Privacy Policy

01 Introduction

mvpph is an online gaming and sports betting platform serving Filipino players across the Philippines, from Manila and Makati to Cebu, Davao, and Quezon City. We are committed to protecting the privacy and security of every player who entrusts us with their personal information.

This Policy applies to all personal data collected by mvpph in connection with the operation of the platform, including data collected during account registration, identity verification, payment processing, gameplay, customer support interactions, and marketing communications. It applies regardless of whether you access the platform via desktop browser or the mvpph mobile application.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of any conflict between this Policy and the Terms & Conditions with respect to data privacy matters, this Policy shall prevail.

mvpph processes personal data in accordance with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as well as the regulatory requirements of the Philippine Amusement and Gaming Corporation (PAGCOR).

02 Data Controller

For the purposes of applicable data protection law, mvpph is the data controller responsible for your personal data collected through the mvpph platform. As data controller, mvpph determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

If you have any questions or concerns about how mvpph processes your personal data, or if you wish to exercise any of your data subject rights as described in Section 10 of this Policy, please contact our Data Privacy Officer using the contact details provided in Section 14.

03 Personal Data We Collect

mvpph collects the following categories of personal data in connection with the operation of the platform:

3.1 Identity and Registration Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Gender
• Nationality
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license, SSS/GSIS number)
• Username and encrypted password

3.2 Contact Data

• Residential address (including barangay, city/municipality, province)
• Email address
• Mobile phone number

3.3 Financial and Payment Data

• GCash account number or registered mobile number
• PayMaya account details
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks)
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Account balance information

3.4 Gaming and Betting Activity Data

• Game history, including games played, bets placed, and outcomes
• Wagering amounts and frequency
• Session duration and login timestamps
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status)

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Unique device identifiers
• Cookie data and session identifiers (see Section 11)

3.6 Communications Data

• Records of customer support interactions, including chat logs and email correspondence
• Feedback, complaints, and dispute records
• Marketing communication preferences

04 How We Collect Your Data

mvpph collects personal data through the following means:

• Directly from you — when you register an account, complete the KYC verification process, make a deposit or withdrawal, contact customer support, or update your account settings.
• Automatically — when you use the mvpph platform, our systems automatically collect technical and device data, including your IP address, device identifiers, and session activity, through cookies and similar tracking technologies.
• From third-party payment providers — when you make a deposit or withdrawal using GCash, PayMaya, BPI, BDO, or Metrobank, we receive transaction confirmation data from those providers to verify and process your payment.
• From identity verification services — mvpph may use third-party KYC and identity verification services to verify the authenticity of documents you submit. These services may return verification results and risk scores to mvpph.
• From regulatory authorities — PAGCOR and other regulatory bodies may share information with mvpph in connection with compliance obligations, including self-exclusion registers.

05 How We Use Your Personal Data

mvpph uses the personal data we collect for the following purposes:

mvpph does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

06 Legal Basis for Processing

mvpph processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing is necessary to perform the contract between you and mvpph — specifically, to provide you with access to the platform, process your transactions, and manage your account.
• Legal obligation: Processing is necessary to comply with mvpph's legal and regulatory obligations, including PAGCOR licensing requirements, anti-money laundering (AML) obligations, and KYC requirements.
• Legitimate interests: Processing is necessary for mvpph's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and improving the quality of our services, provided those interests are not overridden by your rights and interests.
• Consent: Where mvpph relies on your consent as the legal basis for processing — for example, for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Sharing Your Personal Data

mvpph does not sell your personal data to third parties. We 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 service providers — GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, for the purpose of processing your deposits and withdrawals.
• Identity verification providers — Third-party KYC service providers engaged by mvpph to verify the identity and age of registered players.
• Regulatory authorities — PAGCOR and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• Law enforcement agencies — Where mvpph is legally required to disclose information in connection with the investigation or prosecution of criminal activity, including fraud and money laundering.
• Technology and infrastructure providers — Cloud hosting providers, cybersecurity vendors, and other technology partners who process data on mvpph's behalf under strict data processing agreements.
• Professional advisors — Legal counsel, auditors, and compliance consultants, where necessary for the conduct of mvpph's business.

All third parties with whom mvpph shares personal data are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with mvpph's instructions and applicable law.

08 Data Retention

mvpph retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general guide, mvpph applies the following retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR requirements and AML obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Gaming activity data: Retained for a minimum of three (3) years from the date of the activity.
• Customer support records: Retained for three (3) years from the date of the interaction, or longer if the interaction relates to an unresolved dispute or regulatory matter.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

When personal data is no longer required for any of the above purposes, mvpph will securely delete or anonymize it in accordance with our data disposal procedures.

09 Security Measures

mvpph takes the security of your personal data seriously. We implement a range of technical and organizational measures designed to protect your data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the mvpph platform.
• Encryption at rest for sensitive personal data stored on mvpph's servers, including government ID documents and financial data.
• Access controls limiting access to personal data to authorized mvpph personnel on a strict need-to-know basis.
• Multi-factor authentication for internal systems that process personal data.
• Regular security audits and penetration testing of the mvpph platform and infrastructure.
• Incident response procedures to detect, investigate, and respond to data security incidents promptly.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights with respect to your personal data held by mvpph:

These rights are described in more detail below:

• Right to Access: You have the right to request a copy of the personal data mvpph holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request that mvpph correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to mvpph's legal and regulatory retention obligations.
• Right to Object: You have the right to object to the processing of your personal data where mvpph relies on legitimate interests as the legal basis for processing.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact our Data Privacy Officer using the details in Section 14. mvpph will respond to all valid requests within thirty (30) days. In complex cases, this period may be extended by a further thirty (30) days, with prior notice to you.

If you are not satisfied with mvpph's response to your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Cookies and Tracking Technologies

mvpph uses cookies and similar tracking technologies on the mvpph website and application. Cookies are small text files placed on your device that help us recognize you, remember your preferences, and improve your experience on the platform.

mvpph uses the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the operation of the mvpph platform. They enable core functions such as account login, session management, and security. These cookies cannot be disabled.
• Functional cookies: These cookies allow the platform to remember your preferences, such as your preferred language and display settings, to provide a more personalized experience.
• Analytics cookies: These cookies collect aggregated, anonymized information about how players use the mvpph platform, helping us understand which features are most popular and where improvements can be made.
• Security cookies: These cookies help mvpph detect and prevent fraudulent activity, including unauthorized account access and suspicious betting patterns.

You can manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of the mvpph platform. Strictly necessary cookies cannot be disabled as they are required for the platform to function.

12 Minors and Age Restriction

If mvpph becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be returned to the payment source, subject to verification.

If you are a parent or guardian and believe that your child has registered an account on mvpph, please contact our support team immediately using the details in Section 14. We will investigate and take appropriate action promptly.

13 Changes to This Privacy Policy

mvpph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email to their registered email address and/or by posting a prominent notice on the mvpph platform prior to the changes taking effect.

The date of the most recent revision to this Policy is indicated at the top of this page. We encourage you to review this Policy periodically to stay informed about how mvpph protects your personal data. Your continued use of the mvpph platform following the publication of an updated Policy constitutes your acceptance of the changes.

14 Contact Our Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by mvpph, please contact our Data Privacy Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.