Joliph Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how Joliph ("Joliph," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who access or use the Joliph online gaming platform, including the website at joliph.net and any associated mobile applications (collectively, the "Platform").

Joliph is committed to protecting the privacy and personal data of all players in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines ("NPC").

By registering a Joliph account or using the Platform in any way, 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 this Policy, please do not use the Joliph Platform.

This Policy should be read together with Joliph's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, Joliph acts as the Personal Information Controller in respect of the personal data it collects and processes in connection with the operation of the Platform.

Joliph is responsible for ensuring that personal data is processed lawfully, fairly, and transparently, and that appropriate technical and organizational measures are in place to protect personal data against unauthorized access, disclosure, alteration, or destruction.

Where Joliph engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and cloud infrastructure providers — those parties act as Personal Information Processors and are bound by data processing agreements that require them to handle personal data in accordance with this Policy and applicable Philippine law.

3. Personal Data We Collect

Joliph collects the following categories of personal data in connection with your use of the Platform:

Joliph does not intentionally collect sensitive personal information as defined under the DPA (such as health data, political opinions, or religious beliefs) unless specifically required for responsible gaming assessments or as mandated by applicable law.

4. How We Collect Your Data

Joliph collects personal data through the following means:

• Direct Collection: Information you provide when registering a Joliph account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 8 for more details on cookies.
• Third-Party Sources: Identity and fraud-check data received from KYC verification providers, payment processors such as GCash and BDO, and fraud prevention services, where you have authorized such sharing or where Joliph is required to conduct such checks by law.
• Publicly Available Sources: In limited circumstances, Joliph may verify information against publicly available records for compliance purposes.

5. How We Use Your Personal Data

Joliph uses the personal data it collects for the following purposes:

• To create, verify, and manage your Joliph player account, including processing your registration and maintaining your account profile.
• To verify your identity and age (21+) in compliance with Philippine gaming regulations and anti-money laundering requirements.
• To process deposits, withdrawals, and other financial transactions on the Platform, including fraud screening and chargeback management.
• To operate, maintain, and improve the Joliph Platform, including game delivery, technical support, and platform security.
• To administer bonuses, promotions, and loyalty programs in accordance with their applicable terms.
• To monitor gaming activity for responsible gaming purposes, including identifying players who may be exhibiting signs of problem gambling and applying self-exclusion or limit tools where appropriate.
• To communicate with you regarding your account, transactions, promotions, and updates to our policies.
• To comply with applicable Philippine laws and regulations, including the Data Privacy Act of 2012, Anti-Money Laundering Act, and PAGCOR regulatory requirements.
• To detect, investigate, and prevent fraud, cheating, collusion, and other prohibited conduct on the Platform.
• To resolve disputes and enforce Joliph's Terms & Conditions.
• To conduct internal analytics and research to understand how players use the Platform and to improve our services.

Joliph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

6. Legal Basis for Processing

Joliph processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or participating in optional surveys.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and Joliph — specifically, the Terms & Conditions governing your use of the Platform — including account management, payment processing, and game delivery.
• Legal Obligation: Where processing is required for Joliph to comply with a legal obligation under Philippine law, including KYC verification, anti-money laundering reporting, and regulatory record-keeping requirements.
• Legitimate Interests: Where processing is necessary for Joliph's legitimate interests, provided those interests are not overridden by your rights and freedoms. This includes fraud prevention, platform security, and internal analytics.

7. Sharing Your Personal Data

Joliph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Joliph 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: Financial institutions and e-wallet providers such as GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist Joliph in verifying player identities and complying with regulatory requirements.
• Game Providers: Software providers whose games are made available on the Joliph Platform, to the extent necessary for game delivery and technical support.
• Cloud and Infrastructure Providers: Hosting, storage, and technology service providers who process data on Joliph's behalf under binding data processing agreements.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

Where Joliph shares personal data with third-party processors, it ensures that appropriate contractual safeguards are in place to protect your data and that processors are bound to use your data only for the purposes specified by Joliph.

8. Cookies & Tracking Technologies

The Joliph Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and collect analytical data about Platform usage. The following types of cookies may be used:

• Essential Cookies: Strictly necessary for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytical Cookies: Used to collect aggregated, anonymized data about how players interact with the Platform, including pages visited, time spent, and features used. This data helps Joliph improve the Platform.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Joliph Platform. Joliph does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

9. Data Retention

Joliph retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account Data: Retained for the duration of your active Joliph account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and Log Data: Retained for up to twelve (12) months, unless required for longer periods for security investigations or legal proceedings.

When personal data is no longer required for any lawful purpose, Joliph will securely delete or anonymize it in accordance with its data disposal procedures.

10. Your Data Rights

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

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data Joliph holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update certain account information directly through your Joliph 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 Joliph's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data where Joliph relies on legitimate interests as the legal basis, or where your data is being used for direct marketing purposes.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that Joliph has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact Joliph's Data Protection Officer using the contact details in Section 15. Joliph will respond to all verified data rights requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11. Data Security

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

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Joliph Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls ensuring that only authorized Joliph personnel can access personal data, and only to the extent required for their specific job functions.
• Regular security assessments, vulnerability scanning, and penetration testing of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Joliph will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

While Joliph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You acknowledge and accept this inherent risk when using any online platform.

12. Children's Privacy

The Joliph Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. Joliph does not knowingly collect personal data from individuals under the age of 21.

If Joliph becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered a Joliph account, please contact our support team immediately so that we can investigate and take appropriate action.

Joliph's age verification procedures are designed to prevent underage access to the Platform. All players are required to submit government-issued identification confirming their date of birth before their account is fully activated.

13. Cross-Border Data Transfers

In the course of operating the Joliph Platform, personal data may be transferred to and processed in countries other than the Philippines — for example, where Joliph's cloud infrastructure providers or game software providers are located in other jurisdictions.

Where such transfers occur, Joliph ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to process personal data in accordance with standards equivalent to those required under the Data Privacy Act of 2012.

By using the Joliph Platform and accepting this Privacy Policy, you consent to the transfer of your personal data to other countries where Joliph's service providers operate, subject to the safeguards described above.

14. Changes to This Privacy Policy

Joliph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. The date of the most recent revision is indicated in the "Last Updated" notice at the top of this page.

When material changes are made to this Policy, Joliph will notify registered players by email or through a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable. For non-material changes, the updated Policy will be posted on this page with a revised "Last Updated" date.

Your continued use of the Joliph Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed of how Joliph protects your personal data.

15. Contact Us & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or Joliph's handling of your personal data, please contact our Data Protection Officer:

Data Protection Officer — Joliph
Email: [email protected]

For general support inquiries, you may also reach our customer support team at: [email protected]

If you are not satisfied with Joliph's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about how to file a complaint with the NPC is available on the NPC's official website.

For responsible gaming concerns, please visit our Responsible Gaming page. For information about your rights and obligations as a Joliph player, please review our Terms & Conditions.