earph is committed to protecting the personal data of every Filipino player who uses our platform. This Privacy Policy explains what data earph collects, how it is used, how it is protected, and what rights you hold as a data subject under Philippine law.
earph does not sell your personal data to third parties. Your information is collected and processed solely to operate the earph platform, comply with Philippine regulatory requirements, and deliver a secure gaming experience to Filipino players. This policy explains that commitment in full.
This Privacy Policy ("Policy") describes the data practices of the earph online gaming platform operated at earph.club ("earph", "we", "us", "our"). It governs the collection, use, storage, disclosure, and protection of personal data provided by, or collected from, individuals ("Members", "you", "your") who register for, access, or use earph's services.
earph operates in the Republic of the Philippines and processes personal data in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and all applicable issuances of the National Privacy Commission ("NPC"). earph is also subject to the data-related requirements of the PAGCOR online gaming regulatory framework insofar as they relate to Member identity verification and record retention.
By completing registration on earph and accepting earph's Terms & Conditions, you confirm that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not consent to this Policy, you must not create an earph Account or use earph's services.
This Policy applies to all earph services, including the earph website at earph.club, all earph game categories (slots, live casino, bingo, Go Goal Bingo, Fisher Game), and all associated account management, payment processing, and customer support functions.
earph is the data controller in respect of personal data collected through the earph platform. As data controller, earph determines the purposes and means of processing your personal data, and bears responsibility under the DPA for the lawful and transparent handling of that data.
earph has appointed a Data Protection Officer ("DPO") responsible for overseeing earph's data protection compliance, responding to Member data rights requests, and acting as the point of contact for the National Privacy Commission. Members may contact earph's DPO using the contact details set out in Section 16 of this Policy.
earph collects the following categories of personal data in connection with the registration, operation, and ongoing management of your earph Account:
earph does not collect sensitive personal information as defined under Section 3(l) of the DPA — such as race, religion, health data, sexual orientation, or political affiliation — except where age and identity data collected during KYC overlaps with DPA categories by necessity. Such data is handled with heightened protection measures.
earph collects personal data through the following methods:
earph processes your personal data for the following specific, legitimate, and declared purposes:
| Purpose | Data Categories Used |
|---|---|
| Account registration and maintenance | Identity, contact, device data |
| Mandatory age and identity verification (KYC) | Identity data, KYC documents, selfie |
| Processing deposits and withdrawals | Financial data, identity data |
| Delivery of gaming services | Account, gameplay, device data |
| Fraud prevention and security monitoring | Device, login, financial, gameplay data |
| Anti-money laundering (AML) compliance | Identity, financial, transaction data |
| Responsible gaming management | Account, gameplay, responsible gaming settings |
| Customer support | Identity, account, support interaction records |
| Platform improvement and analytics | Aggregated, anonymised usage data |
| Regulatory reporting to PAGCOR and NPC | Identity, financial, transaction data |
| Marketing communications (where consent given) | Contact data, gameplay preferences |
earph does not process your personal data for any purpose beyond those listed above without first obtaining your explicit consent or as otherwise required by law. Where earph seeks to introduce a new processing purpose, this Policy will be updated in accordance with Section 15 and you will be notified accordingly.
Under the Data Privacy Act of 2012, earph relies on the following legal grounds for processing your personal data:
earph does not sell, rent, or trade your personal data to any third party for commercial purposes. earph shares personal data only in the following limited circumstances:
earph engages third-party service providers to assist in the delivery of the earph platform, including: KYC verification providers, payment gateway processors (GCash, PayMaya, and banking partners), cloud infrastructure providers, and game content providers. These parties act as data processors under earph's direction and are contractually bound to process your data only as instructed by earph, to implement adequate security measures, and not to use your data for their own independent purposes.
earph is legally required to share Member data with PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission ("NPC"), and other competent Philippine government authorities in response to lawful orders, regulatory inspections, and mandatory reporting obligations. earph will not notify you of such disclosures where doing so would be prohibited by law or would compromise an ongoing investigation.
Where earph has reasonable grounds to suspect fraudulent activity, money laundering, or other criminal conduct involving your Account, earph may share relevant data with financial institutions, law enforcement agencies, and industry fraud-prevention bodies to the extent necessary to protect earph, other Members, and the integrity of the Philippine online gaming ecosystem.
In the event of a merger, acquisition, restructuring, or sale of all or part of earph's business, your personal data may be transferred to the acquiring entity as part of the transaction. earph will provide reasonable advance notice of any such transfer and ensure that the acquiring entity is bound by data protection obligations consistent with this Policy.
earph will never share your personal data with advertisers, data brokers, or unrelated third-party businesses for their own marketing or commercial purposes. If you receive a communication purporting to be from earph that asks for personal information through an unfamiliar channel, treat it as suspicious and contact earph support immediately.
Some of earph's service providers — particularly cloud infrastructure providers and game content providers — may operate servers located outside of the Republic of the Philippines. Where personal data is transferred to recipients in countries outside the Philippines, earph ensures that adequate safeguards are in place to protect the data in transit and at the destination location, in accordance with NPC guidelines on cross-border data transfers.
Such safeguards may include: contractual data processing agreements incorporating standard contractual clauses approved by the NPC; adequacy assessments of the destination country's data protection regime; and technical security measures applied to data in transit and at rest.
By using earph's services, you acknowledge that your data may be processed in jurisdictions outside the Philippines for the purposes described in this Policy, subject always to the protections described in this Section.
earph retains your personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the minimum retention periods required by Philippine law and regulation. The following general retention guidelines apply:
On expiry of the applicable retention period, earph will securely delete or irreversibly anonymise your personal data, unless a further retention period is required by a subsequent legal obligation or ongoing legal proceedings.
earph uses cookies and similar tracking technologies on the earph platform for the following purposes:
earph does not use third-party advertising cookies or permit advertising networks to place tracking technologies on the earph platform. The cookies used by earph are operated solely by earph or by earph's direct service providers acting under earph's instruction.
You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from completing the earph login process and accessing your Account.
earph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, and unlawful disclosure. These measures include:
Notwithstanding these measures, no data transmission over the internet or data storage system is completely free from risk. earph cannot guarantee the absolute security of data transmitted to or from the earph platform. In the event of a personal data breach that is likely to result in a risk to your rights, earph will notify the National Privacy Commission and, where required, affected Members within the timeframes prescribed by the DPA and its IRR.
Under the Data Privacy Act of 2012, you hold the following rights in respect of personal data processed by earph. You may exercise these rights by contacting earph's Data Protection Officer using the details in Section 16:
You have the right to request a copy of the personal data earph holds about you, together with information about how it is processed, on what legal basis, and with whom it has been shared.
You have the right to request correction of inaccurate or incomplete personal data held on your earph Account. Where permitted, you may update certain data directly through your Account profile settings.
You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. This right is subject to earph's legal retention obligations under PAGCOR regulations and the AMLA, which may require certain data to be retained even after Account closure.
You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though earph may override such objection where compelling grounds exist.
Where processing is based on your consent or a contract, and processing is carried out by automated means, you may request that earph provide your personal data in a structured, commonly used, machine-readable format.
Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal. Withdrawal of consent for marketing purposes does not affect your ability to use earph's core services.
earph will respond to verified data rights requests within thirty (30) calendar days of receipt. Where requests are complex or numerous, earph may extend this period by a further thirty (30) days, with notification to you of the extension and the reasons for it. Requests that are manifestly unfounded or excessive may be declined, with written reasons provided.
earph strictly prohibits the registration and use of the platform by individuals under 21 years of age. If earph discovers that personal data has been collected from a person under 21, that Account will be closed immediately, all associated data will be deleted (subject to any mandatory regulatory retention requirements), and the incident will be reported to PAGCOR in accordance with earph's regulatory obligations.
If you are a parent or guardian and believe that a minor has registered an earph Account or that earph has unknowingly collected personal data of a minor, please contact earph's Data Protection Officer immediately using the contact details in Section 16. earph will investigate and act promptly.
The earph platform may display references to third-party game providers whose games are hosted within the earph interface. While earph selects its game provider partners carefully, earph is not responsible for the independent data practices of third-party game providers in respect of any data they collect directly from your device through their game software. earph recommends reviewing the privacy policies of individual game providers where this is a concern.
earph's Privacy Policy applies exclusively to data processing conducted by earph through the earph.club platform. It does not apply to any third-party website, service, or application that you access through links or references outside of earph's primary platform pages.
earph reserves the right to update this Privacy Policy at any time to reflect changes in earph's data practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. The current version of the Policy, bearing the Effective Date shown at the top of this page, constitutes the governing document.
Where changes are material — meaning they significantly alter your rights or earph's data handling practices in a way that may affect you — earph will provide at least seven (7) days' advance notice via email to your registered address and via a notice displayed prominently on the earph platform prior to the change taking effect. Continued use of earph following the effective date of a material update constitutes acceptance of the revised Policy.
Non-material amendments, such as corrections of typographical errors or clarifications that do not change the substantive effect of the Policy, may take effect immediately upon publication.
If you have questions about this Privacy Policy, wish to exercise a data subject right, or have a concern about earph's handling of your personal data, please contact earph's Data Protection Officer through the following channels:
earph acknowledges receipt of all data rights requests within three (3) business days and provides a substantive response within thirty (30) calendar days as described in Section 12.
If you are not satisfied with earph's response to your data rights request or privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC's complaint process is publicly available through official Philippine government channels.
earph serves Filipino players across all regions of the Philippines — from Manila, Quezon City, Makati, and Taguig in Metro Manila, to Cebu, Davao, Iloilo, Bacolod, and Cagayan de Oro in the Visayas and Mindanao. All privacy communications are handled in English. Response times reflect Philippine Standard Time (PST, UTC+8).
The earph Privacy Policy is built on six core commitments to every Filipino player on the platform.
earph does not sell, rent, or trade your personal data to any third party for commercial or advertising purposes. Your information exists on earph solely to operate your Account, process your payments, and maintain regulatory compliance — nothing else.
All data transmitted between your device and earph's servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest — including KYC documents and financial account details — is encrypted on earph's servers with access controls enforced at a staff level.
earph's data practices are designed to comply with the Philippine Data Privacy Act of 2012 (RA 10173) and the NPC's implementing rules. earph has a designated Data Protection Officer and processes your data only on the lawful bases described in this Policy.
Access, rectification, erasure, objection, portability — your DPA rights at earph are fully operational, not just listed. Submit a request to earph's DPO and receive a substantive response within 30 days. Requests are handled by real people, not automated deflection systems.
earph collects only the personal data that is genuinely required to operate your Account, verify your identity, process your transactions, and fulfil earph's legal obligations. Data collected for KYC is processed for verification purposes only and is not used for unrelated commercial activities.
earph only sends promotional communications to Members who have explicitly opted in. Every marketing message from earph includes a clear, functional opt-out mechanism. Withdrawing marketing consent takes effect immediately and has no impact on your access to earph's gaming services.
earph handles your personal information with the same care it brings to every part of the platform. Register your account, complete verification, and start playing — knowing your data is encrypted, protected, and never sold. Must be 21 or older.
🔞 21+ only | DPA 2012 compliant | KYC required | Gambling is for entertainment only. Play responsibly.