22merryph Privacy Policy – How We Protect Your Data

1 Scope of This Policy

This Privacy Policy applies to all personal data collected by or on behalf of 22merryph in connection with the operation of the platform at 22merryph.net and any related services, communications, and support interactions. It applies to all registered members and to individuals who access the platform without completing registration.

By registering an account or continuing to use the 22merryph platform following publication of this Policy, you acknowledge that you have read and understood how your data is handled. If you do not agree with any part of this Policy, you should not use the platform and may request account closure by contacting support.

This Policy should be read alongside the Terms and Conditions, which govern your use of the 22merryph platform more broadly. In the event of a conflict between the two documents regarding data privacy, this Privacy Policy governs.

2 Personal Data We Collect

The following table summarises the categories of personal data that 22merryph may collect and retain about registered members and platform visitors.

3 How We Collect Your Data

22merryph collects personal data through several channels. Understanding these helps you know when and how your information enters our systems.

Directly from you: The most significant data collection happens when you register an account, complete identity verification, make a deposit or withdrawal, contact support, or update your account settings. You provide this data voluntarily.

Automatically during platform use: When you access 22merryph on any device, the platform automatically records technical data including your IP address, device identifiers, browser type, session timestamps, and pages or games accessed. This happens through standard web server logging, cookies, and similar technologies. See Section 7 for full details on cookies.

From third-party service providers: Where you use a third-party payment method such as GCash or Maya, the payment provider may share transaction confirmation data with 22merryph to verify deposits and withdrawals. Similarly, identity verification providers used during KYC processes may return verification outcomes and flag data.

From public sources: In limited circumstances related to fraud prevention, compliance, or responsible gaming obligations, 22merryph may cross-reference information against publicly available registries or databases as permitted by applicable law.

4 Purpose of Data Processing

22merryph processes personal data for specific, documented purposes. Data is not used for any purpose beyond what is described here without first providing notice to affected members.

• Account management: Creating, maintaining, and operating your 22merryph account, including processing login authentication, account updates, and security verifications.
• Payment processing: Facilitating deposits, withdrawals, and transaction record-keeping in Philippine pesos. Verifying that payment accounts belong to the registered account holder.
• Identity verification (KYC): Confirming that registered members meet age and eligibility requirements and preventing fraudulent or duplicate account creation.
• Regulatory compliance: Meeting obligations under applicable anti-money laundering (AML), know-your-customer (KYC), and gaming regulation requirements.
• Platform improvement: Analysing aggregated, anonymised usage data to improve game performance, navigation, payment flows, and support response quality.
• Responsible gaming: Using behavioural data to identify patterns that may indicate problem gambling and to facilitate responsible gaming tool settings.
• Fraud prevention: Detecting unusual account activity, potential account takeovers, payment fraud, or collusion between members.
• Customer support: Resolving account queries, technical issues, payment questions, and complaints.
• Communications: Sending account-related notifications, security alerts, and where you have opted in, promotional updates about 22merryph offers.

5 Legal Basis for Processing

22merryph processes personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to fulfil the agreement between you and 22merryph when you register an account and use the platform — for example, processing deposits and withdrawals.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML, KYC, and gaming licensing requirements.
• Legitimate interests: Processing based on 22merryph's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights.
• Consent: Processing based on your explicit, freely given consent — primarily for optional marketing communications. You may withdraw consent at any time by contacting support or adjusting your notification preferences in your account settings.

6 Third-Party Data Sharing

22merryph does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. Data is shared with third parties only in the following circumstances and only to the extent necessary:

• Payment processors: GCash, Maya, GrabPay, Coins.ph, Visa, Mastercard, and bank transfer network operators receive transaction data necessary to process your payments. These providers operate under their own data protection frameworks and are not permitted to use your data for their own marketing purposes in connection with 22merryph transactions.
• Identity verification providers: Third-party KYC service providers receive identity documents and related data for the purpose of verifying your identity. Results are returned to 22merryph and documents are handled according to the provider's certified security standards.
• Regulatory and law enforcement bodies: Where required by applicable law, court order, or a lawful request from a regulatory authority, 22merryph may disclose personal data. Such disclosures are made only to the extent required by the specific legal obligation.
• Technology and infrastructure providers: Cloud hosting, analytics, and customer support platform providers may have access to data as part of the technical operation of the platform. All such providers are bound by data processing agreements requiring them to handle data only as instructed and to implement appropriate security measures.
• Responsible gaming bodies: In cases where a self-exclusion request is processed or where referral to external support resources is relevant, limited information may be shared as required by applicable responsible gaming obligations.

7 Cookies and Tracking Technologies

22merryph uses cookies and similar technologies on the platform. A cookie is a small text file placed on your device when you visit a website. Cookies allow the platform to recognise your device across sessions and personalise your experience.

The types of cookies used by 22merryph include:

• Essential cookies: Required for the platform to function. These include session authentication cookies that keep you logged in during an active session and security tokens that protect against cross-site request forgery. You cannot opt out of essential cookies without stopping use of the platform.
• Functional cookies: Remember your preferences such as language settings, game lobby layout choices, and responsible gaming reminder settings. These improve your experience but are not strictly necessary.
• Analytics cookies: Collect aggregated, anonymised data about how members use the platform — which pages are visited most frequently, where users encounter errors, and how navigation flows. This data is used to improve the platform.
• Security and fraud-prevention cookies: Track device fingerprints and session behaviour to detect suspicious activity such as account takeover attempts or unusual betting patterns.

You can manage cookie preferences through your browser settings. Note that disabling functional or analytics cookies may affect your experience on 22merryph but will not prevent you from using core platform features.

8 Data Retention

22merryph retains personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, accounting, and regulatory obligations. The retention periods applied depend on the category of data and the applicable legal requirements.

• Account and identity data: Retained for the duration of the active account relationship and for a minimum period after account closure as required by applicable KYC and AML regulations. This period is typically five to seven years following the last transaction.
• Transaction records: Financial transaction records are retained for the legally required period for accounting and AML reporting purposes.
• Support communications: Retained for a period sufficient to resolve any related dispute and to improve service quality, generally up to three years.
• Behavioural and session data: Typically retained in aggregated form for platform analytics. Identifiable session logs are retained for shorter periods unless flagged during fraud or compliance review.
• Marketing consent records: Retained for the duration of the consent period and for sufficient time afterwards to demonstrate that consent was properly obtained.

When personal data is no longer required for its stated purpose and no legal obligation requires further retention, 22merryph will securely delete or anonymise that data.

9 Security Measures

22merryph takes the security of your personal data seriously and implements technical and organisational measures appropriate to the risk level of the data held. These include:

• SSL/TLS encryption for all data transmitted between your device and the 22merryph platform.
• Encrypted storage for sensitive personal and financial data at rest.
• Access controls ensuring that only authorised staff can access personal data, and only to the extent required for their specific role.
• Multi-factor authentication options for member accounts to reduce the risk of unauthorised access.
• Regular security reviews and vulnerability assessments of platform infrastructure.
• Incident response procedures to detect, contain, and report data security breaches in accordance with applicable obligations.

10 Your Data Rights

As a 22merryph member, you have the following rights regarding your personal data under applicable data protection law. To exercise any of these rights, contact support@22merryph.net with your registered details and a description of your request.

22merryph will respond to data rights requests within a reasonable timeframe as required by applicable law. In most cases this means within 30 days of receiving a properly submitted request. Where a request is refused, 22merryph will explain the reason and the member's right to escalate the matter.

11 Protection of Minors

The 22merryph platform is strictly for adult use only. 22merryph does not knowingly collect personal data from individuals below the minimum age requirement. Where it is discovered that a minor has registered an account, that account will be immediately closed, all transactions voided, and any data collected deleted in accordance with applicable law.

If you are a parent or guardian and believe a minor has registered an account using your or their own details, contact support@22merryph.net immediately. Please include as much identifying information as possible to allow the account to be located and actioned promptly.

Members are also responsible for ensuring that their 22merryph account is not accessible to minors in their household. If you are concerned about gaming access in your home, review the settings and tools available on the Responsible Gaming page.

12 Changes to This Privacy Policy

22merryph may update this Privacy Policy from time to time to reflect changes in data processing practices, legal obligations, or the scope of platform services. When material changes are made, registered members will be notified through the platform, via email, or through both channels.

The date of the most recent revision is displayed at the top of this page. Continued use of the 22merryph platform following notification of any update constitutes acceptance of the revised Privacy Policy. If you have concerns about a change, contact support@22merryph.net before continuing to use the platform.

Archived versions of previous Privacy Policy versions are available on request from support.

13 Contact and Data Enquiries

For any questions, requests, or concerns related to this Privacy Policy or the handling of your personal data by 22merryph, please contact:

• Email: support@22merryph.net
• Subject line suggested: Privacy Request – [Your Registered Email]
• Expected response time: Within 30 days for formal data rights requests; within 5 business days for general enquiries

When submitting a data rights request, include your registered email address, the nature of your request, and any supporting detail that will help locate your records quickly. 22merryph may need to verify your identity before processing the request to protect against unauthorised access to another person's data.

For general questions about using the platform, account management, or responsible gaming tools, the FAQ page and the Responsible Gaming page are also helpful starting points.