Privacy Policy — vvjp Data Protection

This Privacy Policy ("Policy") is issued by vvjp ("vvjp," "we," "us," "our") and applies to all personal data collected, processed, stored, and shared in connection with your use of the vvjp website at https://vvjp.net and all associated services, games, and features (collectively, the "Platform").

vvjp is committed to protecting the privacy and personal data of all users of its Platform, with particular attention to the rights of Filipino players under the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

This Policy explains:

• What categories of personal data vvjp collects from you;
• The purposes for which vvjp collects and uses that data;
• The legal bases on which vvjp relies to process your data;
• How long vvjp retains your data;
• With whom vvjp may share your data;
• The security measures vvjp employs to protect your data;
• Your rights as a data subject under Philippine law and how to exercise them.

By registering for an account on the vvjp Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not register for or use the vvjp Platform.

This Policy applies to all registered players, visitors to the vvjp website, and any individual who contacts vvjp via support channels. It does not apply to third-party websites or services that may be linked from the Platform.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, vvjp acts as the personal information controller in respect of all personal data collected through the Platform.

If you have any questions, concerns, or requests relating to the processing of your personal data by vvjp, you may contact our Data Protection Officer (DPO) using the following details:

vvjp is registered with and operates under the oversight of PAGCOR (Philippine Amusement and Gaming Corporation) for gaming regulatory purposes, and complies with all applicable NPC directives for data privacy purposes.

vvjp collects the following categories of personal data, depending on how you interact with the Platform:

vvjp does not collect sensitive personal information beyond what is required for identity verification, except where you voluntarily provide it and where processing is justified under the Data Privacy Act.

vvjp collects personal data through the following means:

• Direct provision by you: When you register an account, complete KYC verification, make deposits or withdrawals, contact support, or participate in promotions, you directly provide personal data to vvjp.
• Automated collection: When you access and use the vvjp Platform, we automatically collect certain technical data through cookies, log files, pixel tags, and similar tracking technologies. This includes your IP address, device identifiers, browser type, session activity, and pages visited.
• Payment service providers: When you transact via GCash, Maya, BPI, BDO, Metrobank, or other supported payment channels, vvjp receives transaction confirmation data — including masked account identifiers and transaction amounts — from those providers to facilitate and reconcile your transactions.
• Third-party identity verification services: Where vvjp uses a third-party KYC verification provider to authenticate your identity documents, that provider may share the results of its verification check with vvjp.
• Fraud and AML screening providers: vvjp may receive risk indicators or screening results from anti-fraud and anti-money laundering service providers as part of its compliance obligations under Philippine law.

vvjp uses your personal data only for the following defined purposes:

• Account creation and management: To register and administer your vvjp player account, verify your identity at registration and through ongoing KYC processes, and manage your account preferences and settings.
• Processing of transactions: To process deposits, withdrawals, and bonus transactions accurately and securely, and to maintain complete financial records as required by PAGCOR and Philippine tax and AML regulations.
• Provision of gaming services: To deliver the games, features, and services available on the vvjp Platform, including slots, live dealer games, bingo, keno, and HRG Live.
• Responsible gaming compliance: To monitor gaming behaviour, enforce responsible gaming limits you have set, identify potential problem gambling indicators, and apply self-exclusion or cooling-off periods in accordance with PAGCOR responsible gaming standards.
• Legal and regulatory compliance: To meet vvjp's obligations under the Anti-Money Laundering Act (RA 9160 as amended), PAGCOR regulations, NPC directives, and other applicable Philippine laws — including filing of covered and suspicious transaction reports where required.
• Customer support: To respond to your inquiries, resolve disputes, process complaints, and provide technical assistance via live chat and email.
• Security and fraud prevention: To detect, investigate, and prevent fraud, account takeover, collusion, money laundering, and other prohibited activities that could affect the integrity of the Platform or harm other players.
• Platform improvement: To analyse aggregated usage data to improve the performance, features, and user experience of the vvjp Platform. This analysis uses anonymised or pseudonymised data wherever possible.
• Marketing communications: To send you promotional offers, bonus notifications, and news about new games or features — but only where you have expressly opted in to receive such communications. You may opt out at any time via your account settings or by contacting support.

vvjp will not use your personal data for any purpose that is incompatible with the purposes described above without first obtaining your explicit consent or establishing a separate legal basis for such processing.

Under the Data Privacy Act of 2012, vvjp relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing required to perform the contract between you and vvjp — specifically, the Terms and Conditions governing your player account and use of the Platform. This covers account registration, KYC, transaction processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with vvjp's obligations under Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and applicable NPC directives.
• Legitimate interests: Processing that is necessary for vvjp's legitimate business interests — including fraud prevention, security monitoring, responsible gaming enforcement, and platform analytics — where those interests are not overridden by your privacy rights.
• Consent: Where vvjp relies on your consent as the legal basis for processing — most notably for optional marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

vvjp does not sell, rent, or trade your personal data to any third party. vvjp may share your personal data only with the following categories of recipients, and only to the extent strictly necessary for the stated purpose:

• Payment service providers: GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other integrated Philippine payment processors, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party identity verification services used to authenticate your government-issued Philippine ID documents during the KYC process.
• Fraud prevention and AML screening providers: Services used to screen transactions and accounts for fraud indicators and AML compliance purposes.
• Gaming content providers: Game studios and content providers whose games are available on the vvjp Platform may receive pseudonymised player session data for the purpose of game delivery and technical support.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law, court order, or regulatory directive.
• Legal and professional advisers: Lawyers, auditors, and compliance consultants engaged by vvjp, who are bound by strict professional confidentiality obligations.

All third-party service providers with whom vvjp shares personal data are required to handle that data in accordance with the Data Privacy Act of 2012 and applicable NPC regulations, and are contractually prohibited from using it for any purpose beyond the specific service they provide to vvjp.

vvjp retains your personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law. The following general retention periods apply:

Upon expiry of the applicable retention period, vvjp will securely delete or anonymise your personal data so that it can no longer be associated with you as an identified individual. Where data is anonymised rather than deleted, the anonymised data may be retained for analytical purposes without restriction.

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

• Encryption in transit: All communications between your device and the vvjp Platform are encrypted using TLS 1.2 or higher (256-bit SSL), including all login, registration, and payment flows.
• Encryption at rest: Sensitive personal data — including KYC documents and financial account identifiers — is stored in encrypted form using AES-256 encryption.
• Access controls: Access to personal data within vvjp systems is restricted on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and undergo data privacy training.
• Multi-factor authentication: Administrative access to vvjp systems containing personal data requires multi-factor authentication (MFA).
• Intrusion detection and monitoring: vvjp's infrastructure is continuously monitored for security threats, and automated intrusion detection systems are in place to identify and respond to anomalous activity.
• Penetration testing: vvjp conducts periodic security assessments and penetration tests to identify and remediate vulnerabilities in its Platform.
• Incident response: vvjp maintains a documented data breach response plan, and is committed to notifying affected players and the NPC within the timeframes required by the Data Privacy Act in the event of a notifiable personal data breach.

While vvjp takes all reasonable precautions to protect your personal data, no internet-based system can be guaranteed to be 100% secure. You play an important role in your own data security by maintaining a strong, unique password for your vvjp account and enabling two-factor authentication where available.

The vvjp Platform uses cookies and similar tracking technologies to deliver and improve its services. A cookie is a small text file stored on your device when you visit a website. vvjp uses the following categories of cookies:

• Strictly necessary cookies: These are essential for the Platform to function correctly. They enable core features such as session management, login authentication, and security controls. These cookies cannot be disabled without rendering the Platform non-functional.
• Performance and analytics cookies: These cookies collect anonymised or pseudonymised data about how players use the Platform — including which pages are visited most frequently and where errors occur — to help vvjp improve the Platform experience. vvjp uses only first-party analytics tools for this purpose.
• Functionality cookies: These cookies remember your preferences — such as language settings and responsible gaming limit configurations — so you do not need to re-enter them each visit.
• Security cookies: Used to detect fraudulent login attempts, identify suspicious account activity, and support the Platform's fraud prevention controls.

vvjp does not use third-party advertising or retargeting cookies. On your first visit to the vvjp Platform, you will be presented with a cookie consent notice that allows you to accept or decline non-essential cookies. You may also manage your cookie preferences at any time via your browser settings, though disabling strictly necessary cookies may affect your ability to use the Platform.

As a data subject under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by vvjp:

• Right to be informed: The right to be informed of what personal data about you is being collected, how it will be used, and with whom it will be shared — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data that vvjp holds about you, along with information about how it is being processed.
• Right to correction: The right to request that vvjp correct any inaccurate, incomplete, or outdated personal data it holds about you.
• Right to erasure or blocking: The right to request that vvjp delete or block the processing of your personal data where it is no longer necessary for the purposes for which it was collected, subject to vvjp's legal retention obligations under PAGCOR regulations and the AMLA.
• 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. Where you object to marketing, vvjp will cease processing your data for that purpose immediately.
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that vvjp has violated your rights under the Data Privacy Act.

To exercise any of the above rights, please submit a written request to the vvjp Data Protection Officer at [email protected]. vvjp will respond to all valid data subject requests within 15 business days of receipt. In certain circumstances — for example, where a request is complex or where vvjp needs to verify your identity before fulfilling the request — this period may be extended, and vvjp will notify you accordingly.

vvjp reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC directives, PAGCOR regulations, or vvjp's data processing practices. Where amendments are material — meaning they substantially affect how your personal data is processed or your rights as a data subject — vvjp will provide advance notice via the registered email address or mobile number associated with your account, or via a prominent notice on the vvjp Platform, no less than 15 days prior to the changes taking effect.

The effective date at the top of this document reflects the date on which the current version of this Policy was last updated. The most current version of this Privacy Policy is always available on the vvjp website at https://vvjp.net/privacy-policy.

Your continued use of the vvjp Platform following the effective date of any amendment to this Policy constitutes your acknowledgment of and agreement to the revised Policy. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure by contacting vvjp support.

For all privacy-related inquiries, data subject requests, or concerns about how vvjp handles your personal data, please contact our Data Protection Officer at [email protected]. We are available 24/7 via live chat on the Platform and will respond to all email inquiries within 15 business days.