mgame Privacy Policy 🔒

1. Introduction and Scope

This Privacy Policy ("Policy") describes how mgame ("mgame," "we," "us," or "our") collects, uses, stores, and protects the personal data of individuals ("you," "your," or "Player") who access or use the mgame online gaming platform available at mgame.app (the "Platform").

mgame is committed to protecting your privacy and handling your personal data responsibly, transparently, and in full compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC").

By registering an account on the Platform or otherwise providing your personal data to mgame, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the Platform.

This Policy applies to all personal data collected through the Platform, including data collected during registration, gameplay, payment processing, customer support interactions, and marketing communications.

2. Data Controller Information

mgame acts as the data controller in respect of the personal data collected through the Platform. As data controller, mgame determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws.

For all data privacy-related enquiries, requests, or complaints, you may contact our designated Data Privacy Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

mgame collects the following categories of personal data:

3.1 Identity and Contact Data

• Full legal name;
• Date of birth (for age verification — players must be 21 years or older);
• Nationality and country of residence;
• Email address;
• Mobile phone number;
• Residential address (including barangay, city, province, and postal code).

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID);
• Proof of address documents;
• Selfie or facial image for identity verification purposes;
• Proof of payment method ownership.

3.3 Financial Data

• GCash or PayMaya account details (mobile number only — mgame does not store full wallet credentials);
• Bank account details for BPI, BDO, Metrobank, or other approved banks (account name and number only);
• Transaction history, including deposits, withdrawals, and bonus activity;
• Payment method type and last four digits of card where applicable.

3.4 Gaming and Behavioural Data

• Game history, bet amounts, win/loss records, and session duration;
• Bonus and promotion usage;
• Responsible gaming tool usage (deposit limits, self-exclusion requests);
• Platform preferences and settings.

3.5 Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Login timestamps and session data;
• Cookie identifiers and analytics data.

3.6 Communications Data

• Customer support chat logs and email correspondence;
• Survey responses and feedback submissions.

4. How We Collect Your Data

mgame collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Data collected automatically when you use the Platform, including through cookies, log files, and analytics tools;
• Third-party sources: Data received from identity verification service providers, payment processors, fraud prevention services, and regulatory bodies where permitted by law.

5. How We Use Your Personal Data

mgame uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your player account;
• Identity verification: To verify your identity and age (21+) in compliance with regulatory requirements;
• Payment processing: To process deposits, withdrawals, and refunds via GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment channels;
• Platform operation: To provide access to games, process bets, and calculate winnings;
• Regulatory compliance: To comply with anti-money laundering (AML), counter-terrorism financing (CTF), and other applicable Philippine legal obligations;
• Fraud prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct;
• Responsible gaming: To monitor gaming behaviour and enforce responsible gaming tools, including deposit limits and self-exclusion;
• Customer support: To respond to your enquiries, complaints, and support requests;
• Marketing communications: To send you promotional offers, bonuses, and platform updates where you have provided consent;
• Platform improvement: To analyse usage patterns and improve the Platform's features, performance, and user experience.

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to upon registration;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML/CTF obligations and PAGCOR regulatory requirements;
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming enforcement;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

7. Sharing of Personal Data

7.1 mgame does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

7.2 mgame may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment service providers, for the purpose of processing transactions;
• Identity verification providers: Third-party KYC and age verification service providers;
• Fraud prevention services: Third-party providers that assist in detecting and preventing fraudulent activity;
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on our behalf under data processing agreements;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where required by law or court order;
• Professional advisers: Legal, accounting, and auditing firms, subject to professional confidentiality obligations.

7.3 Where personal data is transferred to third-party processors, mgame ensures that appropriate contractual safeguards are in place to protect your data in accordance with the DPA.

8. Data Retention

8.1 mgame retains your personal data for as long as your account is active and for a period thereafter as required by applicable law or legitimate business purposes.

8.2 In accordance with Philippine AML regulations and PAGCOR requirements, transaction records and KYC documentation are retained for a minimum of five (5) years following the closure of your account or the completion of the relevant transaction, whichever is later.

8.3 Where personal data is no longer required for the purposes for which it was collected, mgame will securely delete or anonymize it in accordance with our internal data retention schedule.

9. Cookies and Tracking Technologies

9.1 mgame uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support our marketing activities. A cookie is a small text file placed on your device when you visit the Platform.

9.2 mgame uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled;
• Performance and analytics cookies: Used to collect anonymized data about how players use the Platform, helping us identify areas for improvement;
• Functional cookies: Used to remember your preferences, such as language settings and display options;
• Marketing cookies: Used to deliver relevant promotional content. These are only placed with your consent.

9.3 You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

10. Data Security

10.1 mgame implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including financial and identity information;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments, vulnerability testing, and penetration testing;
• Two-factor authentication (2FA) options for player accounts;
• Incident response procedures for detecting and responding to data breaches.

10.2 In the event of a personal data breach that is likely to result in harm to affected individuals, mgame will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

10.3 While mgame takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. Players are encouraged to use strong, unique passwords and to enable 2FA on their accounts.

11. Your Rights as a Data Subject

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

• Right to be informed: The right to be notified of how your personal data is collected and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data mgame holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Privacy Officer using the details in Section 14. mgame will respond to all verified requests within thirty (30) days, in accordance with NPC guidelines.

12. Children's Privacy

The mgame Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming regulations. mgame does not knowingly collect personal data from persons under the age of 21. If mgame becomes aware that personal data has been collected from an individual under 21, the relevant account will be immediately closed and all associated data will be deleted or returned in accordance with applicable law. If you believe a minor has registered on the Platform, please contact us immediately at the details provided in Section 14.

13. Changes to This Privacy Policy

mgame reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. Material changes will be communicated to registered players via the email address on file or through a prominent notice on the Platform. The "Last Updated" date at the top of this Policy will be revised accordingly. Your continued use of the Platform following the posting of any changes constitutes your acceptance of the revised Policy.

14. Contact and Data Privacy Officer

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

• Data Privacy Officer: mgame Data Privacy Office
• Email: [email protected]
• Support Email: [email protected]
• Response Time: We aim to respond to all data privacy requests within 30 days

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.