Privacy Policy

Introduction

Welcome to viplh. This Privacy Policy governs the collection, processing, storage, and disclosure of personal information by viplh ("we," "us," "our," or "the Company") when you access or use the viplh platform, including the website at viplh.cam, any associated mobile interfaces, and all related services (collectively, the "Services").

We are committed to protecting the privacy and security of every player who trusts us with their personal data. This Policy is written in plain, accessible English to ensure that Filipino players — and all users regardless of location — fully understand their rights and how their information is handled. Where terms have specific legal meanings under applicable Philippine law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, those meanings shall apply.

By registering an account, accessing our Services, or otherwise providing personal data to viplh, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree, please discontinue use of our Services immediately. All players must be 21 years of age or older to use viplh.

This Policy should be read together with our Terms & Conditions, which governs the overall relationship between viplh and its registered players.

1.1 Information You Provide Directly

When you create a viplh account, interact with our customer support team, or otherwise communicate with us, you voluntarily provide personal information that may include:

• Identity data: Full legal name, date of birth, nationality, and government-issued identification details (e.g., Philippine Passport, SSS ID, UMID, Driver's License, or PRC ID).
• Contact data: Email address, mobile number (including Globe, Smart, or DITO lines), and residential address including barangay, city (e.g., Makati, Quezon City, Cebu, Davao), province, and ZIP code.
• Financial data: Payment method details including GCash mobile number, Maya account information, BPI or BDO account information, UnionBank details, or cryptocurrency wallet addresses used for USDT transactions. We do not store full card numbers or CVV codes.
• Account credentials: Username and hashed password. We never store passwords in plaintext.
• Verification documents: Copies of government-issued identification, selfie photographs, and proof of address submitted during Know Your Customer (KYC) verification, as required under applicable anti-money laundering (AML) regulations.
• Communication records: Content of messages sent via our live chat system, email correspondence, or any feedback or survey responses you submit.

1.2 Information Collected Automatically

When you use our platform, certain technical and behavioral data is collected automatically through standard internet technologies:

• Device and technical data: IP address, device type, operating system version, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages viewed, games played, session duration, betting history, deposit and withdrawal activity, features accessed, click patterns, and navigation paths within the platform.
• Location data: Approximate geolocation derived from your IP address. We do not collect precise GPS location without your explicit consent.
• Cookies and similar technologies: As described in Section 6 of this Policy.

1.3 Information from Third Parties

We may receive personal information about you from third-party sources, including:

• Payment processors and e-wallet providers (such as GCash or Maya) for the purpose of processing and verifying transactions.
• Identity verification service providers used during KYC/AML compliance checks.
• Fraud detection and responsible gaming partners who flag patterns of problematic behavior.
• Regulatory bodies and law enforcement authorities as required by law.

viplh processes personal data only for specified, explicit, and legitimate purposes. We use the information we collect to:

• Provide and maintain our Services: Create and manage your account, process deposits and withdrawals, deliver gaming services, and ensure platform functionality.
• Verify your identity: Fulfill KYC, AML, and counter-terrorist financing (CTF) obligations as required under Philippine law and applicable gaming regulations.
• Process financial transactions: Facilitate deposits via GCash, Maya, BPI, BDO, and other supported methods, as well as process withdrawal requests to your designated payment account.
• Provide customer support: Respond to inquiries, resolve disputes, and improve the overall support experience for Filipino players.
• Personalize your experience: Tailor game recommendations, promotional offers, and platform content based on your preferences and activity — never in a way that encourages irresponsible gambling.
• Communicate with you: Send transactional notifications (deposit confirmations, withdrawal approvals), account security alerts, and — with your consent — promotional communications.
• Ensure platform security: Detect and prevent fraud, cheating, money laundering, unauthorized access, and other illegal or prohibited activities.
• Comply with legal obligations: Meet requirements under the Data Privacy Act of 2012, PAGCOR regulations, AML laws, and any other applicable Philippine or international legal requirements.
• Improve our Services: Conduct analytics, testing, and research to enhance platform features, game offerings, and user experience.
• Enforce our terms: Investigate and act on breaches of our Terms & Conditions or this Privacy Policy.

Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, viplh processes personal data on the following legal grounds:

• Consent: Where you have given clear, specific, and informed consent, such as for receiving marketing communications or for the processing of sensitive personal information.
• Contractual necessity: Processing required to fulfill our contract with you — specifically, to provide the gaming and payment services you have registered to receive.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML/CTF obligations, tax reporting requirements, and PAGCOR regulatory directives.
• Legitimate interests: Processing undertaken in furtherance of our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your fundamental rights and freedoms.
• Vital interests: In limited cases, processing necessary to protect life or safety, including responsible gaming interventions for at-risk players.

viplh does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your information only in the following limited circumstances:

• Service providers: We engage trusted third-party vendors who process data on our behalf under strict contractual obligations, including payment processors (GCash, Maya, BPI), game platform providers, KYC/identity verification providers, cloud hosting services, and customer support tools.
• Regulatory and law enforcement authorities: We may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or law enforcement bodies when legally required or when necessary to prevent serious harm.
• Business transfers: In the event of a merger, acquisition, or sale of company assets, personal data may be transferred to the successor entity, subject to equivalent privacy protections.
• Responsible gaming partners: In cases where a player has voluntarily enrolled in a self-exclusion program or where we identify patterns indicative of problem gambling, limited information may be shared with responsible gaming support organizations.
• With your explicit consent: For any other purpose not listed above, we will always seek your prior written consent before sharing your personal data.

All third parties who receive personal data from viplh are contractually bound to use it solely for the specified purpose and to maintain at least equivalent standards of data protection.

We retain personal data for as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal retention requirements. Specific retention periods include:

• Account data: Retained for the duration of your active account relationship with viplh, and for a minimum of five (5) years following account closure, as required under Philippine AML regulations.
• Transaction records: Financial transaction data, including deposit and withdrawal records, is retained for a minimum of five (5) years from the date of each transaction.
• KYC/identity verification documents: Retained for at least five (5) years after the end of the business relationship, in compliance with AMLC requirements.
• Communication records: Customer support interactions and correspondence are retained for three (3) years unless a longer retention period is required for legal proceedings.
• Cookies and analytics data: Session cookies expire at the end of your browsing session. Persistent analytics data is retained for up to twenty-four (24) months.

When personal data is no longer required for its original purpose and no legal retention obligation applies, viplh will securely delete, anonymize, or pseudonymize that data.

viplh uses cookies and similar technologies to operate our platform, recognize returning users, maintain session security, and understand how players interact with our Services. The categories of cookies we use are:

• Strictly necessary cookies: Essential for core platform functionality, including authentication, session management, and security features. These cannot be disabled without rendering the platform non-functional.
• Performance and analytics cookies: Used to collect aggregated, anonymized information about how players navigate the platform, which pages are most visited, and where errors occur. This helps us continuously improve the viplh experience.
• Functional cookies: Used to remember your preferences, such as language settings, preferred game categories, and display options, to personalize your experience.
• Responsible gaming cookies: Used to track session duration and prompt responsible gaming reminders in accordance with our duty-of-care obligations to players.

You may manage cookie preferences through your browser settings. Note that disabling certain cookies may affect platform functionality. By continuing to use viplh after being presented with our cookie notice, you consent to our use of non-essential cookies as described above.

viplh implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security framework includes:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.3 or higher. Sensitive data at rest, including financial information, is encrypted using AES-256.
• Access controls: Personal data is accessible only to authorized viplh personnel with a legitimate need to access it, governed by role-based access controls and enforced by multi-factor authentication for administrative systems.
• Secure payment processing: We partner with PCI DSS-compliant payment processors. Full payment card details are never stored on our systems.
• Regular security audits: Our infrastructure undergoes periodic vulnerability assessments and penetration testing by qualified security professionals.
• Incident response: We maintain a documented data breach response plan. In the event of a breach affecting your rights and freedoms, we will notify the National Privacy Commission and affected individuals within 72 hours, as required under RA 10173.

While we take all reasonable precautions, no online system is entirely immune from risk. We encourage you to use a strong, unique password for your viplh account and to enable two-factor authentication where available.

Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights with respect to your personal data held by viplh:

• Right to be informed: The right to know what personal data we hold about you and how it is being processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of all personal data we hold about you, along with information about how it is used.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure / right to be forgotten: The right to request deletion of your personal data, subject to our legal retention obligations and ongoing contractual requirements.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to restrict processing: The right to request that we limit how we use your data in certain circumstances, such as while a dispute is being investigated.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing that occurred prior to withdrawal.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the address listed in Section 11. We will respond to all valid requests within fifteen (15) business days. We may need to verify your identity before processing certain requests.

viplh is strictly an adults-only platform. In accordance with Philippine law and PAGCOR regulations, all players must be at least 21 years of age to register and use our Services. We do not knowingly collect, process, or retain personal data from individuals under the age of 21.

During the registration process, all users are required to confirm their age and subsequently verify their identity through our KYC process. Any account found to belong to a person under 21 years of age will be immediately suspended, all funds will be frozen pending investigation, and the account will be permanently closed. Any winnings generated during the underage period will be forfeited in full.

If you believe that a minor has registered an account on our platform or that we have inadvertently collected personal data from someone under 21, please contact us immediately at the details provided in Section 11 so we can take prompt corrective action.

viplh reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or platform features. When we make material changes, we will notify you by one or more of the following methods:

• Posting a prominent notice on the viplh platform upon your next login.
• Sending an email notification to the address registered on your account.
• Updating the "Effective Date" at the top of this page.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of viplh following the posting of any changes constitutes your acceptance of the revised Policy. If you do not agree with any changes, you must discontinue using our Services and may request account closure by contacting our support team.

Archived versions of previous Privacy Policy iterations are available upon written request to our Data Protection Officer.

viplh has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact us through the following channels:

• Email: [email protected] — please use the subject line "Privacy Request" or "Data Protection Inquiry"
• Live Chat: Available 24/7 directly on the viplh platform — our support agents will escalate data privacy matters to the DPO within one business day
• Response time: We aim to acknowledge all privacy-related inquiries within 48 hours and provide a substantive response within 15 business days

If you are not satisfied with our response, or if you believe that viplh has violated your data privacy rights under RA 10173, you have the right to file a complaint with the National Privacy Commission of the Philippines. The NPC accepts complaints and inquiries through its official government channels and is the primary regulatory body overseeing data privacy compliance in the Philippines.

We take all privacy complaints seriously and are committed to resolving issues fairly, transparently, and in accordance with applicable law. Your trust is important to us, and we will always treat your concerns with the respect and urgency they deserve.