dreamph Privacy Policy

1. Introduction

dreamph ("we", "us", "our") is committed to protecting the privacy and personal data of all users of the dreamph online gaming platform accessible at dreamph.org ("the Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information provided by users ("you", "your") in connection with your use of the dreamph Platform.

This Privacy Policy is issued in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. dreamph is committed to upholding the rights of Filipino data subjects and adhering to the principles of transparency, legitimate purpose, and proportionality in all data processing activities.

This Privacy Policy should be read together with the dreamph Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Personal Data We Collect

dreamph collects personal data that is necessary to provide you with a safe, secure, and compliant gaming experience. The categories of personal data we collect include:

• Registration Data: Full legal name, date of birth, gender, nationality, residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati), email address, and Philippine mobile number.
• Identity Verification (KYC) Data: Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID), proof of address documents, and selfie photographs for identity verification purposes.
• Financial Data: Payment method details (GCash account number, PayMaya/Maya account, bank account details for BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, or linked debit card details), transaction history, deposit and withdrawal records.
• Account Activity Data: Login history, game play history, betting records, session duration, bonus usage, and account preferences.
• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Communications Data: Records of your communications with dreamph support, including live chat transcripts, email correspondence, and any feedback or complaints submitted.
• Responsible Gaming Data: Self-exclusion requests, deposit limit settings, session limit preferences, and any information provided in connection with responsible gaming support.

3. How We Use Your Personal Data

dreamph uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your dreamph account, including verifying your identity and eligibility to use the Platform.
• Service Delivery: To provide you with access to dreamph games, process deposits and withdrawals, and deliver the features and functionality of the Platform.
• Regulatory Compliance: To comply with our obligations under Philippine law, including the Data Privacy Act of 2012, Anti-Money Laundering Act (AMLA), and applicable PAGCOR regulations. This includes conducting KYC verification, transaction monitoring, and reporting to relevant authorities where required.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance.
• Responsible Gaming: To implement and monitor responsible gaming tools such as deposit limits, session limits, and self-exclusion, and to identify players who may be at risk of problem gambling.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent to receive such communications. You may withdraw this consent at any time.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the dreamph Platform.
• Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the Platform.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide you with access to the dreamph Platform and its services.
• Legal Obligation: Processing is necessary to comply with our legal obligations under Philippine law, including KYC requirements, anti-money laundering obligations, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided those interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing and Disclosure

dreamph does not sell your personal data to third parties. We may share your personal data with the following categories of recipients in the circumstances described:

• Service Providers: Third-party vendors who provide services on our behalf, including payment processors (GCash, PayMaya, Philippine banks), identity verification providers, IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law or regulation.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of dreamph's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.
• Professional Advisers: Lawyers, auditors, and other professional advisers where necessary for the conduct of our business, subject to confidentiality obligations.

6. Cookies and Tracking Technologies

dreamph uses cookies and similar tracking technologies to enhance your experience on the Platform. The types of cookies we use include:

• Essential Cookies: Necessary for the Platform to function correctly, including session management, authentication, and security features. These cookies cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, helping us identify areas for improvement.
• Preference Cookies: Used to remember your settings and preferences, such as language and display options.
• Marketing Cookies: Used to deliver relevant promotional content. These cookies are only set where you have provided consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the dreamph Platform. For more information on managing cookies, refer to your browser's help documentation.

7. Data Retention

dreamph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account data and transaction records are retained for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• KYC verification documents are retained for a minimum of five (5) years following the end of the business relationship.
• Communications data (support interactions) is retained for three (3) years.
• Marketing consent records are retained for the duration of the consent and for three (3) years thereafter.

Upon expiry of the applicable retention period, dreamph will securely delete or anonymise your personal data in accordance with our data disposal procedures.

8. Data Security

dreamph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption of data in transit using industry-standard TLS/SSL protocols.
• Encryption of sensitive data at rest, including financial and identity verification data.
• Access controls limiting personal data access to authorised personnel on a need-to-know basis.
• Regular security assessments and penetration testing of the dreamph Platform.
• Staff training on data protection and information security obligations.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, dreamph will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Data Privacy 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 dreamph:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of the personal data dreamph holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• 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) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the dreamph Data Protection Officer at [email protected]. dreamph will respond to all data subject requests within thirty (30) days of receipt.

10. Children's Privacy

The dreamph Platform is strictly intended for persons aged 21 years and above. dreamph does not knowingly collect personal data from individuals under the age of 21. If dreamph becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account suspended.

If you are a parent or guardian and believe that a person under 21 in your care has provided personal data to dreamph, please contact us immediately at [email protected].

11. International Data Transfers

dreamph primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines, dreamph ensures that such transfers are subject to appropriate safeguards in accordance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

Such safeguards may include contractual clauses approved by the National Privacy Commission, adequacy decisions, or other legally recognised transfer mechanisms. dreamph will not transfer your personal data to countries that do not provide an adequate level of data protection without implementing appropriate safeguards.

12. Third-Party Links

The dreamph Platform may contain links to third-party websites or services. dreamph is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to the dreamph Platform.

13. Updates to This Privacy Policy

dreamph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, dreamph will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this page. Your continued use of the dreamph Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. We recommend reviewing this page periodically.

14. Contact and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or dreamph's data processing practices, please contact our Data Protection Officer:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Response Time: dreamph aims to respond to all privacy-related enquiries within 30 days of receipt.

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by dreamph.