vipiny Privacy Policy

1 Who We Are

vipiny (referred to in this policy as "vipiny," "we," "us," or "our") is an online casino and sports betting platform accessible at vipiny.net, designed and operated to serve Filipino players with a safe, compliant, and enjoyable gaming environment. vipiny operates in accordance with applicable Philippine gaming and data privacy regulations.

For the purposes of this Privacy Policy, vipiny is the data controller — meaning we are the entity that determines the purposes and means by which your personal information is processed. If you have any questions about who controls your data or how this policy applies to you, please contact us using the details in Section 14.

2 Information We Collect

vipiny collects personal information from you in the following ways: information you provide to us directly, information collected automatically as you use the platform, and information received from third-party service providers. The categories of personal data we collect include:

2.1 Information You Provide Directly

• Registration data: Full name, date of birth, email address, mobile number, residential address, and username when you create your vipiny account.
• Identity verification (KYC) documents: Government-issued ID (e.g., Philippine passport, SSS ID, driver's license, PhilSys national ID), proof of address, and proof of payment method ownership when required for verification.
• Financial information: Payment method details such as your GCash number, Maya account, BPI or BDO account reference, and transaction records. Note that vipiny does not store full bank account numbers or card numbers directly.
• Communications: Messages, feedback, and complaints you send to our support team via live chat or email.
• Responsible Gaming preferences: Self-exclusion requests, deposit limits, and session limit settings you configure in your account.

2.2 Information Collected Automatically

• Device and technical data: IP address, browser type and version, operating system, device model, and screen resolution.
• Usage data: Pages visited, games played, session duration, time and date of access, and in-game betting activity.
• Cookies and similar technologies: Session cookies, persistent cookies, and local storage tokens used to maintain your login session and remember your preferences. See Section 6 for full details.
• Geolocation data: General location derived from your IP address, used to verify eligibility and ensure compliance with jurisdictional restrictions.

2.3 Information from Third Parties

• Identity verification results from our KYC and AML screening partners.
• Payment transaction status from payment processors such as GCash, Maya, InstaPay, and BancNet-affiliated banks.
• Fraud risk scores from fraud prevention service providers.

3 How We Use Your Data

vipiny uses the personal information we collect for the following purposes:

• Account creation and management: To register your account, verify your identity, manage your profile, and enable access to all platform features.
• Processing transactions: To process deposits, withdrawals, and any financial transactions conducted through your vipiny account.
• Regulatory compliance: To fulfil our legal obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and data privacy requirements, including Know Your Customer (KYC) verification.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other unlawful conduct on the platform.
• Customer support: To respond to your inquiries, resolve complaints, and provide technical assistance through our 24/7 support team.
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling and to implement self-exclusion, deposit limits, and other player protection measures.
• Platform improvement: To analyse aggregate usage patterns and improve the features, design, and performance of the vipiny platform.
• Promotions and communications: To send you information about bonuses, promotions, and account-related notifications. You may opt out of promotional communications at any time through your account settings.
• Legal proceedings: To establish, exercise, or defend legal claims when necessary.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its implementing rules and regulations, vipiny processes your personal information on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and vipiny — specifically, to operate your account, process transactions, and deliver the gaming services you have signed up for.
• Legal obligation: Processing is required for vipiny to comply with applicable Philippine laws, including PAGCOR regulatory requirements, AML obligations under Republic Act No. 9160, and data retention mandates.
• Legitimate interests: Processing is necessary for the legitimate interests of vipiny, including fraud detection, platform security, and business analytics, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: For certain processing activities such as marketing communications and non-essential cookies, vipiny relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Sharing Your Information

vipiny does not sell your personal data to any third party. We may, however, share your information with the following categories of recipients where it is necessary and proportionate to do so:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, InstaPay, PesoNet, QR Ph, GrabPay, and 7-Eleven CLiQQ, to facilitate deposits and withdrawals.
• KYC and AML service providers: Third-party identity verification and sanctions screening providers engaged to fulfil our regulatory obligations.
• Fraud prevention and cybersecurity providers: Service providers that assist vipiny in detecting and preventing fraudulent transactions and security incidents.
• Game content providers: Third-party game studios and live dealer providers (such as Ezugi) whose games are hosted on the vipiny platform. These providers may receive limited technical data necessary to deliver the game experience.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent authorities where disclosure is required by law or by a lawful order.
• Professional advisers: Lawyers, auditors, and accountants bound by confidentiality obligations where disclosure is required in connection with legal advice or proceedings.

All third-party service providers engaged by vipiny are required to handle your personal data in accordance with applicable data protection laws and are prohibited from using your data for their own independent commercial purposes.

6 Cookies & Tracking Technologies

vipiny uses cookies and similar tracking technologies to operate the platform effectively, maintain session security, and improve the player experience. Below is a summary of the cookies we use:

vipiny does not use third-party advertising cookies or behavioural tracking cookies that follow you across other websites. Strictly necessary cookies cannot be disabled as they are essential to the secure operation of your account.

You can manage or delete functional and analytics cookies through your browser settings at any time. Note that disabling functional cookies may affect your ability to use certain platform features. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.

7 Data Security

vipiny takes the security of your personal information seriously and implements a multi-layered approach to data protection:

• SSL/TLS encryption: All data transmitted between your device and vipiny.net is encrypted using industry-standard TLS protocols. Look for the padlock icon in your browser's address bar on every vipiny page.
• Encryption at rest: Sensitive personal data stored on vipiny servers is encrypted at rest using strong encryption standards.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. vipiny staff are granted access only to the data necessary to perform their specific roles.
• Security monitoring: vipiny operates continuous security monitoring and logging to detect and respond to potential breaches or unauthorised access attempts in real time.
• Penetration testing: The vipiny platform undergoes regular security assessments, including penetration testing by qualified cybersecurity professionals.
• Incident response: In the event of a personal data breach that is likely to result in risk to your rights and freedoms, vipiny will notify the National Privacy Commission and affected players in accordance with the timeframes required by the Data Privacy Act and its implementing rules.

While vipiny employs robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own account credentials. If you suspect unauthorised access to your account, please contact support immediately.

8 Data Retention

vipiny retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention considerations:

• Active accounts: Personal data associated with an active vipiny account is retained for the duration of the account's active status.
• Closed accounts: Following account closure, vipiny retains transaction records, KYC documentation, and gaming activity logs for a minimum of five (5) years to comply with PAGCOR regulatory requirements and AML obligations under Philippine law.
• Support communications: Live chat transcripts and email communications are retained for up to two (2) years from the date of the interaction.
• Technical and usage logs: Server access logs and session data are retained for up to twelve (12) months for security and performance monitoring purposes.
• Legal hold: Where personal data is subject to ongoing legal proceedings, regulatory investigations, or dispute resolution processes, retention may be extended until the matter is fully resolved.

When personal data is no longer required and no legal basis for retention exists, vipiny will securely delete or anonymise the data in accordance with our internal data disposal procedures.

9 Your Data Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by vipiny:

• Right to be informed: You have the right to be informed that your personal data is being collected and processed, including the purposes for which it is used. This Privacy Policy fulfils that obligation.
• Right of access: You may request a copy of the personal data vipiny holds about you, along with information about how it is processed.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic account information directly in your account settings.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations that may override this right.
• Right to object: You have the right to object to the processing of your personal data where that processing is based on legitimate interests or for direct marketing purposes.
• Right to data portability: You may request that your personal data be provided to you in a structured, commonly used, and machine-readable format.
• Right to file a complaint: If you believe that vipiny has processed your personal data in violation of applicable data privacy laws, you have the right to file a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please submit a written request to our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will acknowledge your request within 3 business days and provide a substantive response within 15 business days. For complex requests, we may require additional time and will notify you accordingly.

10 Children & Minors

vipiny strictly prohibits the use of its platform by individuals under the age of 21. This is a firm legal requirement under Philippine gaming regulations applicable to casino-style gambling. vipiny does not knowingly collect personal information from persons under 21 years of age.

If vipiny becomes aware that personal data has been collected from an individual who is under 21 years of age, we will immediately suspend the associated account, delete the data collected, and report the matter to the appropriate regulatory authorities if required.

11 International Data Transfers

vipiny operates primarily within the Philippines. However, some of our third-party service providers — including KYC verification platforms, cybersecurity services, and game content providers — may process data in servers located outside the Philippines.

Where personal data is transferred to a jurisdiction outside the Philippines, vipiny ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include:

• Contractual data processing agreements incorporating standard data protection clauses.
• Transfers only to jurisdictions recognised as providing an adequate level of data protection by the National Privacy Commission.
• Technical and organisational security measures mandated in processor agreements.

You may request further information about international data transfers applicable to your account by contacting our Data Protection Officer.

12 Third-Party Links

The vipiny platform may contain references to or integrations with third-party game providers and payment services. While vipiny takes care to work only with reputable partners, this Privacy Policy applies solely to data processed by vipiny and does not cover the data practices of any third-party service providers or platforms.

We encourage you to read the privacy policies of any third-party services you interact with in connection with your vipiny account. vipiny is not responsible for the privacy practices or content of third-party operators.

13 Updates to This Privacy Policy

vipiny reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will notify registered players through a prominent notice on the platform and, where appropriate, by email to your registered address. The updated policy will become effective from the date indicated at the top of this page.

Your continued use of the vipiny platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of and agreement to the updated terms. If you do not accept any changes to this Privacy Policy, you must stop using the platform and may request account closure in accordance with the procedures set out in our Terms & Conditions.

14 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way vipiny handles your personal data, please contact our Data Protection Officer through the following channels:

• Email: [email protected] — use the subject line "Privacy Policy Inquiry" or "Data Privacy Request."
• Live Chat: Available 24/7 directly on the vipiny platform for immediate assistance with account-related privacy concerns.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. More information about the NPC and how to file a complaint is available through official Philippine government channels.