Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how jewelph ("the Platform," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "the User," or "the Player") who access or use the jewelph website at jewelph.app and any associated mobile-optimised interfaces.

jewelph takes your privacy seriously. As a platform serving Filipino players, we are bound by the Philippine Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). We have appointed a Data Protection Officer (DPO) to oversee our compliance with these obligations.

By registering an account on jewelph, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the jewelph Platform.

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

2. Personal Data We Collect

jewelph collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

We do not collect sensitive personal information (as defined under RA 10173) unless it is strictly necessary for regulatory compliance, such as health information relevant to a responsible gaming assessment. Where such data is collected, we will seek your explicit consent.

3. How We Collect Your Data

jewelph collects personal data through the following means:

• Direct interactions: Data 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 Platform, including via cookies, web beacons, pixel tags, and server logs.
• Third-party sources: Identity verification and fraud-prevention data from licensed KYC service providers; payment data from GCash, Maya, and banking partners; analytics data from platform analytics tools operating under data processing agreements with jewelph.
• Publicly available sources: Information from government databases used to verify identity or screen against sanctions and politically exposed persons (PEP) lists, as required by Philippine anti-money laundering regulations.

4. Purpose & Legal Basis for Processing

jewelph processes your personal data only where a lawful basis exists under RA 10173. The table below sets out the primary purposes for which we process your data and the corresponding legal basis:

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time by updating your communication preferences in your account settings or by contacting our DPO. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

jewelph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• KYC and identity verification providers: Licensed third-party services that verify your identity documents and screen against sanctions lists and PEP databases.
• Payment processors and banking partners: GCash, Maya, BPI, BDO, UnionBank, Metrobank, and other payment partners necessary to process your deposits and withdrawals.
• Game content providers: Licensed game studios whose titles are available on the jewelph Platform. These providers may receive anonymised or pseudonymised session data for game integrity and fairness auditing purposes.
• IT infrastructure and cloud service providers: Hosting, database, and security service providers operating under strict data processing agreements that prohibit independent use of your data.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies, where disclosure is required by law or a valid legal order.
• Professional advisers: Lawyers, auditors, and accountants, subject to professional confidentiality obligations.

6. Cookies & Tracking Technologies

jewelph uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage patterns, and deliver a personalised experience. The types of cookies we use are:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled. They include session authentication tokens, security cookies, and load-balancing cookies.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming limits you have set.
• Analytics cookies: Collect anonymised data about how players use the Platform — which pages are visited most, where players drop off, and how features are used. This data helps us improve the Platform.
• Marketing cookies: Used only where you have consented, to deliver relevant promotional content and measure the effectiveness of our campaigns.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. A full Cookie Policy is available on request from our DPO.

7. Data Retention

jewelph retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with Philippine AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Gaming history: Retained for three (3) years from the date of each session, or longer where required for dispute resolution or regulatory purposes.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained for the duration of your consent and for one (1) year after withdrawal, as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

8. Data Security

jewelph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the jewelph Platform;
• Encryption of sensitive data at rest, including financial data and government ID information;
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent necessary for their role;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Multi-factor authentication (MFA) for staff accessing systems that process personal data;
• Incident response procedures, including notification to the National Privacy Commission and affected players within the timeframes prescribed by RA 10173 in the event of a personal data breach.

9. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jewelph. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13.

10. Children & Minors

If you are a parent or guardian and believe that a minor has registered on the jewelph Platform or provided us with personal data, please contact our DPO immediately using the contact details in Section 13. We will investigate and take appropriate action without delay.

11. Cross-Border Data Transfers

jewelph primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to a recipient located outside the Philippines — for example, to a game content provider or cloud infrastructure partner — jewelph ensures that such transfers are carried out in compliance with RA 10173 and NPC guidelines.

Specifically, jewelph will only transfer personal data internationally where:

• The recipient country has been assessed to provide an adequate level of data protection; or
• Appropriate safeguards are in place, such as standard contractual clauses approved by the NPC or binding corporate rules; or
• The transfer is necessary for the performance of a contract with you (e.g., processing a payment through an international payment network).

You may request details of the safeguards in place for any specific cross-border transfer by contacting our DPO.

12. Updates to This Privacy Policy

jewelph may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance. The date of the most recent revision is displayed at the top of this page.

Where a material change is made to this Policy, jewelph will notify registered players via email or an in-platform notification at least 14 days before the change takes effect. Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically. If you have any questions about a specific change, please contact our DPO before the effective date.

13. Contact & Data Protection Officer

jewelph has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and this Privacy Policy. If you wish to exercise any of your data privacy rights, have a question about this Policy, or wish to raise a data privacy concern, please contact our DPO:

Data Protection Officer — jewelph
Email: [email protected]

For general support enquiries unrelated to data privacy, please contact our customer support team:
Email: [email protected]

We will acknowledge your request within 72 hours and provide a substantive response within 15 business days, as required by the NPC's guidelines on data subject rights requests. Where a request is complex or involves a large volume of data, we may extend this period by a further 15 business days, in which case we will notify you of the extension and the reason for it.