Privacy Policy

1. Introduction

Welcome to the 23merryph Privacy Policy. This document explains how 23merryph ("we," "us," "our," or "the Platform") collects, uses, stores, and protects the personal information of individuals ("you," "the User," or "the Player") who access or use the services available at 23merryph.net and any associated subdomains, mobile interfaces, or applications.

By registering an account on 23merryph, accessing the Platform, or using any of our services, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the Platform.

23merryph operates as an online gaming and casino platform serving players in the Philippines. We are committed to transparency in our data practices and to upholding the highest standards of data protection in compliance with Philippine law.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a 23merryph account, we collect the following personal information:

• Identity Information: Full legal name, date of birth, gender, and nationality;
• Contact Information: Email address, mobile phone number, and residential address;
• Account Credentials: Username and password (passwords are stored in encrypted form);
• Financial Information: Payment method details such as GCash account, PayMaya account, bank account numbers, and transaction history;
• Verification Documents: Government-issued ID (passport, driver's license, SSS/UMID card), proof of address (utility bills, bank statements), and proof of payment method ownership as required for Know Your Customer (KYC) compliance.

2.2 Information Collected Automatically

When you access or use the 23merryph platform, we automatically collect certain technical and usage information, including:

• Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers;
• Log Data: IP address, access times, pages viewed, time spent on pages, referring URLs, and clickstream data;
• Gaming Activity: Games played, wagers placed, winnings and losses, bonus usage, and session duration;
• Location Data: Approximate geographic location derived from your IP address to verify eligibility and comply with gaming regulations.

2.3 Information from Third Parties

23merryph may receive information about you from third-party service providers, including payment processors (GCash, PayMaya, banks), identity verification services, and fraud prevention partners. This information is used to verify your identity, process transactions, and protect against fraudulent activity.

3. How We Use Your Data

23merryph uses your personal information for the following purposes:

• Account Management: To create, maintain, and manage your 23merryph account, including authentication and customer support;
• Transaction Processing: To process deposits, withdrawals, and other financial transactions securely and efficiently;
• Regulatory Compliance: To verify your identity, age, and eligibility in compliance with Philippine gaming regulations and anti-money laundering laws;
• Service Improvement: To analyze usage patterns, improve Platform functionality, develop new features, and enhance user experience;
• Marketing Communications: To send you promotional offers, bonuses, newsletters, and updates about 23merryph services (you may opt out at any time);
• Security & Fraud Prevention: To detect, prevent, and investigate fraudulent activity, bonus abuse, collusion, and other violations of our Terms & Conditions;
• Legal Obligations: To comply with applicable laws, regulations, court orders, and requests from government authorities;
• Responsible Gaming: To monitor gaming behavior, identify problem gambling patterns, and enforce self-exclusion and deposit limits.

4. Data Sharing & Disclosure

4.1 When We Share Your Information

23merryph does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your information with the following categories of recipients:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other financial institutions to process deposits and withdrawals;
• Game Providers: Third-party game developers and software providers whose games are available on the Platform;
• Identity Verification Services: KYC and anti-fraud service providers to verify your identity and prevent fraudulent activity;
• Regulatory Authorities: Philippine gaming regulators, law enforcement agencies, and government bodies when required by law;
• Service Providers: Cloud hosting providers, customer support platforms, analytics tools, and other vendors who assist in operating the Platform;
• Legal & Professional Advisors: Lawyers, accountants, auditors, and consultants in connection with legal proceedings or regulatory compliance.

4.2 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. You will be notified via email or a prominent notice on the Platform before your information is transferred and becomes subject to a different privacy policy.

5. Cookies & Tracking Technologies

5.1 What Are Cookies?

Cookies are small text files stored on your device when you visit the 23merryph website. Cookies help us recognize your device, remember your preferences, and improve your browsing experience.

5.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly, including authentication and security features;
• Performance Cookies: Collect anonymous data about how visitors use the Platform to help us improve performance;
• Functional Cookies: Remember your preferences such as language, currency, and display settings;
• Marketing Cookies: Track your activity across websites to deliver personalized advertisements and measure campaign effectiveness.

5.3 Managing Cookies

You can control and delete cookies through your browser settings. However, disabling essential cookies may affect the functionality of the 23merryph platform. Most browsers allow you to refuse cookies or alert you when cookies are being sent.

6. Data Security

23merryph implements industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• 256-Bit SSL Encryption: All data transmitted between your device and our servers is encrypted using Secure Socket Layer (SSL) technology;
• Secure Data Storage: Personal information is stored on secure servers with restricted access and regular security audits;
• Password Protection: User passwords are hashed and encrypted using industry-standard algorithms;
• Access Controls: Only authorized 23merryph personnel with a legitimate business need can access personal data;
• Regular Security Testing: We conduct vulnerability assessments and penetration testing to identify and address security risks;
• Employee Training: All 23merryph staff receive training on data protection and security best practices.

7. Data Retention

23merryph retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by applicable law. Specific retention periods include:

• Active Accounts: Personal data is retained for the duration of your account's active status;
• Closed Accounts: After account closure, we retain certain information for up to seven (7) years to comply with Philippine anti-money laundering regulations, tax laws, and gaming regulations;
• Transaction Records: Financial transaction data is retained for a minimum of five (5) years as required by Philippine law;
• Marketing Data: If you opt out of marketing communications, your contact information is retained on a suppression list to ensure we do not contact you again;
• Legal Disputes: Information relevant to ongoing legal proceedings or regulatory investigations is retained until the matter is resolved.

After the applicable retention period expires, your personal information is securely deleted or anonymized so that it can no longer be associated with you.

8. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal information:

• Right to Access: You may request a copy of the personal data we hold about you;
• Right to Correction: You may request that we correct inaccurate or incomplete personal information;
• Right to Erasure: You may request deletion of your personal data, subject to legal retention requirements;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes;
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to Withdraw Consent: You may withdraw your consent to data processing at any time, though this may affect your ability to use 23merryph services;
• Right to Lodge a Complaint: You may file a complaint with the Philippine National Privacy Commission if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 12 of this Privacy Policy. We will respond to your request within a reasonable timeframe as required by Philippine law.

9. Children's Privacy

23merryph is an online gaming platform intended exclusively for individuals who are 21 years of age or older. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a person under 21, we will take immediate steps to delete that information and close the associated account.

Parents or guardians who believe that a minor has provided personal information to 23merryph should contact us immediately using the contact details provided in Section 12. We take the protection of minors seriously and will cooperate fully to resolve any such issues.

10. International Data Transfers

23merryph primarily operates within the Philippines and stores personal data on servers located in the Philippines or in secure data centers operated by reputable cloud service providers. In some cases, your personal information may be transferred to, stored, or processed in jurisdictions outside the Philippines where our service providers are located.

When we transfer personal data internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with Philippine data protection standards. These safeguards may include standard contractual clauses, data processing agreements, and verification that the recipient jurisdiction provides adequate data protection.

11. Changes to This Privacy Policy

23merryph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this Privacy Policy, we will notify you by:

• Posting a prominent notice on the 23merryph homepage;
• Sending an email notification to the address associated with your account;
• Displaying an in-platform notification when you next log in.

The revised Privacy Policy will take effect on the date specified in the notice. Your continued use of the 23merryph platform after the effective date constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how 23merryph handles your personal information, please contact our Data Protection Officer:

When contacting us regarding a privacy matter, please include your registered username, a detailed description of your request or concern, and any relevant supporting documentation. We will respond to all privacy inquiries within thirty (30) days as required by the Philippine Data Privacy Act.

If you are not satisfied with our response or believe that your privacy rights have been violated, you have the right to file a complaint with the National Privacy Commission of the Philippines.