4vipph Privacy Policy

1.1 Policy Purpose. This Privacy Policy explains how 4vipph collects, uses, discloses, stores, and protects your personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its implementing rules and regulations, and the directives of the National Privacy Commission (NPC).

1.2 Personal Data Controller. 4vipph acts as the personal data controller for all information collected through the Platform. We determine the purposes and means of processing your personal data and are responsible for ensuring compliance with the DPA.

1.3 Consent. By registering an account, depositing funds, or otherwise using 4vipph's services, you acknowledge that you have read this Privacy Policy and consent to the collection, processing, and storage of your personal data as described herein. If you do not agree, please do not use the Platform.

1.4 Relationship to Terms. This Privacy Policy should be read in conjunction with the 4vipph Terms & Conditions. In the event of conflict between the two documents concerning data privacy matters, this Privacy Policy shall prevail.

4vipph collects the following categories of personal data depending on how you interact with the Platform:

2.1 Registration Data. When you create an account, we collect:

• Full legal name (as it appears on government-issued identification);
• Date of birth (to verify age eligibility of 21 years or older);
• Residential address (street, barangay, city, province, postal code);
• Philippine mobile phone number;
• Email address;
• Username and password (password is stored in encrypted form).

2.2 Identity Verification Data. To comply with PAGCOR know-your-customer (KYC) and anti-money laundering (AML) regulations, we may request:

• Government-issued photo identification (e.g., Philippine Passport, Driver's License, UMID, SSS ID, Postal ID);
• Proof of address documents (utility bills, bank statements, government correspondence);
• Selfie or video verification for biometric matching;
• Source of funds documentation for large transactions.

2.3 Financial Data. When you deposit or withdraw funds, we collect:

• Payment method details (GCash mobile number, PayMaya account, bank account name and number);
• Transaction history (deposits, withdrawals, wagers, winnings);
• Payment processor confirmation numbers and timestamps.

2.4 Behavioral and Technical Data. When you use the Platform, we automatically collect:

• IP address and geolocation data;
• Device type, operating system, and browser version;
• Pages visited, time spent on pages, and navigation patterns;
• Game play history (games played, bet amounts, win/loss records);
• Login times, session duration, and device identifiers;
• Referral source (how you found 4vipph).

2.5 Communications Data. When you contact customer support or respond to marketing communications, we collect:

• Live chat transcripts and email correspondence;
• Phone call recordings (with prior notice and consent);
• Survey responses and feedback;
• Marketing preferences and opt-out requests.

2.6 Sensitive Personal Information. Under the DPA, certain data categories are considered sensitive. 4vipph may process the following sensitive personal information solely for the purposes and with the legal bases described in Section 4:

• Government-issued ID numbers (for identity verification);
• Biometric data (selfie images for facial recognition verification);
• Financial account details (to process transactions securely).

4vipph processes your personal data for the following purposes:

3.1 Account Creation and Management. To register your account, authenticate your identity, maintain your profile, and provide you with access to 4vipph's gaming and betting services.

3.2 Transaction Processing. To process deposits, withdrawals, wagers, and payouts through our licensed payment processors (GCash, PayMaya, BPI, BDO, Metrobank, and others).

3.3 Identity Verification and KYC. To verify that you are 21 years of age or older, confirm your identity, prevent duplicate accounts, and comply with PAGCOR's know-your-customer requirements.

3.4 Fraud Prevention and Security. To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, collusion, account hacking, and other violations of our Terms & Conditions. This includes monitoring gameplay patterns, transaction anomalies, and login behavior.

3.5 Regulatory Compliance. To comply with obligations imposed by PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine regulatory authorities. This may include reporting suspicious transactions and responding to lawful information requests.

3.6 Customer Support. To respond to your inquiries, resolve technical issues, process complaints, and provide assistance via live chat, email, or phone.

3.7 Marketing and Promotions. With your consent, to send you promotional offers, bonus announcements, VIP rewards updates, and newsletters via email, SMS, or push notifications. You may opt out of marketing communications at any time without affecting your ability to use essential Platform services.

3.8 Platform Improvement and Analytics. To analyze usage patterns, identify popular games, optimize website performance, conduct A/B testing, and develop new features. Aggregated, anonymized data may be used for statistical analysis and business intelligence.

3.9 Responsible Gaming. To monitor for signs of problem gambling, enforce deposit limits and self-exclusion requests, and provide information about responsible gaming resources in accordance with our Responsible Gaming Policy.

Under the Philippine Data Privacy Act, 4vipph processes your personal data on one or more of the following lawful bases:

4.1 Consent. You have explicitly consented to the processing of your personal data for specific purposes, such as receiving marketing communications or participating in surveys.

4.2 Contract Performance. Processing is necessary to fulfill our contractual obligations to you under the 4vipph Terms & Conditions, including account creation, transaction processing, and service delivery.

4.3 Legal Obligation. Processing is required to comply with Philippine laws and regulations, including PAGCOR licensing conditions, AML reporting requirements, tax obligations, and court orders.

4.4 Legitimate Interests. Processing is necessary for the legitimate interests of 4vipph, such as fraud prevention, network security, business analytics, and improvement of Platform services, provided that such interests do not override your fundamental rights and freedoms.

4.5 Vital Interests. In rare circumstances, processing may be necessary to protect your vital interests or those of another person, such as preventing imminent harm or responding to emergency situations.

4vipph may disclose your personal data to the following categories of recipients:

5.1 Payment Processors. GCash, PayMaya, BPI, BDO, Metrobank, and other licensed payment service providers require limited personal data (name, account number, transaction amount) to process your deposits and withdrawals securely.

5.2 Game Providers. Licensed third-party software providers (e.g., Evolution Gaming, Pragmatic Play, JILI, PG Soft) may receive pseudonymized player identifiers and gameplay data to deliver games, calculate RTP, and maintain game integrity.

5.3 Identity Verification Services. Specialized KYC and anti-fraud services may receive identity documents and biometric data to verify your age, identity, and address in compliance with PAGCOR regulations.

5.4 Regulatory Authorities. 4vipph is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies when legally obligated to do so. This includes suspicious transaction reports, player complaints, and responses to subpoenas or court orders.

5.5 Legal and Professional Advisors. Lawyers, accountants, auditors, and compliance consultants may access personal data on a need-to-know basis to provide professional services to 4vipph.

5.6 Business Transfers. In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal data may be transferred to the acquiring entity, subject to confidentiality obligations and compliance with the DPA.

5.7 Affiliates and Group Companies. 4vipph may share personal data with affiliated companies within the same corporate group for purposes of centralized data processing, consolidated reporting, or shared customer support services.

5.8 All third parties with whom 4vipph shares personal data are contractually required to implement appropriate technical and organizational security measures and to process data only for specified, lawful purposes.

6.1 What Are Cookies? Cookies are small text files stored on your device by your web browser. 4vipph uses cookies and similar technologies (web beacons, pixels, local storage) to recognize your device, remember your preferences, analyze traffic, and improve user experience.

6.2 Types of Cookies We Use:

• Essential Cookies: Required for Platform functionality, including login sessions, security features, and load balancing. These cannot be disabled without impairing the Platform.
• Performance Cookies: Collect anonymous data on how you use the Platform (pages visited, time on site) to help us optimize performance and fix bugs.
• Functional Cookies: Remember your language preference, currency selection, and other personalization settings.
• Marketing Cookies: Track your browsing behavior across websites to deliver targeted advertisements. These are set by third-party advertising networks with your consent.

6.3 Managing Cookies. You can control cookie settings through your browser preferences. Note that blocking essential cookies may prevent you from accessing certain Platform features. Most browsers allow you to delete cookies, block third-party cookies, or receive alerts before cookies are stored.

6.4 Do Not Track. 4vipph does not currently respond to "Do Not Track" browser signals, as there is no industry consensus on how to interpret such signals. You may control tracking through your browser's cookie settings.

7.1 Technical Safeguards. 4vipph implements industry-standard security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:

• SSL/TLS encryption (256-bit) for all data transmitted between your device and 4vipph servers;
• Encrypted storage of sensitive data, including passwords (using bcrypt or similar hashing algorithms);
• Firewalls, intrusion detection systems, and DDoS protection;
• Regular security audits and penetration testing by independent cybersecurity firms;
• Secure data centers with physical access controls, surveillance, and redundant backups.

7.2 Organizational Safeguards. 4vipph maintains strict internal policies governing data access:

• Access to personal data is restricted to authorized personnel on a need-to-know basis;
• Employees undergo background checks and sign confidentiality agreements;
• All staff receive regular data protection and cybersecurity training;
• Access logs are maintained and periodically reviewed for suspicious activity.

7.3 Data Breach Response. In the event of a personal data breach that poses a risk to your rights and freedoms, 4vipph will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by the DPA. Notifications will include the nature of the breach, affected data categories, and remedial actions taken.

7.4 Your Responsibility. You are responsible for maintaining the confidentiality of your login credentials. Do not share your password, enable two-factor authentication where available, and log out after each session. Report any suspected unauthorized access immediately via live chat or email [email protected].

8.1 Retention Periods. 4vipph retains your personal data only as long as necessary to fulfill the purposes described in this Policy or to comply with legal obligations:

• Active Account Data: Retained for the duration of your account's active status plus ninety (90) days after closure.
• Transaction Records: Retained for seven (7) years from the date of the transaction, as required by AMLC regulations and PAGCOR audit requirements.
• Identity Verification Documents: Retained for seven (7) years after account closure to comply with AML record-keeping obligations.
• Marketing Data: Retained until you withdraw consent or for three (3) years from your last interaction with 4vipph marketing communications, whichever is earlier.
• Support Communications: Retained for three (3) years to resolve disputes and improve customer service quality.

8.2 Automated Deletion. At the end of the applicable retention period, personal data is either securely deleted or anonymized such that it can no longer be associated with you as an individual.

8.3 Legal Holds. If your data is subject to a legal hold (e.g., ongoing investigation, litigation, regulatory inquiry), retention periods may be extended until the matter is resolved.

Under the Philippine Data Privacy Act, you have the following rights regarding your personal data:

9.1 Right to Be Informed. You have the right to be informed about the collection, use, and processing of your personal data. This Privacy Policy fulfills that obligation.

9.2 Right to Access. You may request a copy of all personal data 4vipph holds about you. To exercise this right, contact [email protected] with the subject line "Data Access Request." We will provide a structured export of your data within fifteen (15) business days.

9.3 Right to Rectification. If your personal data is inaccurate or incomplete, you may request corrections. You can update most account information directly through your account dashboard, or contact support for assistance.

9.4 Right to Erasure (Right to Be Forgotten). You may request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or when you withdraw consent. Note that 4vipph may be legally required to retain certain data for PAGCOR compliance and AML purposes.

9.5 Right to Object. You have the right to object to the processing of your personal data for direct marketing purposes at any time. Use the "Unsubscribe" link in marketing emails or adjust your communication preferences in your account settings.

9.6 Right to Data Portability. You may request that 4vipph transfer your personal data to another service provider in a structured, commonly used, machine-readable format, where technically feasible.

9.7 Right to Withdraw Consent. Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

9.8 Right to Lodge a Complaint. If you believe 4vipph has violated your data privacy rights, you may file a complaint with the Philippine National Privacy Commission (NPC). Contact details are available at privacy.gov.ph. You may also contact our Data Protection Officer at [email protected].

10.1 4vipph's services are intended exclusively for individuals aged twenty-one (21) years or older. We do not knowingly collect personal data from minors under the age of 21.

10.2 If we become aware that a person under 21 has provided personal data or registered an account, we will immediately close the account, delete all associated data, and refund any deposited funds (less any withdrawals already processed).

10.3 Parents or guardians who believe their child has provided personal data to 4vipph should contact [email protected] immediately.

11.1 4vipph may update this Privacy Policy periodically to reflect changes in our data practices, legal obligations, or business operations. The "Last Updated" date at the top of this document indicates the most recent revision.

11.2 Where changes are material — defined as modifications that significantly expand data collection, introduce new processing purposes, or affect your rights — 4vipph will notify you via email or prominent notice on the Platform at least seven (7) days before the changes take effect.

11.3 Continued use of the Platform after the effective date of an amended Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you must cease using the Platform and request account closure.

If you have questions, concerns, or requests regarding this Privacy Policy or 4vipph's data practices, please contact us:

• Email: [email protected] (General Inquiries) or [email protected] (Data Protection Officer)
• Live Chat: Available 24/7 through the 4vipph Platform
• Data Protection Officer: For formal data privacy complaints or requests to exercise your rights, contact our Data Protection Officer at [email protected]

We will respond to all data privacy inquiries within fifteen (15) business days. For complex requests requiring additional investigation, we may extend this period by an additional fifteen (15) days with notice.