Privacy Policy

1. Overview and Scope

This Privacy Policy applies to all personal information collected by romaph through our website, mobile applications, customer support channels, and any other platforms or services we operate. It covers information collected from users located in the Philippines and other jurisdictions where we operate.

romaph operates under the licensing and regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR), and we comply with all applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173). We are committed to handling your personal information in accordance with international data protection standards.

This Privacy Policy should be read in conjunction with our Terms and Conditions, Responsible Gaming Policy, and other policies incorporated into our user agreement. In the event of any conflict between this Privacy Policy and other policies, the terms of this Privacy Policy shall prevail with respect to data protection matters.

2. Information We Collect

romaph collects various types of information to provide, maintain, improve, and secure our services. The information we collect falls into the following categories:

2.1 Account Registration Information

When you create a romaph account, we collect:

• Personal Identification: Full legal name, date of birth, gender, and nationality
• Contact Information: Email address, mobile phone number, and residential address
• Account Credentials: Username, password (stored in encrypted form), and security questions
• Preferred Currency: Your chosen currency for transactions (typically Philippine Peso)
• Communication Preferences: Your preferences for receiving promotional communications and notifications

2.2 Identity Verification Documents

To comply with PAGCOR regulations and anti-money laundering (AML) requirements, we collect:

• Government-issued identification documents (Philippine passport, driver's license, UMID card, postal ID)
• Proof of address documents (utility bills, bank statements, government correspondence)
• Proof of payment method ownership (bank statements, screenshots of e-wallet accounts)
• Selfie photographs holding identification documents for identity verification

These documents are securely stored and accessed only by authorized verification personnel for the purposes of confirming your identity and age (21+ requirement) before processing withdrawals.

2.3 Financial and Transaction Information

When you make deposits or withdrawals, we collect:

• Payment method details (GCash number, PayMaya account, bank account numbers, cryptocurrency wallet addresses)
• Transaction history including dates, amounts, payment methods, and transaction status
• Deposit and withdrawal limits you have set for responsible gaming purposes
• Bonus claims, wagering activity, and promotional code usage

We do not store full credit card numbers or complete bank account credentials. Payment processing is handled through secure, PCI-DSS compliant payment processors. We retain only the information necessary to process future transactions and maintain transaction records for regulatory compliance.

2.4 Gaming Activity and Behavior Data

To provide personalized gaming experiences, detect fraud, and ensure responsible gaming, we collect:

• Games played, bet sizes, win/loss records, and gaming session durations
• Login timestamps, session frequencies, and patterns of play
• Device information including IP address, browser type, operating system, and device identifiers
• Geolocation data to verify you are accessing our services from permitted jurisdictions
• Responsible gaming tool usage (deposit limits, self-exclusion periods, reality check settings)

2.5 Communications and Support Interactions

When you contact romaph customer support or communicate with us, we collect:

• Live chat transcripts, email correspondence, and phone call recordings
• Feedback, complaints, and dispute information
• Survey responses and reviews you provide voluntarily

Support communications are retained to resolve your inquiries, improve service quality, train support staff, and maintain records for dispute resolution purposes.

2.6 Automatically Collected Technical Data

We automatically collect certain information when you use romaph services:

• Browser type, version, and language settings
• Operating system and device hardware information
• IP address and approximate geographic location
• Referral source (how you found romaph)
• Pages visited, time spent on pages, and navigation patterns
• Cookies and similar tracking technologies (see Section 7)

3. How We Use Your Information

romaph uses the collected information for the following purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your romaph account
• Processing deposits, withdrawals, and other financial transactions
• Providing access to casino games, sports betting, and other gaming services
• Managing bonuses, promotions, and VIP program benefits
• Handling customer support inquiries and resolving disputes

3.2 Legal and Regulatory Compliance

• Verifying your identity and age (21+ requirement) before processing withdrawals
• Complying with PAGCOR licensing requirements and gaming regulations
• Conducting anti-money laundering (AML) and know-your-customer (KYC) checks
• Maintaining transaction records as required by Philippine law
• Cooperating with law enforcement and regulatory investigations when legally obligated
• Enforcing our Terms and Conditions and other policies

3.3 Security and Fraud Prevention

• Detecting and preventing fraudulent transactions, bonus abuse, and money laundering
• Identifying multiple accounts, collusion, and other violations of fair play
• Monitoring for unusual betting patterns or suspicious activity
• Protecting against hacking attempts, unauthorized access, and security threats
• Verifying the authenticity of payment methods and preventing chargebacks

3.4 Responsible Gaming and Player Protection

• Enforcing the 21+ age requirement and preventing underage gambling
• Implementing deposit limits, loss limits, and session time controls
• Processing self-exclusion requests and cooling-off periods
• Identifying patterns of problem gambling behavior
• Providing access to responsible gaming tools and support resources

3.5 Service Improvement and Personalization

• Analyzing user behavior to improve platform functionality and user experience
• Personalizing game recommendations based on your preferences and play history
• Testing new features and optimizing platform performance
• Conducting market research and user satisfaction surveys
• Training customer support staff to improve service quality

3.6 Marketing and Communications

• Sending promotional offers, bonus notifications, and marketing communications (with your consent)
• Notifying you about new games, features, and platform updates
• Providing personalized promotions based on your gaming preferences
• Sending important account notifications and security alerts

You can opt out of marketing communications at any time through your account settings or by using the unsubscribe link in our emails. Note that you cannot opt out of essential service communications such as security alerts and transaction confirmations.

4. Information Sharing and Disclosure

romaph does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the following limited circumstances:

4.1 Service Providers and Business Partners

We share information with trusted third-party service providers who assist us in operating our platform:

• Payment Processors: GCash, PayMaya, banks, and other financial institutions to process deposits and withdrawals
• Game Providers: Casino game developers and sports betting data providers who power our gaming content
• Identity Verification Services: Third-party KYC providers who verify identity documents and conduct AML checks
• Customer Support Tools: Live chat platforms and customer service software providers
• Cloud Hosting and Data Storage: Infrastructure providers who host our platform and securely store data
• Analytics Providers: Services that help us analyze platform usage and improve user experience

All service providers are contractually obligated to protect your information, use it only for the specific purposes we authorize, and comply with applicable data protection laws.

4.2 Legal and Regulatory Authorities

We may disclose your information to government agencies, law enforcement, and regulatory bodies when:

• Required by Philippine law or PAGCOR regulations
• Responding to valid legal requests such as court orders or subpoenas
• Investigating suspected illegal activities including fraud, money laundering, or underage gambling
• Protecting the rights, property, or safety of romaph, our users, or the public
• Enforcing our Terms and Conditions or other agreements

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy proceeding involving romaph, your personal information may be transferred to the acquiring or successor entity. We will notify you of any such change in ownership and provide you with choices regarding your information.

4.4 With Your Consent

We may share your information with other third parties when you provide explicit consent for such sharing. You can withdraw your consent at any time by contacting our data protection team.

5. Data Security Measures

romaph employs industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Security Controls

• Encryption: All data transmissions use 256-bit SSL/TLS encryption. Sensitive data at rest (passwords, financial information) is encrypted using advanced cryptographic algorithms.
• Secure Infrastructure: Our platform is hosted on secure cloud infrastructure with redundant backups, DDoS protection, and 24/7 monitoring.
• Access Controls: Strict role-based access controls limit employee access to personal data on a need-to-know basis. All access is logged and audited.
• Firewalls and Intrusion Detection: Multi-layered firewall systems and real-time intrusion detection systems monitor for security threats.
• Regular Security Audits: Third-party security firms conduct regular penetration testing and vulnerability assessments.

5.2 Organizational Security Measures

• All employees undergo background checks and sign confidentiality agreements
• Regular security awareness training for all staff members
• Incident response procedures for data breaches and security events
• Data protection impact assessments for new features and services
• Compliance with PCI-DSS standards for payment card data handling

5.3 Account Security Best Practices

While we implement robust security measures, you also play a critical role in protecting your account:

• Create strong, unique passwords and change them regularly
• Enable two-factor authentication (2FA) when available
• Never share your login credentials with anyone
• Log out when using shared or public computers
• Be cautious of phishing emails claiming to be from romaph
• Report suspicious account activity immediately

6. Data Retention and Storage

romaph retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

6.1 Retention Periods

• Active Account Data: Retained for the duration of your active account plus applicable legal retention periods
• Transaction Records: Maintained for 5 years after the transaction date as required by PAGCOR and Philippine tax law
• KYC Documentation: Retained for 5 years after account closure for AML compliance purposes
• Marketing Communications: Retained until you unsubscribe or request deletion
• Support Communications: Retained for 3 years for dispute resolution and service improvement
• Gaming Activity Logs: Retained for 1 year for responsible gaming monitoring and fraud detection

6.2 Account Closure and Data Deletion

When you close your romaph account, we will:

• Deactivate your account and prevent further logins
• Stop processing your personal information for marketing purposes
• Retain necessary information for the legally required retention periods
• Anonymize or delete information that is no longer legally required to be retained

Please note that even after account closure, we must retain certain information to comply with regulatory obligations, prevent fraud, resolve disputes, and enforce our Terms and Conditions.

6.3 Data Storage Locations

Your personal information is primarily stored on secure servers located in data centers compliant with international security standards. We use cloud infrastructure providers with data centers in multiple geographic locations to ensure redundancy and disaster recovery capabilities.

7. Cookies and Tracking Technologies

romaph uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content.

7.1 Types of Cookies We Use

• Essential Cookies: Required for the platform to function properly. These enable account login, session management, and security features. You cannot disable these cookies.
• Functional Cookies: Remember your preferences such as language settings, favorite games, and display options to provide a personalized experience.
• Analytics Cookies: Collect anonymous information about how users interact with our platform, helping us identify areas for improvement.
• Marketing Cookies: Track your activity across websites to deliver relevant advertisements and measure campaign effectiveness.

7.2 Managing Cookie Preferences

You can control cookie preferences through your browser settings. Most browsers allow you to:

• View what cookies are stored and delete them individually or in bulk
• Block third-party cookies while allowing first-party cookies
• Block all cookies (note: this may prevent the platform from functioning properly)
• Set cookies to be deleted when you close your browser

Our platform also provides a cookie consent manager where you can customize your preferences for non-essential cookies.

7.3 Third-Party Analytics and Advertising

We use third-party analytics services to understand user behavior and improve our platform. These services may use cookies and similar technologies. Examples include Google Analytics, which provides insights into user demographics, interests, and navigation patterns.

For more information about how these third parties handle data, please refer to their respective privacy policies.

8. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012 and applicable data protection laws, you have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request access to the personal information we hold about you. We will provide you with a copy of your data in a commonly used electronic format. You can access most of your personal information through your romaph account dashboard.

8.2 Right to Rectification

If any personal information we hold about you is inaccurate or incomplete, you have the right to request correction. You can update most information directly through your account settings or by contacting customer support.

8.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal information in certain circumstances, such as when:

• The information is no longer necessary for the purposes it was collected
• You withdraw consent for processing based on consent
• You object to processing and there are no overriding legitimate grounds
• The information was unlawfully processed

Note that we may be unable to delete information if we are legally required to retain it for regulatory compliance, dispute resolution, or fraud prevention purposes.

8.4 Right to Restrict Processing

You may request that we limit the processing of your personal information in certain situations, such as when you contest the accuracy of the data or object to processing.

8.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.

8.6 Right to Object

You may object to processing of your personal information for direct marketing purposes at any time. We will stop processing your information for marketing unless we have compelling legitimate grounds to continue.

8.7 Right to Withdraw Consent

Where we process your information based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing before withdrawal.

8.8 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 12. We will respond to your request within 30 days. In some cases, we may ask you to verify your identity before processing your request to protect your privacy and security.

9. International Data Transfers

romaph primarily operates within the Philippines and stores data on servers located in secure data centers. However, some of our service providers may be located in other countries, which may result in your personal information being transferred to, stored, or processed outside the Philippines.

When we transfer data internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include:

• Standard contractual clauses approved by data protection authorities
• Ensuring service providers are certified under recognized data protection frameworks
• Obtaining your explicit consent for specific transfers

If you have questions about international data transfers, please contact our Data Protection Officer.

10. Children's Privacy

romaph services are strictly intended for individuals who are 21 years of age or older. We do not knowingly collect personal information from anyone under the age of 21.

If we become aware that we have collected personal information from a person under 21 without proper age verification, we will take immediate steps to delete that information and close the account. Our age verification procedures include:

• Date of birth collection during registration
• Government-issued identification document verification before first withdrawal
• Ongoing monitoring for suspicious accounts potentially created by underage individuals

Parents or guardians who believe their child under 21 has created an account should immediately contact us so we can close the account and delete the associated information.

11. Changes to Privacy Policy

romaph reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Privacy Policy
• Notify you via email or prominent notice on our platform
• Provide you with reasonable time to review the changes before they take effect
• For significant changes affecting your rights, request your explicit consent where required by law

Your continued use of romaph services after changes to this Privacy Policy constitutes your acceptance of the updated policy. If you do not agree with the changes, you should discontinue using our services and may close your account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how romaph handles your personal information, please contact us:

We are committed to responding to all privacy-related inquiries within 30 days. For urgent security concerns or suspected data breaches affecting your account, please contact us immediately through live chat or email with "URGENT - SECURITY" in the subject line.