis for that processing.
• Right to data portability: Where technically feasible and legally required, you may request that earnpho provides your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that took place before withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that earnpho has not handled your personal data in accordance with applicable law.

earnpho will respond to all legitimate privacy rights requests within thirty (30) calendar days of receipt, or within such shorter period as may be required by applicable law. We may need to verify your identity before processing a request.

11. Children & Minors

earnpho's services are strictly restricted to individuals who are 21 years of age or older, in compliance with PAGCOR's minimum age requirement for online gambling in the Philippines. earnpho does not knowingly collect, store, or process the personal data of individuals under the age of 21.

If earnpho becomes aware that it has inadvertently collected personal data from an individual under 21 years of age, it will immediately close the relevant Account, forfeit any associated Bonus Funds, and delete the personal data concerned in accordance with our data retention procedures. Any real-money balance will be returned in accordance with applicable law.

Parents and guardians who believe that their child may have registered on earnpho are encouraged to contact us immediately at [email protected] so that we can take appropriate action without delay.

12. Third-Party Links

The earnpho platform may contain references to or links from third-party services such as payment processors (GCash, PayMaya, BPI, BDO, Metrobank) or game provider platforms. earnpho is not responsible for the privacy practices or content of any third-party websites or services. When you leave the earnpho platform to access a third-party service, you do so at your own risk and subject to that third party's own privacy policy.

We encourage you to review the privacy policies of any third-party services you use in connection with your earnpho experience, particularly your chosen payment provider, before submitting personal or financial information to them.

13. Changes to This Privacy Policy

earnpho reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Where material changes are made, earnpho will notify registered Players by email to their registered address and/or by displaying a prominent notice on the earnpho platform.

The updated Privacy Policy will take effect from the date specified at the top of the document. Your continued use of the earnpho platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not accept the revised Privacy Policy, you must stop using the platform and may request Account closure.

We recommend that all Players review this Privacy Policy periodically to stay informed about how earnpho protects and uses your personal data.

14. Contact & Complaints

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

Data Protection Officer — earnpho
Email: [email protected]
Platform: https://earnpho.net

Please include your full name, registered Account username, and a clear description of your request or concern when contacting us. earnpho will acknowledge receipt of your request within five (5) business days and provide a full response within thirty (30) calendar days.

If you are not satisfied with earnpho's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which can be reached through its official channels as published on the NPC website.