treasureph Privacy Policy

01 Introduction

treasureph ("we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who use the treasureph platform, accessible at treasureph.app. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal data.

This policy applies to all players, registered users, and visitors of the treasureph platform, including the website and any associated mobile applications. It should be read together with our Terms & Conditions and Responsible Gaming Policy.

By registering an account or using the treasureph 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.

02 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), treasureph is the personal information controller responsible for your personal data collected through the treasureph platform.

Our designated Data Protection Officer (DPO) can be contacted at [email protected] for any privacy-related inquiries, requests, or complaints.

03 Personal Data We Collect

3.1 Registration and Account Data

When you create a treasureph account, we collect the following information:

• Full legal name;
• Date of birth (to verify you are 21 years of age or older);
• Residential address (including city, province, and postal code);
• Email address;
• Mobile phone number;
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and the Anti-Money Laundering Act (Republic Act No. 9160), we collect:

• Government-issued ID (e.g., Philippine passport, SSS/UMID card, PhilSys National ID, driver's license);
• Proof of address documents;
• Selfie or facial verification image (where required);
• Proof of payment method ownership.

3.3 Financial Data

We collect transaction data necessary to process deposits and withdrawals, including GCash account references, PayMaya wallet details, and bank account information (BPI, BDO, Metrobank, UnionBank). We do not store full payment card numbers on our servers.

3.4 Gaming Activity Data

We record your gaming history, including games played, wagers placed, wins and losses, session durations, and bonus usage. This data is used for account management, responsible gaming monitoring, and regulatory reporting.

3.5 Technical and Device Data

We automatically collect certain technical data when you access the platform, including IP address, browser type and version, device type and operating system, referring URLs, and session timestamps.

04 How We Collect Your Data

treasureph collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions;
• Automatically — through cookies, web beacons, and similar tracking technologies when you browse or use the treasureph platform;
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO), and fraud prevention partners, where necessary to verify your identity or process transactions;
• From regulatory bodies — PAGCOR and the Anti-Money Laundering Council (AMLC) may share information with us as part of our licensing and compliance obligations.

05 How We Use Your Personal Data

treasureph uses your personal data for the following purposes:

• To create and manage your treasureph account;
• To verify your identity and age (21+) in compliance with PAGCOR requirements;
• To process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers;
• To detect and prevent fraud, money laundering, and other illegal activities;
• To comply with our legal and regulatory obligations under Philippine law, including reporting to PAGCOR and the AMLC;
• To provide customer support and respond to your inquiries;
• To send you account-related notifications, security alerts, and service updates;
• To send you marketing communications about treasureph promotions and offers, where you have consented to receive them;
• To monitor gaming activity for responsible gaming purposes and to enforce self-exclusion requests;
• To analyze platform usage and improve the treasureph gaming experience;
• To resolve disputes and enforce our Terms & Conditions.

06 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, treasureph processes your personal data on the following legal bases:

• Contractual necessity — processing required to fulfill our obligations under the Terms & Conditions you agreed to when registering your account;
• Legal obligation — processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws;
• Legitimate interests — processing necessary for fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights;
• Consent — processing for marketing communications and optional features, where you have given explicit consent. You may withdraw consent at any time.

07 Data Sharing and Disclosure

treasureph does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only where necessary and lawful:

7.1 Regulatory Authorities

We are required by law to share certain data with PAGCOR, the AMLC, the National Privacy Commission (NPC), and other Philippine government agencies upon lawful request or as part of our licensing obligations.

7.2 Service Providers

We engage trusted third-party service providers to assist in operating the treasureph platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, and customer support platforms. These providers are bound by strict data processing agreements and may only use your data for the specific purpose for which it was shared.

7.3 Game Software Providers

Certain game providers may receive limited technical data (such as player session tokens) necessary to deliver their games on the treasureph platform. No personally identifiable information beyond what is technically required is shared with game providers.

7.4 Law Enforcement

We may disclose personal data to law enforcement agencies, courts, or other authorities where required by law, court order, or to protect the rights, property, or safety of treasureph, its players, or the public.

08 Data Retention

treasureph retains your personal data for as long as your account is active and for a period thereafter as required by law. Specifically:

• Account and KYC data — retained for a minimum of five (5) years after account closure, as required by PAGCOR and anti-money laundering regulations;
• Transaction records — retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act;
• Gaming activity logs — retained for three (3) years for responsible gaming monitoring and dispute resolution purposes;
• Marketing consent records — retained until you withdraw consent, plus one (1) year thereafter for compliance documentation;
• Technical logs — retained for up to twelve (12) months for security and fraud detection purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines.

09 Cookies and Tracking Technologies

The treasureph platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze platform usage. The types of cookies we use include:

• Essential cookies — required for the platform to function, including session management and security tokens. These cannot be disabled;
• Analytics cookies — used to understand how players interact with the platform, helping us improve performance and usability;
• Preference cookies — used to remember your settings and preferences, such as language and display options;
• Marketing cookies — used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies may affect the functionality of the treasureph platform.

10 Data Security

treasureph implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit;
• AES-256 encryption for sensitive data at rest;
• Multi-factor authentication for account access;
• Regular security audits and penetration testing;
• Strict access controls limiting data access to authorized personnel only;
• Secure data centers with physical access controls.

While we take all reasonable steps to protect your data, no system is completely immune to security risks. In the event of a data breach that is likely to result in a risk to your rights and freedoms, treasureph will notify you and the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, as required by the Data Privacy Act.

11 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 treasureph:

• Right to be informed — you have the right to know what personal data we collect and how it is used;
• Right of access — you may request a copy of the personal data we hold about you;
• Right to rectification — you may request correction of inaccurate or incomplete personal data;
• Right to erasure — you may request deletion of your personal data, subject to our legal retention obligations;
• Right to object — you may object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability — you may request your personal data in a structured, commonly used format;
• Right to lodge a complaint — you have the right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

12 Children's Privacy

The treasureph platform is strictly for individuals aged 21 years and above, in compliance with PAGCOR regulations. We do not knowingly collect personal data from anyone under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the data, and report the matter to PAGCOR as required.

If you are a parent or guardian and believe your child has provided personal data to treasureph, please contact us immediately at [email protected].

13 Third-Party Links

The treasureph platform may contain links to third-party websites or services. This Privacy Policy applies solely to the treasureph platform. We are not responsible for the privacy practices of any third-party websites. We encourage you to review the privacy policies of any external sites you visit.

14 Changes to This Privacy Policy

treasureph reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. Material changes will be communicated to registered players via email or prominent notice on the platform at least seven (7) days before taking effect.

The "Last Updated" date at the top of this policy indicates when it was most recently revised. Your continued use of the treasureph platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

15 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with our response to your privacy concern.