Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by gogoph ("gogoph," "we," "us," or "our"), the operator of the online gaming platform accessible at gogoph.app and its associated mobile applications (collectively, the "Platform"). This Policy describes how gogoph collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," or "Data Subject") who access or use the Platform.

gogoph is committed to protecting the privacy and personal data of all users in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering on or using the gogoph Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference.

2. Personal Data We Collect

gogoph collects the following categories of personal data from users of the Platform:

gogoph does not intentionally collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. Where sensitive personal information is collected — such as government-issued ID numbers — it is handled with heightened security measures and access controls.

3. How We Collect Your Data

gogoph collects personal data through the following means:

3.1 Direct Collection

We collect data that you provide directly when you register an account on gogoph, complete identity verification (KYC), make deposits or withdrawal requests, contact our customer support team, respond to surveys or promotions, or update your account profile settings.

3.2 Automated Collection

When you access and use the gogoph Platform, we automatically collect certain technical data through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser type, pages visited, session duration, and clickstream data. This automated collection helps us maintain platform security, detect fraudulent activity, and improve the overall user experience.

3.3 Third-Party Sources

gogoph may receive personal data about you from third-party sources, including: payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank (for transaction verification); identity verification service providers (for KYC processing); fraud detection and anti-money laundering screening services; and publicly available sources where permitted by applicable Philippine law.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your gogoph account, process your deposits and withdrawals, and deliver the gaming services you have requested.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering (AMLA) obligations, gaming regulatory requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for gogoph's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending you marketing communications or promotional offers — gogoph relies on your freely given, specific, and informed consent. You may withdraw this consent at any time by updating your communication preferences in your account settings or by contacting our support team.

5. How We Use Your Personal Data

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

• To create, verify, and manage your gogoph account, including age and identity verification in compliance with the 21+ age requirement applicable to casino-style gaming in the Philippines.
• To process deposits, withdrawals, and other financial transactions on the Platform, including verification of payment method ownership.
• To provide customer support and respond to your queries, complaints, and dispute submissions.
• To monitor gaming activity for responsible gaming purposes, including detecting signs of problem gambling and applying self-exclusion or account restrictions where appropriate.
• To detect, investigate, and prevent fraud, money laundering, cheating, and other prohibited conduct on the Platform.
• To comply with our legal and regulatory obligations under Philippine law, including reporting obligations to relevant authorities.
• To send you transactional communications, including deposit confirmations, withdrawal notifications, and security alerts.
• To send you promotional communications and personalized offers, where you have provided consent to receive such communications.
• To analyze Platform usage patterns and improve the functionality, performance, and content of the gogoph Platform.
• To enforce our Terms & Conditions and other applicable policies.

6. Data Sharing and Disclosure

6.1 Service Providers

gogoph shares personal data with carefully selected third-party service providers who assist us in operating the Platform. These include payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification providers, cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and cybersecurity service providers. All third-party service providers are contractually bound to process personal data only on gogoph's instructions and in accordance with applicable data protection law.

6.2 Game Content Providers

Certain games available on the gogoph Platform are provided by third-party game studios and content providers. These providers may receive limited technical data (such as session tokens and game round identifiers) necessary to deliver their games. They do not receive your full personal profile.

6.3 Regulatory and Law Enforcement Authorities

gogoph may disclose personal data to Philippine regulatory bodies, law enforcement agencies, courts, or other government authorities where required by applicable law, court order, or regulatory directive. This includes disclosures required under the Anti-Money Laundering Act (AMLA) and its amendments, and any applicable gaming regulatory requirements.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of gogoph's business, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy. gogoph will notify affected users of any such transfer via the Platform or by email.

6.5 No Sale of Personal Data

gogoph does not sell, rent, lease, or otherwise commercially exploit your personal data to third-party advertisers, data brokers, or marketing companies. Your data is not a product on gogoph.

7. Cookies and Tracking Technologies

The gogoph Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze Platform usage. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting core Platform functionality.
• Functional Cookies: Remember your preferences, such as language settings and display options, to provide a more personalized experience on gogoph.
• Analytics Cookies: Help us understand how users interact with the gogoph Platform — which pages are visited most, where users encounter issues, and how we can improve overall performance. Data collected is aggregated and anonymized where possible.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the gogoph Platform. Strictly necessary cookies cannot be disabled as they are essential to Platform operation.

8. Data Retention

gogoph retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active account relationship with gogoph, and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine anti-money laundering regulations.
• Gaming History: Retained for a minimum of three (3) years from the date of the relevant gaming session, for dispute resolution and regulatory compliance purposes.
• Customer Support Communications: Retained for three (3) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing Preferences and Consent Records: Retained for the duration of your account and for three (3) years following account closure or withdrawal of consent.

Upon expiry of the applicable retention period, gogoph will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

9. Data Security

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

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the gogoph Platform.
• Encryption of sensitive data at rest, including financial information and government ID data.
• Role-based access controls ensuring that gogoph personnel can only access personal data necessary for their specific job functions.
• Regular security assessments, penetration testing, and vulnerability scanning of 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.

While gogoph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, gogoph will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

10. Your Data Subject Rights

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

• Right to be Informed: The right to be informed of how your personal data is being collected and processed — which this Policy fulfills.
• Right of Access: The right to request a copy of the personal data gogoph holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data gogoph holds about you.
• 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 gogoph's legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on gogoph's legitimate interests.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe gogoph has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact gogoph's Data Protection Officer at [email protected]. gogoph will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11. Children's Privacy

The gogoph Platform is strictly intended for individuals who are at least 21 years of age, in accordance with the minimum legal age for participation in casino-style gambling activities in the Philippines. gogoph does not knowingly collect personal data from individuals under the age of 21.

If gogoph 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. If you believe that a minor has registered on the gogoph Platform, please contact us immediately at [email protected].

12. Cross-Border Data Transfers

gogoph primarily processes and stores personal data within the Philippines. However, certain third-party service providers engaged by gogoph — including cloud infrastructure providers and game content providers — may process personal data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, gogoph ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses that meet the standards required by the National Privacy Commission. gogoph will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without implementing appropriate safeguards.

13. Updates to This Privacy Policy

gogoph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

Where changes to this Policy are material, gogoph will provide reasonable advance notice to registered users via email or a prominent notice on the Platform. Your continued use of the gogoph Platform following the effective date of any amendment constitutes your acknowledgment of the updated Policy. We encourage you to review this Policy periodically to stay informed about how gogoph protects your personal data.

14. Contact Us & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or gogoph's personal data processing practices, please contact our Data Protection Officer:

Data Protection Officer — gogoph
Email: [email protected]

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

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

Please include your registered account username, a clear description of your concern, and any relevant supporting information when contacting us, to help us assist you as efficiently as possible.