23merryph Privacy Policy

23merryph ("we," "us," "the Platform") operates the online gaming website accessible at https://23merryph.club. We are the personal information controller responsible for the collection, use, and protection of your personal data in connection with your use of the 23merryph platform.

23merryph operates under Philippine gaming regulations and is committed to full compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

23merryph collects the following categories of personal data from registered Players and platform visitors:

We do not collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

23merryph collects your personal data through the following means:

• Direct Submission: Information you provide when registering an Account, completing KYC verification, making a deposit or withdrawal request, contacting support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the 23merryph platform, including through cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; payment confirmation data from GCash, Maya, and partner banks; fraud detection signals from security service providers.
• Publicly Available Sources: In limited circumstances, we may verify information against publicly available Philippine government databases for identity and age verification purposes.

23merryph processes your personal data for the following specific purposes:

• Account Registration & Management: To create and maintain your 23merryph Account, verify your identity, and manage your profile settings.
• Age & Identity Verification: To confirm that you are at least 21 years of age and legally eligible to participate in gaming activities on the platform, in compliance with Philippine law and PAGCOR regulations.
• Payment Processing: To process deposits and withdrawals via GCash, Maya, and partner bank transfers, and to maintain accurate financial records of all transactions.
• Gaming Services: To provide access to games, record game outcomes, calculate and credit winnings, and administer bonuses and promotions.
• Regulatory Compliance: To fulfill our obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012, including mandatory record-keeping and reporting.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct.
• Responsible Gaming: To monitor gaming patterns, identify potential problem gambling behavior, and administer self-exclusion and deposit limit tools in accordance with our Responsible Gaming Policy.
• Customer Support: To respond to your inquiries, resolve disputes, and improve the quality of our support services.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the features, performance, and security of the 23merryph platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided consent or where we have a legitimate interest, and always with an option to opt out.

Under the Data Privacy Act of 2012, 23merryph processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you accepted upon registration, including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA reporting requirements, and NPC registration obligations.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained. You may withdraw consent at any time by contacting support or adjusting your Account preferences.

23merryph does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, and Security Bank receive transaction data necessary to process your deposits and withdrawals.
• KYC & Identity Verification Providers: Licensed third-party verification services receive identity documents and biometric data solely for the purpose of confirming your eligibility to use the platform.
• Game Providers: Licensed game studios (such as Pragmatic Play, PG Soft, Jili Games, and Evolution Gaming) receive your account identifier and game session data to deliver gaming services. These providers do not receive your full identity or financial data.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities may receive data as required by law or upon lawful request.
• Fraud Prevention & Security Services: Specialized security providers receive technical and behavioral data to detect and prevent fraudulent activity on the platform.
• Professional Advisors: Legal counsel, auditors, and compliance consultants may access data on a confidential, need-to-know basis in connection with their professional services to 23merryph.

All third-party service providers engaged by 23merryph are contractually required to process your data only for the specified purpose, maintain appropriate security measures, and comply with the Data Privacy Act of 2012.

23merryph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account & Identity Data: Retained for a minimum of five (5) years from the date of Account closure, in compliance with PAGCOR record-keeping requirements and AMLA obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session for dispute resolution and regulatory audit purposes.
• Support Communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained for the duration of your Account and for two (2) years following Account closure or consent withdrawal.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized in a manner that prevents re-identification.

23merryph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and the 23merryph platform is encrypted using industry-standard TLS 1.3 protocols.
• Encrypted Data Storage: Sensitive personal and financial data stored on our servers is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Regular Security Audits: The 23merryph platform undergoes periodic penetration testing and security audits conducted by independent third-party security firms.
• Fraud Monitoring: Real-time automated systems monitor account activity for suspicious patterns and flag potential security incidents for immediate review.

While we take every reasonable precaution to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials and for notifying us immediately if you suspect unauthorized access to your Account.

23merryph uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how Players navigate the platform, which games are most popular, and where technical issues occur. This data is used solely for internal platform improvement.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may prevent you from accessing certain features of the 23merryph platform. 23merryph does not use third-party advertising cookies or behavioral tracking cookies for external advertising networks.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 23merryph:

• Right to Be Informed: The right to know what personal data we collect, how it is used, and with whom it is shared — as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most Account information directly through your Account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations under PAGCOR and AMLA requirements.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer via the live chat support channel inside your 23merryph Account. We will respond to all verified data subject requests within fifteen (15) business days of receipt.

The 23merryph platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated Account, delete the personal data in question, and return any deposited funds in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor has registered an Account on 23merryph, please contact our support team immediately via live chat so that we can take prompt corrective action.

In certain circumstances, your personal data may be transferred to and processed by service providers located outside the Republic of the Philippines — for example, where game providers or technical infrastructure providers operate servers in other jurisdictions.

Where such transfers occur, 23merryph ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual data processing agreements that impose data protection obligations equivalent to those required under RA 10173.
• Transfer only to jurisdictions that have been assessed as providing an adequate level of data protection.
• Implementation of technical security measures consistent with those described in Section 8 of this Policy.

By using the 23merryph platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject always to the protections outlined in this Privacy Policy.

23merryph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered Players via on-platform notification or email to the address on file at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how 23merryph protects your personal data. Your continued use of the platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

23merryph has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact us through the following channels:

• Live Chat Support: Available 24/7 inside your 23merryph Account dashboard. This is the fastest way to reach our DPO for data subject requests.
• Email: [email protected] (plain text — not a clickable link)

If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.