em88 Privacy Policy

§ 1 Who We Are & Scope of This Policy

This Privacy Policy is issued by em88, the online gaming platform accessible at em88.bio ("em88", "we", "us", "our"). em88 acts as the data controller in respect of personal data collected through the em88.bio website and all associated mobile interfaces, APIs, and communication channels.

This Policy applies to:

• All registered players with an active or closed em88 account.
• Visitors who browse em88.bio without creating an account.
• Any individual who contacts em88 through our customer support channels.
• Any individual whose personal data is provided to em88 in the course of KYC verification, payment processing, or responsible gaming compliance activities.

This Policy does not apply to third-party websites or services linked from em88.bio. em88 has no control over the privacy practices of third-party game providers or payment processors, and their own privacy policies govern the data they process independently. Please review those policies separately.

§ 2 Personal Data We Collect

em88 collects the following categories of personal data:

2.1 Identity & Contact Data

• Full legal name as it appears on a valid Philippine government-issued ID.
• Date of birth (used for age verification — players must be 21+).
• Philippine mobile number (used as primary account identifier and for OTP verification).
• Email address (used for account communications and account recovery).
• Residential address in the Philippines (collected during KYC).

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., PhilSys ID, passport, driver's license, UMID, Voter's ID, SSS ID, PRC ID).
• Selfie photographs submitted for KYC liveness verification purposes.
• Proof of payment method ownership (e.g., bank account screenshots) where required.

2.3 Financial & Transaction Data

• GCash or PayMaya wallet numbers, BPI, BDO, or Metrobank account numbers registered for deposits and withdrawals.
• Transaction records including deposit amounts, withdrawal requests, dates, and statuses.
• Account balance history.

2.4 Gaming & Behavioral Data

• Bet histories, game session durations, wagering amounts, wins, and losses.
• Bonus usage and wagering requirement progress.
• Game provider preferences and session frequency patterns.

2.5 Technical & Device Data

• IP address and approximate geographic location derived from IP.
• Device type, operating system, browser type and version.
• Login timestamps and session durations.
• Device fingerprint identifiers used for security and duplicate account detection.

2.6 Communications Data

• Customer support chat logs, email correspondence, and any other communications sent to or from em88 support channels.

§ 3 How We Collect Your Data

em88 collects personal data through the following means:

• Direct provision by you: When you register an account, complete KYC, make a deposit or withdrawal, contact customer support, or update your account settings.
• Automated technical collection: Through cookies, session tokens, server logs, and device fingerprinting technologies that operate when you access em88.bio. See Section 7 for full cookie details.
• Payment and verification service providers: When you initiate a GCash, PayMaya, or bank transfer transaction, em88 receives confirmation data from the payment provider confirming the transaction details.
• Third-party identity verification services: em88 may use licensed identity verification platforms to assist with automated KYC document checking. These providers process your submitted ID documents under strict data processing agreements.
• Game providers: Game session data (bet amounts, results, session duration) is provided to em88 by the third-party game provider platforms that power the em88 lobby.

§ 4 Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), em88 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to register and operate your account, process deposits and withdrawals, verify identity, and provide the gaming services you have contracted with em88 to receive.
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act, tax obligations, and any other applicable Philippine law.
• Legitimate interests: Processing required for fraud detection and prevention, security monitoring, duplicate account detection, and platform integrity — where these interests are not overridden by your privacy rights.
• Consent: For optional marketing communications (e.g., promotional emails, SMS notifications about bonuses). You may withdraw consent for marketing at any time through your account settings without affecting the operation of your account.

§ 5 How We Use Your Personal Data

em88 uses your personal data for the following specific purposes:

• Account management: Creating, operating, and maintaining your em88 account; processing login authentication including OTP verification.
• Identity verification (KYC): Verifying that you are who you say you are, that you meet the 21+ age requirement, and that your payment methods are registered in your own name.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank; maintaining accurate transaction records.
• Regulatory compliance: Meeting PAGCOR's player verification and record-keeping requirements; complying with Anti-Money Laundering Act obligations including customer due diligence and transaction monitoring.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling indicators; implementing player-requested limits, self-exclusion, and cooling-off periods in accordance with PAGCOR's responsible gaming framework.
• Security and fraud prevention: Detecting and preventing unauthorized account access, duplicate accounts, fraudulent transactions, and other prohibited activities described in the em88 Terms and Conditions.
• Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Platform improvement: Analyzing anonymized usage patterns to improve game selection, site performance, and user experience on the em88 platform.
• Marketing (with consent only): Sending promotional communications about em88 bonuses, new game launches, and special offers for Filipino players — only where you have provided consent and have not withdrawn it.

§ 6 Sharing Your Personal Data

em88 does not sell or rent your personal data to any third party. em88 shares your personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Game providers: Bet and session data is shared with the licensed game providers powering the em88 lobby (e.g., PG Soft, JILI, Pragmatic Play, Evolution Gaming) to enable game functionality and resolve game-related disputes.
• Payment processors: Transaction data is shared with GCash, PayMaya, BPI, BDO, and Metrobank as required to process your deposits and withdrawals.
• KYC verification providers: Identity document data is processed by licensed KYC/AML service providers under strict data processing agreements that prohibit those providers from using your data for any purpose other than verification.
• Regulatory authorities: em88 is required to share player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine regulatory or law enforcement authorities upon lawful demand.
• Legal proceedings: em88 may disclose personal data where required by a court order, subpoena, or other lawful legal process under Philippine law.
• Professional advisers: em88's lawyers, accountants, auditors, and compliance consultants may access personal data on a strictly need-to-know basis and are bound by confidentiality obligations.

§ 7 Cookies & Tracking Technologies

em88 uses cookies and similar tracking technologies on em88.bio. A cookie is a small text file placed on your device by a website. em88 uses the following categories of cookies:

• Strictly necessary cookies: Required for the em88 platform to function. These include session authentication tokens, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without rendering the site non-functional.
• Functional cookies: Remember your preferences such as language settings, last-used game filters, and display preferences. These improve your experience but are not essential.
• Analytics cookies: Collect anonymized data about how visitors use em88.bio — which pages are visited, how long sessions last, and which games are most popular. This data is aggregated and not linked to individual players. Used to improve the em88 platform.
• Security cookies: Used for device fingerprinting and duplicate account detection. These are classified as legitimate-interest cookies tied to em88's fraud prevention obligations.

em88 does not use third-party advertising cookies or allow advertising networks to place tracking cookies on em88.bio. You may manage non-essential cookies through your browser settings. Disabling all cookies will prevent login functionality and is not recommended.

§ 8 Data Security

em88 implements the following technical and organizational security measures to protect your personal data:

• Encryption in transit: All data transmitted between your browser or app and em88 servers is encrypted using TLS 1.2 or higher (256-bit SSL).
• Encryption at rest: Sensitive personal data fields — including password hashes, KYC documents, and payment account identifiers — are encrypted in em88's database using industry-standard encryption algorithms.
• Access controls: Access to systems containing player personal data is restricted to authorized em88 personnel on a strict need-to-know basis. All internal access is logged and audited.
• Two-factor authentication: em88 internal systems require multi-factor authentication for all staff with access to personal data.
• Regular security testing: em88 conducts regular penetration testing and vulnerability assessments on its platform infrastructure.
• Incident response: em88 maintains a data breach response plan. In the event of a personal data breach that creates a real risk of serious harm to affected players, em88 will notify affected players and the National Privacy Commission within the timeframes required by the Data Privacy Act.

§ 9 Data Retention

em88 retains personal data only for as long as necessary for the purpose for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Active account data: Retained for the full duration of the account's active status plus a post-closure period as described below.
• Closed account data: Following account closure, em88 retains identity, KYC, and transaction records for a minimum of five (5) years as required by the Anti-Money Laundering Act and PAGCOR record-keeping regulations.
• Customer support communications: Retained for three (3) years from the date of the last support interaction, or longer if the communication is relevant to an ongoing dispute or legal matter.
• Technical logs (IP addresses, device data): Retained for twelve (12) months in rolling logs for security monitoring purposes.
• Marketing consent records: Retained for as long as the consent is active plus three (3) years following consent withdrawal, as evidence of the consent and its withdrawal.

When the applicable retention period expires, em88 securely deletes or anonymizes the relevant personal data. Anonymized, aggregated data may be retained indefinitely as it no longer constitutes personal data.

§ 10 Your Data Rights Under Philippine Law

Under the Data Privacy Act of 2012 (RA 10173), registered em88 players have the following rights in respect of personal data em88 holds about them:

To exercise any of the above rights, contact em88's Data Protection Officer at: [email protected] with the subject line "Data Privacy Request". em88 will respond within 30 calendar days of receiving a verified request. em88 may need to verify your identity before processing your request.

§ 11 Children & Minors

em88 is strictly for adults aged 21 years and above as required by Philippine PAGCOR regulations. em88 does not knowingly collect personal data from any person under the age of 21.

If em88 becomes aware that personal data has been collected from a person under 21 — whether through registration, browsing, or any other means — that data will be immediately deleted and the associated account (if any) will be permanently closed.

If you are a parent or guardian and believe your child has created an em88 account or that their personal data has been collected by em88, please contact em88 support immediately at [email protected] so that the data can be located and deleted.

§ 12 Changes to This Privacy Policy

em88 may update this Privacy Policy from time to time to reflect changes in how we process personal data, changes in Philippine data protection law, PAGCOR regulatory updates, or changes to the services we offer.

Material changes — meaning changes that meaningfully affect your rights or how we use your personal data — will be communicated to registered players via the email address or mobile number on record at least 14 days before the change takes effect.

Non-material changes (such as clarifications, corrections of typographical errors, or minor structural reorganization that does not alter the substance of the Policy) may be made without advance notice. The "Last updated" date at the top of this page will be revised on every update.

Your continued use of the em88 platform after a Privacy Policy update takes effect constitutes your acknowledgment of the updated Policy. If you do not accept the changes, you may request account closure in accordance with the em88 Terms and Conditions.

§ 13 Contact & Complaints

em88 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012.

For any privacy-related inquiries, data rights requests, or concerns about how em88 processes your personal data, please contact:

If you are not satisfied with em88's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent authority responsible for enforcing the Data Privacy Act and can be reached through official Philippine government channels.

em88 cooperates fully with NPC investigations and is committed to resolving all legitimate privacy complaints in a timely and transparent manner.