Privacy Policy – ambergame

1 Introduction

ambergame is a PAGCOR-regulated online gaming platform serving Filipino players. As a regulated operator, ambergame is legally required to collect, verify, and retain certain categories of personal data as a condition of its PAGCOR operating licence. Beyond regulatory obligations, ambergame collects personal data only to the extent necessary to provide you with a secure, functional, and enjoyable gaming experience.

ambergame's data processing activities are overseen by a designated Data Protection Officer ("DPO") in accordance with the DPA. Any data privacy concerns, requests, or complaints may be directed to the DPO via the contact details provided in Section 13 of this Policy.

2 Personal Data We Collect

ambergame may collect the following categories of personal data from you:

• Identity Data: Full legal name, date of birth, nationality, gender, government-issued ID number (e.g., PhilSys ID, passport, driver's licence, UMID).
• Contact Data: Philippine mobile number, email address, and residential address.
• Financial Data: GCash account details, PayMaya account details, bank account numbers (BPI, BDO, Metrobank), and transaction records including deposit and withdrawal histories.
• Account Data: Username, encrypted password, account creation date, login history, session data, and betting and gaming activity records.
• Device & Technical Data: IP address, browser type and version, device type and operating system, screen resolution, and referral URL.
• KYC Verification Data: Copies of government-issued identification documents and selfie photographs submitted during identity verification.
• Communications Data: Records of your communications with ambergame's support team, including live chat transcripts and submitted support tickets.

3 How We Collect Personal Data

ambergame collects personal data through the following means:

• Direct Collection: Information you provide when creating an account, completing KYC verification, making deposits or withdrawals, entering promotions, or contacting support.
• Automated Collection: Technical data collected automatically when you access ambergame, including through cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data obtained from PAGCOR-approved KYC service providers; payment verification data from payment processing partners including GCash and Maya; fraud prevention data from ambergame's risk management systems.

4 Purposes of Processing

ambergame processes your personal data for the following purposes:

• To create, manage, and maintain your ambergame account;
• To verify your identity and age (21+) in compliance with PAGCOR requirements;
• To process deposits and withdrawals through GCash, Maya, and Philippine bank channels;
• To detect and prevent fraud, money laundering, and other prohibited activities;
• To provide customer support and resolve disputes;
• To send transactional communications such as deposit confirmations and withdrawal receipts;
• To send promotional communications where you have consented to receive them;
• To analyse platform usage for the purposes of improving ambergame's services;
• To comply with PAGCOR regulatory reporting obligations and Philippine legal requirements.

5 Legal Basis for Processing

ambergame processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform the contract between you and ambergame, including account management, gameplay, and financial transactions.
• Legal Obligation: Processing required to comply with PAGCOR regulatory requirements, the Anti-Money Laundering Act, and other applicable Philippine laws.
• Legitimate Interest: Processing necessary for fraud prevention, platform security, and service improvement, where ambergame's legitimate interests are not overridden by your rights.
• Consent: Processing for marketing communications, where you have provided explicit consent. You may withdraw this consent at any time by contacting ambergame support.

6 Data Sharing & Disclosure

ambergame does not sell your personal data. We may share your personal data with the following categories of recipients in accordance with this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, and other Philippine payment service providers, for the purpose of processing financial transactions.
• KYC & Identity Verification Providers: Third-party providers engaged to verify the identity documents submitted during account registration and verification.
• Game Content Providers: Third-party game developers and live casino operators who may receive limited technical data necessary to deliver game content to your device.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council ("AMLC"), and other Philippine government authorities, where disclosure is required by law or regulation.
• Law Enforcement: Philippine law enforcement agencies or courts, where ambergame is required to disclose data pursuant to a lawful order or to prevent or detect crime.

All third-party service providers engaged by ambergame are bound by data processing agreements that prohibit the use of player data for any purpose other than those specified and that require compliance with the DPA.

7 Data Retention

ambergame retains personal data for the period necessary to fulfil the purposes for which it was collected, subject to the following retention periods:

• Active Account Data: Retained for the duration of your ambergame account and for a period of five (5) years following permanent account closure.
• KYC & Identity Records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR and AMLC regulations.
• Financial Transaction Records: Retained for a minimum of ten (10) years, as required under Philippine anti-money laundering legislation.
• Support Communications: Retained for a period of two (2) years from the date of the last communication.
• Marketing Consent Records: Retained until you withdraw consent or for two (2) years from the date consent was given, whichever is earlier.

8 Cookies & Tracking Technologies

ambergame uses cookies and similar tracking technologies on the platform for the following purposes:

• Essential Cookies: Necessary for the platform to function, including session management and security tokens. These cannot be disabled without rendering the platform inoperable.
• Performance Cookies: Used to measure page load times, identify errors, and analyse user navigation paths for the purpose of improving platform performance. Data collected is aggregated and does not identify individual users.
• Functional Cookies: Used to remember your preferences such as language, preferred games, and login state where you have enabled "Remember Me".

You may manage cookie preferences through your browser settings. Note that disabling essential cookies will impair your ability to use ambergame's core services, including the ability to log in.

9 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ambergame:

• Right to be Informed: The right to be informed of the nature, purpose, and extent of processing of your personal data.
• Right of Access: The right to request a copy of the personal data ambergame holds about you.
• Right to Rectification: The right to correct inaccurate or incomplete personal data.
• Right to Erasure / Right to be Forgotten: The right to request deletion of personal data that is no longer necessary for the purpose for which it was collected, subject to applicable legal retention requirements.
• Right to Object: The right to object to the processing of your personal data on grounds of legitimate interest, including for direct marketing purposes.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission ("NPC") of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, contact ambergame's Data Protection Officer via the details in Section 13. ambergame will respond to all data subject requests within 15 business days.

10 Children's Privacy

ambergame's services are strictly restricted to individuals aged 21 years or older, as required by PAGCOR. ambergame does not knowingly collect personal data from persons under the age of 21. If ambergame becomes aware that personal data has been collected from a person under 21, the associated account will be closed immediately and the data deleted, except where retention is required by applicable law or regulation.

If you believe that a person under 21 years of age has registered an account on ambergame, please contact our support team immediately via live chat or the email address provided in Section 13.

11 Security Measures

ambergame implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data in transit;
• Encryption of sensitive data at rest, including financial account details and KYC document copies;
• Role-based access controls restricting internal access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of the ambergame platform;
• Multi-factor authentication for administrative access to systems containing personal data;
• A documented data breach response procedure compliant with the NPC's breach notification requirements.

No data transmission over the internet can be guaranteed to be completely secure. While ambergame takes all reasonable precautions, you are responsible for maintaining the security of your own account credentials.

12 Changes to This Policy

ambergame reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered players through their registered contact details and by posting a notice on the ambergame platform. The "Last Updated" date at the top of this Policy will be revised accordingly.

Your continued use of ambergame following notification of a material change to this Policy constitutes your acceptance of the revised Policy. We recommend that all ambergame players review this page periodically to remain informed of how their personal data is being processed.

13 Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ambergame, please contact us through the following channels:

• Data Protection Officer Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week, directly on ambergame.club

ambergame serves players from all regions of the Philippines, including Manila, Quezon City, Cebu, Davao, Makati, Iloilo, and beyond. All data privacy communications are handled in English.