garogem Privacy Policy

01 Who We Are

garogem ("garogem", "we", "us", "our") is a PAGCOR-regulated online gaming and sports betting platform accessible at garogem.app, serving Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and other areas throughout the Philippines. garogem operates as the data controller responsible for the personal information collected through the garogem website, mobile interface, and related services.

This Privacy Policy applies to all registered garogem account holders, visitors to garogem.app, and any individual whose personal data garogem processes in connection with the provision of its gaming services. It governs the collection, use, storage, sharing, and protection of personal data in accordance with Republic Act 10173 — the Data Privacy Act of 2012 — and its Implementing Rules and Regulations (IRR) issued by the National Privacy Commission (NPC).

02 Data We Collect

garogem collects personal data that is necessary for the lawful and effective delivery of its online gaming services, compliance with PAGCOR licensing obligations, and fulfilment of anti-money laundering (AML) requirements under Philippine law. The categories of personal data we collect include:

2.1 Account Registration Data

• Full legal name (as it appears on a government-issued Philippine ID)
• Date of birth (to verify the 21+ age requirement mandated by PAGCOR)
• Residential address (barangay, city/municipality, province)
• Valid Philippine mobile number
• Email address
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Scanned or photographed copies of government-issued IDs (PhilSys, Passport, LTO Driver's License, UMID, Voter's ID, PRC ID)
• Selfie photograph for liveness verification, where required
• Proof of address documents (utility bills, bank statements) where requested by the compliance team

2.3 Financial & Transaction Data

• GCash account name and mobile number
• Maya (PayMaya) account details
• BPI, BDO, or Metrobank account holder name and account number (partial, for verification)
• Deposit and withdrawal transaction history
• Bet history, game session records, and wagering activity

2.4 Technical & Device Data

• IP address and approximate geolocation at time of login
• Device type, operating system, and browser version
• Session timestamps and duration
• Cookie identifiers and similar tracking data (see Section 6)

2.5 Communications Data

• Live chat transcripts with garogem support agents
• Email correspondence sent to [email protected]
• Records of any dispute, complaint, or self-exclusion request submitted to garogem

03 How We Use Your Data

garogem processes your personal data for the following specific and legitimate purposes:

• Account Management: Creating, maintaining, and securing your garogem player account, including password recovery and two-factor authentication processes.
• Identity Verification (KYC): Confirming your identity, age (21+), and residential address in compliance with PAGCOR licensing requirements and Philippine AML laws.
• Payment Processing: Facilitating deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, InstaPay, and QR Ph payment channels.
• Game Delivery & Fairness: Operating slot games, live dealer tables, bingo, color prediction games, and sports betting markets in a fair and technically reliable manner.
• Fraud Prevention & Security: Detecting and investigating suspicious login activity, duplicate accounts, bonus abuse, money laundering patterns, and other prohibited conduct under our Terms and Conditions.
• Regulatory Reporting: Submitting required player activity reports, suspicious transaction reports (STRs), and covered transaction reports (CTRs) to PAGCOR and the Anti-Money Laundering Council (AMLC) as mandated by Philippine law.
• Responsible Gaming: Monitoring betting patterns to identify at-risk behaviour and enforcing self-exclusion, deposit limit, and cooling-off tools requested by players.
• Customer Support: Responding to account inquiries, payment disputes, technical issues, and complaints submitted via live chat or email.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve game performance, website usability, and customer service quality.
• Marketing Communications: Sending promotional offers, loyalty program updates, and event notifications — only to players who have opted in to receive such communications and have not subsequently opted out.

04 Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173) and its IRR, garogem processes personal data only where a valid legal basis exists. The applicable legal bases for garogem's data processing activities are:

• Consent: Where you have provided express consent at registration for specific processing activities, such as receiving marketing communications or sharing anonymised data for platform analytics.
• Contractual Necessity: Processing required to perform the services outlined in garogem's Terms and Conditions — including account creation, game access, and payment processing — that you have accepted as a registered player.
• Legal Obligation: Processing mandated by Philippine laws and regulations, including PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Cybercrime Prevention Act, and NPC regulations.
• Legitimate Interests: Processing necessary to protect garogem's legitimate interests in fraud prevention, platform security, and responsible gaming enforcement — provided such interests do not override your fundamental rights as a data subject.

05 Data Sharing & Disclosure

garogem does not sell, rent, or otherwise commercially transfer your personal data to any third party. Data sharing is strictly limited to the following categories of recipients, each of whom is bound by confidentiality obligations or data processing agreements with garogem:

5.1 Regulatory Authorities

garogem is required to share player identity data, transaction records, and activity reports with the Philippine Amusement and Gaming Corporation (PAGCOR) and the Anti-Money Laundering Council (AMLC) in accordance with applicable Philippine law. Disclosure to these bodies is mandatory and cannot be refused by garogem or the player.

5.2 Payment Processors

To facilitate deposits and withdrawals, garogem shares the minimum necessary transaction and identity data with licensed payment service providers operating in the Philippines, including GCash (Globe Fintech Innovations), Maya Philippines, and participating banks (BPI, BDO, Metrobank). These providers process data solely for payment settlement purposes.

5.3 Technology & Platform Service Providers

garogem engages third-party technology vendors for cloud hosting, game content delivery, KYC verification services, and customer support platform tools. These vendors access personal data only as necessary to deliver their contracted services and are prohibited from using garogem player data for their own marketing or commercial purposes.

5.4 Law Enforcement & Courts

garogem will disclose personal data to Philippine law enforcement agencies, courts, or other competent public authorities when required to do so by a lawful order, warrant, or binding legal process. garogem will notify the affected player of such disclosure where legally permitted to do so.

5.5 Corporate Transactions

In the event of a merger, acquisition, or sale of substantially all of garogem's assets, personal data held by garogem may be transferred to the acquiring entity, subject to the acquirer's commitment to maintain data protection standards at least equivalent to those set out in this Privacy Policy.

06 Cookies & Tracking Technologies

garogem uses cookies and similar browser-based tracking technologies to operate the platform, improve user experience, and understand how players interact with garogem.app. Cookies are small text files stored on your device when you visit a website.

Types of Cookies Used

• Essential Cookies: Required for core platform functionality — session authentication, login state, and security tokens. These cannot be disabled without breaking the platform.
• Performance Cookies: Collect anonymised data on page load times, game performance, and error rates to help garogem's technical team maintain platform stability.
• Functional Cookies: Remember your language preferences, last visited game category, and in-session display settings for a more personalised experience.
• Analytics Cookies: Aggregate, anonymised data used to understand player navigation patterns, popular game categories, and session duration — helping garogem improve content and UX.

You can manage or disable non-essential cookies at any time through your browser's settings or through the garogem cookie preference centre accessible from the platform footer. Note that disabling essential cookies will prevent proper login and platform access.

07 Data Retention

garogem retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law and PAGCOR licensing conditions.

• Active Account Data: Retained for the full duration of your account's active status plus a minimum of five (5) years after account closure, in line with PAGCOR record-keeping requirements.
• KYC / Identity Documents: Retained for a minimum of five (5) years from the date of submission, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as mandated under AMLA and BSP regulations applicable to payment service providers.
• Support & Communication Records: Retained for three (3) years from the date of last interaction for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained until you withdraw consent or close your account, plus one (1) year thereafter as proof of historical consent status.
• Technical & Log Data: Retained for up to twelve (12) months for security monitoring and fraud investigation purposes, then securely deleted.

When personal data is no longer required and the applicable retention period has expired, garogem will securely delete or anonymise the data so it can no longer be associated with an identifiable individual.

08 Data Security

garogem implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Key security measures include:

• TLS 1.2 / 1.3 encryption for all data transmitted between your device and garogem's servers
• AES-256 encryption for personal and financial data stored at rest in garogem's database infrastructure
• Two-factor authentication (2FA) available for all player accounts
• Role-based access controls limiting garogem employee access to personal data on a strict need-to-know basis
• Regular third-party penetration testing and security audits of the garogem platform
• Intrusion detection and anomaly monitoring systems operating 24/7
• Secure, access-logged storage of KYC documents with restricted retrieval permissions
• Employee data privacy training and confidentiality agreements for all garogem staff with access to personal data

In the event of a personal data breach that poses a real risk of serious harm to affected players, garogem will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals as required by NPC Circular 16-03 and subsequent NPC guidelines.

09 Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173), you — as a data subject — hold the following rights with respect to your personal data processed by garogem:

To exercise any of the rights listed above, submit a written request to garogem's Data Protection Officer at the contact details provided in Section 13 of this policy. garogem will verify your identity before processing any data subject rights request to prevent unauthorised access to another player's information.

10 Children & Minors

garogem's services are strictly intended for individuals who are twenty-one (21) years of age or older, in compliance with PAGCOR regulations governing online gambling in the Philippines. garogem does not knowingly collect personal data from individuals below the age of 21.

During the registration process, garogem requires all applicants to confirm their date of birth and submit a valid government-issued Philippine ID for age verification as part of the KYC process. Any account found to belong to a person under 21 years of age will be immediately suspended, and any deposited funds will be returned to the originating payment method after a compliance review.

If you are a parent or guardian and believe that a minor in your care has created a garogem account without your knowledge, please contact our support team immediately at [email protected]. garogem will investigate and take appropriate action, including account closure and data deletion where legally permissible.

11 Cross-Border Data Transfers

garogem's primary data processing infrastructure is located within the Philippines. However, some technology service providers engaged by garogem — including cloud infrastructure, game content platforms, and security monitoring tools — may process or store data in data centres located outside the Philippines.

Where personal data is transferred to processors in other countries, garogem ensures that appropriate safeguards are in place to maintain a level of data protection equivalent to that required under RA 10173. These safeguards include:

• Data Processing Agreements (DPAs) with all third-party processors containing NPC-compliant data protection clauses
• Contractual obligations requiring overseas processors to comply with Philippine data privacy standards
• Transfer impact assessments for transfers to jurisdictions without equivalent data protection laws

garogem will not transfer personal data to any jurisdiction or processor that cannot provide adequate guarantees of data security and privacy protection consistent with RA 10173 and NPC guidelines.

12 Updates to This Privacy Policy

garogem reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulations, or NPC guidelines. When material changes are made, garogem will notify registered players via email to their registered address and/or via a prominent notice displayed upon login to the garogem platform.

The revised Privacy Policy will be published at garogem.app/privacy-policy with an updated effective date. Your continued use of garogem following the effective date of any revised policy constitutes your acknowledgement of the updated terms. If you do not agree with material changes to this policy, you may close your account as described in garogem's Terms and Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how garogem protects your personal data. The current version will always be accessible via the link in the garogem website footer.

13 Contact & Data Protection Officer

garogem has appointed a Data Protection Officer (DPO) in compliance with Section 21 of RA 10173 and NPC Circular 16-01. The DPO is responsible for overseeing garogem's compliance with the Data Privacy Act and serves as the primary point of contact for all data privacy matters, including data subject rights requests and privacy complaints.

• Data Protection Officer: garogem DPO Office
• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 inside your garogem account dashboard
• Response Time: garogem aims to acknowledge all DPO inquiries within two (2) business days and provide a substantive response within fifteen (15) business days.
• Regulatory Authority: National Privacy Commission (NPC) of the Philippines

If you are not satisfied with garogem's response to your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines, which has jurisdiction over data privacy matters under RA 10173.