Privacy Policy

1. Introduction

Welcome to ggfap. This Privacy Policy ("Policy") is issued by ggfap ("ggfap", "we", "us", "our") and governs the collection, use, storage, disclosure, and protection of personal information obtained from individuals ("you", "your", "Player") who access or use the ggfap platform, including our website at ggfap.cam, any associated mobile-optimized interfaces, and all related services (collectively, the "Platform").

ggfap is committed to protecting the privacy of all Filipino players and users of our Platform. This Policy has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and related issuances of the National Privacy Commission (NPC).

By accessing the Platform, creating an account, or otherwise using any of our services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with any part of this Policy, please discontinue your use of the Platform immediately.

2. Personal Data We Collect

ggfap collects personal information that is necessary for the lawful operation of our gaming platform and the delivery of our services to Filipino players. The categories of personal data we collect include, but are not limited to, the following:

2.1 Registration and Account Data

• Full legal name as appearing on a valid Philippine government-issued identification document
• Date of birth (to verify you are 21 years of age or older, as required by applicable gaming regulations)
• Mobile telephone number (Philippine format)
• Email address
• Username and encrypted account password
• Residential address within the Philippines
• Nationality and citizenship status

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine Passport, Driver's License, SSS/GSIS ID, UMID, Voter's ID, PhilSys National ID)
• Proof of billing address or proof of residence
• Selfie or liveness verification image for biometric KYC purposes
• Source of funds documentation where required by PAGCOR or Anti-Money Laundering Act (AMLA) obligations

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and methods used (GCash, Maya, BPI, BDO, UnionBank, 7-Eleven, USDT TRC20, Coins.ph)
• E-wallet account identifiers (e.g., registered GCash or Maya mobile numbers) as provided by you during transaction processing
• Bank account details provided for withdrawal processing, subject to our secure handling procedures
• Bonus claims, promotion participation history, and wager records

2.4 Technical and Usage Data

• IP address and approximate geolocation data
• Device type, operating system, browser type and version
• Session duration, pages visited, games played, bet amounts, and gameplay logs
• Login timestamps, session history, and access logs
• Cookie identifiers and similar tracking technology data (see Section 7)

2.5 Communications Data

• Support chat transcripts and email communications with our customer service team
• Records of complaints, disputes, and their resolutions
• Responses to surveys, promotions, and feedback requests

3. How We Use Your Personal Data

ggfap processes your personal information for the following purposes:

• Account creation and management: To register and maintain your ggfap account, verify your identity, and provide access to our Platform and services.
• Age verification and compliance: To confirm that you meet the minimum age requirement of 21 years as mandated by Philippine gaming regulations before allowing access to real-money gaming.
• Platform operation and service delivery: To process deposits and withdrawals, credit winnings, apply bonuses and promotions, and maintain accurate account balances in Philippine Peso (PHP).
• Regulatory and legal compliance: To fulfill our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA) of the Philippines, the Data Privacy Act of 2012, and other applicable laws and regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorized access, money laundering, and other illegal or harmful activities on our Platform.
• Responsible gaming: To monitor player behavior for signs of problem gambling, enforce self-exclusion requests, and apply deposit limits, session limits, or cooling-off periods requested by players or required by regulation.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Marketing and promotions: To send you relevant offers, bonus notifications, and platform updates where you have provided your consent or where we have a legitimate interest in doing so. You may opt out at any time.
• Platform improvement: To analyze usage patterns, improve game offerings, optimize user experience, and conduct internal reporting and analytics.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, ggfap processes your personal data on the following lawful bases:

• Contractual necessity: Processing is necessary for the performance of the contract between you and ggfap (i.e., your account terms and service agreement), including enabling deposits, gameplay, and withdrawals.
• Legal obligation: Processing is required to comply with our legal and regulatory obligations, including PAGCOR licensing conditions, AMLA reporting requirements, and NPC data privacy obligations.
• Legitimate interests: Processing is carried out in pursuit of ggfap's legitimate business interests — such as fraud prevention, platform security, and business analytics — where those interests are not overridden by your rights and interests.
• Consent: For certain processing activities, particularly marketing communications, we rely on your freely given, specific, informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing based on consent prior to its withdrawal.

5. Data Sharing and Disclosure

ggfap does not sell, rent, or commercially trade your personal data to third parties. We may share your personal information only in the following limited circumstances:

• Payment processors and e-wallet providers: We share necessary transaction data with payment processing partners (such as GCash and Maya operators, banks, and cryptocurrency networks) strictly to process your deposits and withdrawals.
• Identity verification (KYC) providers: We engage third-party KYC service providers to assist in verifying the identity and age of new account holders. These providers are contractually bound to process data solely for KYC purposes.
• Regulatory authorities: We are obligated to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and other competent government authorities when required by law, court order, or regulatory directive.
• IT infrastructure and cloud service providers: We use third-party cloud and hosting service providers to operate our Platform. These vendors process data only on our instructions and under data processing agreements that bind them to appropriate security and confidentiality standards.
• Auditors and legal advisors: We may share data with our professional advisors (auditors, legal counsel, compliance consultants) under strict obligations of confidentiality as necessary for the operation of our business.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of ggfap's business, personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

6. Data Retention

ggfap retains your personal data for as long as is necessary to fulfill the purposes outlined in this Policy, subject to the following specific considerations:

• Active accounts: Personal data associated with an active ggfap account is retained for the duration of the account's existence plus any applicable legal retention periods thereafter.
• Closed or suspended accounts: Following account closure or suspension, ggfap is required under PAGCOR conditions and Philippine AMLA regulations to retain transaction records, KYC documentation, and account history for a minimum period of five (5) years from the date of the last transaction or account closure, whichever is later.
• Marketing data: Where you have consented to marketing communications, we retain your contact data for marketing purposes until you withdraw your consent or request erasure, subject to legal retention obligations.
• Technical logs: Server logs and technical access records are retained for security and audit purposes for periods consistent with industry standards and applicable regulatory requirements.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymized, or pseudonymized in accordance with established data disposal procedures.

7. Cookies and Tracking Technologies

ggfap uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device by your web browser. They help us operate the Platform effectively and improve your experience as a player.

• Strictly necessary cookies: These are required for the Platform to function properly, including maintaining your login session, remembering your preferences, and securing your account. These cannot be disabled without significantly impairing Platform functionality.
• Analytical/performance cookies: These cookies collect anonymized or aggregated data about how players use the Platform — which pages are visited most, how long sessions last, and where technical errors occur. This data is used solely to improve Platform performance.
• Functionality cookies: These remember your settings and preferences (such as language preference and bet display format) to provide a more personalized experience.
• Marketing cookies: Where you have given your consent, these cookies track your interaction with our Platform to help us deliver relevant promotional content. You may opt out of marketing cookies at any time through your browser settings or our cookie preference center.

Most web browsers allow you to control cookies through their settings. Please note that disabling certain cookies may affect the functionality of the ggfap Platform. For more information about managing cookies, refer to your browser's help documentation.

8. Data Security

ggfap implements a range of technical, organizational, and physical security measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• SSL/TLS encryption for all data in transit between your device and our servers
• Encryption of sensitive data at rest, including account credentials and financial records
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis
• Regular security audits, vulnerability assessments, and penetration testing by qualified third parties
• Multi-factor authentication (MFA) options for player account login security
• Continuous monitoring of systems for suspicious activity, intrusion attempts, and anomalies
• Staff training on data handling, privacy obligations, and security protocols

Despite these measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. If you have reason to believe that your ggfap account or personal data has been compromised, please contact our support team immediately.

9. 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 ggfap:

• Right to be informed: You have the right to be informed of what personal data we collect, why we collect it, and how it is used — as set out in this Policy.
• Right to access: You have the right to request a copy of the personal data ggfap holds about you, subject to reasonable verification of your identity.
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data. You may update certain account information directly through your ggfap account settings.
• Right to erasure: You have the right to request deletion of your personal data where there is no longer a lawful basis for its retention, subject to our legal and regulatory obligations to retain certain records (see Section 6).
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to assessment of whether our interests override yours in the specific context.
• Right to data portability: Where technically feasible and where processing is based on consent or contract, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: If you believe ggfap has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details in Section 13. We will respond to your request within thirty (30) days of receipt, or within such other timeframe as may be required by applicable law.

10. Children and Minors — Strict 21+ Policy

ggfap does not knowingly collect, process, or retain personal data from any individual under the age of 21. Our registration process includes mandatory age verification steps, and KYC procedures require submission of a valid government-issued ID confirming date of birth prior to full account activation and withdrawal privileges.

If ggfap becomes aware or has reasonable grounds to believe that a registered account belongs to an individual under 21 years of age, we will immediately suspend the account, conduct an investigation, forfeit any remaining balance in accordance with our Terms and Conditions, and permanently close the account. We will also take steps to delete any personal data collected from that individual to the extent permitted by law.

Parents and guardians are encouraged to take appropriate measures — including the use of parental control software — to prevent minors from accessing gambling websites. If you suspect that a minor has registered an account on ggfap, please contact our support team immediately.

11. International Data Transfers

ggfap's primary operations and data processing are centered on serving Filipino players within the Philippines. However, some of our technical infrastructure, third-party service providers, or cloud hosting facilities may be located outside the Philippines.

Where your personal data is transferred outside of the Philippines, ggfap ensures that such transfers are carried out in compliance with the Data Privacy Act of 2012 and NPC regulations, including by implementing appropriate contractual safeguards (such as standard contractual clauses) and by verifying that the destination country or recipient provides an adequate level of protection for personal data.

By using the ggfap Platform, you consent to the transfer of your personal data to jurisdictions outside the Philippines as described in this section, provided that such transfers are subject to appropriate safeguards.

12. Changes to This Privacy Policy

ggfap reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The updated Policy will be published on this page with a revised "Last Updated" date at the top.

Where changes to this Policy are material — meaning they significantly affect how we collect, use, or share your personal data — ggfap will provide additional notice, which may include a notice posted in your account dashboard or a communication sent to your registered email address or mobile number.

Your continued use of the ggfap Platform following the posting of any changes to this Privacy Policy constitutes your acceptance of those changes. If you do not agree with the revised Policy, you should stop using the Platform and may request account closure by contacting our support team.

13. Contact Us — Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by ggfap, please contact our designated Data Protection Officer (DPO) using the following details:

You also have the right to raise a concern or lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government website and offices in Manila.