em88 Privacy Policy

01 About This Policy

This Privacy Policy applies to all personal data collected by em88 through the em88 website at em88.org, its mobile-optimized interface, customer support channels, and any other service or feature operated by em88. It applies to all registered players, prospective players, and visitors to the em88 platform regardless of location, including users accessing em88 from Metro Manila, Cebu, Davao, Quezon City, Makati, and other parts of the Philippines.

em88 acts as the data controller for the personal information you provide to us. This means we determine the purposes and means by which your personal data is processed. Where we engage third-party service providers to process data on our behalf, those providers act as data processors and are bound by contractual obligations to handle your data securely and only for the purposes we specify.

This Privacy Policy should be read together with our Terms & Conditions, which govern your use of the em88 platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

02 Personal Data We Collect

em88 collects only the personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

Category	Examples	Purpose
Identity Data	Full name, date of birth, nationality, government ID number	Account registration, KYC verification, age verification (21+)
Contact Data	Email address, Philippine mobile number, residential address	Account communication, OTP delivery, support correspondence
Financial Data	GCash number, PayMaya account, BPI/BDO/Metrobank account details, transaction history	Processing deposits and withdrawals in Philippine Peso (₱)
Technical Data	IP address, device type, browser type, operating system, session logs	Platform security, fraud detection, service optimization
Usage Data	Games played, wager amounts, session duration, bonus usage	Responsible gaming monitoring, personalization, analytics
Verification Data	Copies of government-issued ID, proof of address, selfie photos	KYC compliance, AML obligations, identity verification
Communications Data	Live chat transcripts, email correspondence, support ticket content	Customer support, dispute resolution, quality assurance

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required by law or for responsible gaming purposes (for example, if you voluntarily disclose a gambling-related health concern when requesting self-exclusion).

03 How We Collect Your Data

em88 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, contacting customer support, or participating in a promotion.
• Automated Technologies: Technical and usage data collected automatically when you access the em88 platform, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-Party Sources: Identity and fraud-check data received from KYC verification providers, payment processors (such as GCash and PayMaya), and fraud prevention services, where permitted by applicable law.
• Publicly Available Sources: In limited circumstances, we may verify information against publicly available records, such as government databases, where required for AML compliance.

04 How We Use Your Personal Data

em88 uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your em88 player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to em88 games, process your deposits and withdrawals in Philippine Peso, and deliver the features and functionality of the em88 platform.
• Legal & Regulatory Compliance: To fulfill our obligations under Philippine law, including KYC verification, AML reporting to the Anti-Money Laundering Council (AMLC), age verification (21+), and compliance with PAGCOR regulations.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the em88 platform.
• Responsible Gaming: To monitor gaming patterns, enforce responsible gaming limits you have set, and identify players who may be at risk of problem gambling so that appropriate support can be offered.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Communications: To send you transactional communications (such as deposit confirmations, withdrawal notifications, and security alerts) and, where you have consented, promotional communications about em88 offers and new games.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the performance, security, and user experience of the em88 platform.

05 Legal Basis for Processing

em88 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your em88 account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and PAGCOR compliance mandates.
• Legitimate Interests: Processing is necessary for em88's legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

06 Sharing Your Personal Data

em88 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 Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party providers engaged to verify your identity and age as required by Philippine law.
• Fraud Prevention & Security Services: Providers of fraud detection, cybersecurity, and risk management services that help protect the em88 platform and its players.
• Regulatory & Law Enforcement Authorities: The Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or court order.
• IT & Cloud Service Providers: Providers of hosting, data storage, and technical infrastructure services who process data on our behalf under strict data processing agreements.
• Professional Advisers: Lawyers, auditors, and other professional advisers who require access to your data in the course of providing services to em88, subject to professional confidentiality obligations.

Where em88 transfers personal data to third-party processors, we ensure that appropriate contractual safeguards are in place to protect your data and that processors are bound to use your data only for the purposes specified by em88.

07 Cookies & Tracking Technologies

em88 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit em88.org. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the operation of the em88 platform, including maintaining your login session, processing transactions, and ensuring platform security. These cookies cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymized data about how players use the em88 platform, helping us identify areas for improvement. These cookies are only set with your consent.
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming limits, to provide a more personalized experience.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats on the em88 platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the em88 platform. For strictly necessary cookies, no opt-out is available as they are essential to the operation of the service.

08 Data Retention

em88 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our general data retention periods are as follows:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• KYC & Verification Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by law or ongoing regulatory investigation.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of your consent history.

Upon expiry of the applicable retention period, em88 will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

09 Data Security

em88 implements robust technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the em88 platform is encrypted using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Sensitive personal data, including financial information and identity documents, is stored in encrypted form on secure servers.
• Access Controls: Access to personal data is restricted to em88 personnel and authorized third parties who have a legitimate need to access it, and is governed by role-based access control policies.
• Two-Factor Authentication: em88 supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security.
• Regular Security Audits: em88 conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the platform.
• Incident Response: em88 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, em88 will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

10 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by em88:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data em88 holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data em88 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 em88's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on em88's legitimate interests.
• Right to Data Portability: The right to receive a copy of 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 Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe em88 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 13 of this Privacy Policy. em88 will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with the requirements of the Data Privacy Act of 2012.

Please note that certain rights are subject to limitations. For example, em88 may be unable to delete your data where retention is required by law, or where deletion would prejudice ongoing legal proceedings or regulatory investigations.

11 Children & Minors

If you are a parent or guardian and believe that a minor has registered with em88 or provided personal data to em88 without your consent, please contact our support team immediately at the contact details provided in Section 13. em88 takes underage access extremely seriously and will act promptly upon receiving such a report.

12 Updates to This Privacy Policy

em88 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. When we make material changes to this Privacy Policy, we will notify registered players by email to the address on file and/or by displaying a prominent notice on the em88 platform prior to the changes taking effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent changes were made. We encourage you to review this Privacy Policy periodically to stay informed about how em88 protects your personal data. Your continued use of the em88 platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised policy.

13 Contact Us & Data Protection Officer

em88 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us through the following channels:

• Data Protection Officer: em88 Data Protection Office
• Email: privacy@em88.org
• General Support: support@em88.org
• Live Chat: Available 24/7 via the em88 platform — the fastest way to reach our team.

If you are not satisfied with em88's 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.