vvll Casino
Privacy Policy

1 Data Controller Identity

The data controller responsible for the personal data collected through the vvll Casino platform is vvll Casino, the operator of the website located at vvll.app. As data controller, vvll determines the purposes and means of processing your personal data, and is responsible for ensuring that such processing is carried out in accordance with Republic Act No. 10173 and its Implementing Rules and Regulations.

vvll Casino has designated a Data Protection Officer (DPO) in accordance with NPC requirements. The DPO is responsible for overseeing vvll's data protection strategy, ensuring compliance with the DPA, and serving as the primary point of contact for data subjects and the National Privacy Commission. Contact details for the DPO are provided in Section 13 of this Policy.

2 Data We Collect

vvll Casino collects personal data in the following categories, depending on how you interact with the platform:

2.1 Registration Data. When you create a vvll account, we collect your legal full name, date of birth, nationality, residential address, Philippine mobile number, and email address. This information is required to establish and maintain your account.

2.2 Identity Verification (KYC) Data. To comply with Philippine AML regulations and our licensing obligations, we may collect copies of government-issued identification documents such as your Philippine passport, SSS ID, UMID, PhilSys National ID, driver's licence, or PRC ID, as well as proof of address documents such as a recent utility bill or bank statement.

2.3 Financial Data. We collect transaction records including deposit amounts, withdrawal amounts, payment method details (e.g., GCash mobile number, Maya account reference, bank account name), and transaction timestamps. We do not store full bank account numbers or card numbers on our servers.

2.4 Gaming Activity Data. We maintain records of your gameplay history, game selections, wager amounts, session durations, bonus usage, and win/loss outcomes. This data is used for account management, fraud prevention, and regulatory reporting.

2.5 Technical & Device Data. We automatically collect technical information when you access the vvll platform, including your IP address, device type, operating system, browser type and version, screen resolution, and session timestamps. This data is collected via server logs and cookies as described in Section 8.

2.6 Communication Data. If you contact vvll Casino's customer support team via live chat, email, or any other channel, we retain records of that correspondence, including the content of your messages and the resolution of any reported issues.

2.7 Responsible Gaming Data. Where you use vvll's responsible gaming tools — such as deposit limits, self-exclusion requests, or reality check settings — we record those preferences and any associated documentation to ensure compliance and protect your wellbeing.

3 Lawful Basis for Processing

vvll Casino processes your personal data only where a lawful basis exists under the Data Privacy Act of 2012. The applicable lawful bases for our processing activities are:

• Contractual Necessity: Processing your registration data, KYC information, financial transactions, and gaming activity is necessary to perform the contract between you and vvll Casino (i.e., to operate your player account and deliver gaming services).
• Legal Obligation: Certain processing — particularly identity verification, transaction records, and AML reporting — is required to comply with Republic Act No. 9160 (Anti-Money Laundering Act), PAGCOR regulations, and National Privacy Commission issuances.
• Legitimate Interest: vvll processes technical and device data for fraud detection, platform security, and abuse prevention. These interests are balanced against your data protection rights and do not override them.
• Consent: Where vvll Casino sends direct marketing communications (promotional emails, SMS notifications about bonuses and new games), we do so on the basis of your freely given, specific, and informed consent. You may withdraw this consent at any time.

4 How We Use Your Data

vvll Casino uses the personal data we collect for the following specific purposes:

• Account Management: Creating, operating, verifying, and maintaining your vvll Casino player account, including processing login requests and account recovery.
• Identity Verification: Conducting KYC checks to confirm your identity, age (21+ verification), and eligibility to hold a vvll account, as required by Philippine law.
• Payment Processing: Facilitating deposits and withdrawals through GCash, Maya, BPI, BDO, Metrobank, and other supported Philippine payment channels. Verifying that all payments are made to and from accounts registered in your own name.
• Fraud Prevention & Security: Detecting and preventing fraudulent transactions, multiple account registrations, collusion, bonus abuse, money laundering, and other prohibited activities using automated systems and manual review.
• Regulatory Compliance: Fulfilling vvll's obligations under the Anti-Money Laundering Act, PAGCOR regulations, and NPC directives, including mandatory reporting of suspicious transactions to the AMLC.
• Customer Support: Responding to your queries, resolving disputes, and processing complaints submitted to vvll Casino's support team.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviours, administering self-exclusion requests, and enforcing deposit and session limits set by you.
• Service Improvement: Analysing aggregated and anonymised usage data to improve the vvll platform, personalise game recommendations, and develop new features.
• Marketing Communications: Sending you information about vvll Casino promotions, new games, and special offers — only where you have consented to receive such communications.

5 Data Sharing & Disclosure

vvll Casino does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, only to the extent strictly necessary:

• Payment Processors: GCash (Mynt – Globe Fintech Innovations), Maya (Voyager Innovations), BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions.
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged by vvll to verify the authenticity of identity documents.
• Game Studio Partners: Game software providers whose titles appear in the vvll Casino library may receive anonymised session data necessary for game operation and technical support. These providers do not receive directly identifying personal data.
• 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, court order, or regulatory directive.
• Professional Advisers: Legal counsel, auditors, and financial advisers engaged by vvll Casino, where disclosure is necessary for the provision of professional services and subject to confidentiality obligations.
• Business Successors: In the event of a merger, acquisition, or transfer of vvll Casino's operations to a successor entity, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and the privacy practices of the successor entity.

All third parties with whom vvll Casino shares personal data are required to maintain appropriate data protection standards consistent with the Data Privacy Act and to process your data only for the specified purpose of the disclosure.

6 Data Retention

vvll Casino retains your personal data only for as long as is necessary to fulfil the purposes set out in this Policy, or as required by applicable Philippine law. The following retention periods apply:

• Active Account Data: Retained for the duration of your active vvll Casino account relationship, plus a minimum of five (5) years following account closure.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of the last transaction or account closure, in compliance with RA 9160 (Anti-Money Laundering Act).
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by AMLC regulations.
• Customer Support Communications: Retained for three (3) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution or legal proceedings.
• Marketing Consent Records: Retained for the duration of the marketing relationship, plus three (3) years following withdrawal of consent or account closure, to demonstrate compliance with consent requirements.
• Technical & Log Data: Typically retained for twelve (12) months from collection, unless a longer retention period is required for fraud investigations or regulatory purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be attributed to any individual data subject.

7 Security Measures

vvll Casino implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the vvll platform is encrypted using TLS 1.2 or higher. Sensitive data at rest — including KYC documents and financial records — is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. vvll staff access to production data is governed by role-based access controls, multi-factor authentication, and comprehensive audit logging.
• Infrastructure Security: The vvll platform is hosted on secure cloud infrastructure with firewall protection, intrusion detection systems, and regular vulnerability scanning.
• Data Breach Response: vvll Casino maintains a documented data breach response procedure. In the event of a personal data breach that poses a real risk of serious harm to affected data subjects, vvll will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected users without undue delay.
• Staff Training: All vvll Casino staff who handle personal data receive regular training on data protection obligations, secure data handling practices, and the requirements of RA 10173.

8 Cookies & Tracking Technologies

vvll Casino uses cookies and similar tracking technologies on the vvll.app website to support platform functionality, improve your experience, and analyse usage patterns. The categories of cookies we use are:

• Strictly Necessary Cookies: Essential for the operation of the vvll platform. These cookies enable core functions such as user authentication, session management, and security features. They cannot be disabled without significantly impairing platform functionality.
• Functional Cookies: Used to remember your preferences such as your preferred language, game display settings, and responsible gaming tool configurations. These cookies enhance your experience but are not essential.
• Analytics Cookies: Used to collect aggregated, anonymised data about how visitors navigate the vvll platform, which pages they visit most frequently, and which features they use. This information helps us improve the platform and identify technical issues.
• Session Replay Cookies: In limited contexts, vvll may use session recording technology to capture anonymised user interactions on the platform for the purpose of identifying usability issues and improving the interface.

You may control non-essential cookie preferences through your browser settings. Please note that disabling certain functional cookies may affect the availability of some vvll Casino features. vvll does not use cookies to serve third-party advertising or to track your activity on websites outside of vvll.app.

9 Your Privacy Rights

As a data subject under the Philippine Data Privacy Act, you are entitled to exercise the following rights in relation to your personal data held by vvll Casino:

To exercise any of these rights, please contact vvll Casino's Data Protection Officer using the details in Section 13. We will acknowledge your request within five (5) business days and will endeavour to resolve it within thirty (30) calendar days. We may need to verify your identity before processing certain requests.

10 Minors & Age Restriction

vvll Casino is strictly for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from persons under 21 years of age. The collection of date of birth during registration, and the KYC age verification process, are specifically designed to prevent underage individuals from accessing the platform.

If vvll Casino becomes aware that personal data has been collected from an individual who is under 21 years of age, we will immediately:

• Suspend and close the affected account;
• Return any real-money balance to the verified payment source;
• Securely delete the personal data of the underage individual, subject only to data retention obligations required by law; and
• Report the incident to the relevant regulatory authority where required.

11 Cross-Border Data Transfers

In the course of operating the vvll Casino platform, your personal data may be transferred to, stored in, or processed by servers or service providers located outside the Philippines — for example, where vvll uses cloud infrastructure providers or international game studio technical support teams.

Any cross-border transfer of personal data by vvll Casino is subject to the following safeguards, consistent with NPC Circular 16-01 and the DPA's provisions on cross-border data flows:

• Transfers are made only to recipients located in countries with an adequate level of data protection, or where vvll has put in place appropriate contractual safeguards (such as data processing agreements incorporating NPC-approved standard contractual clauses).
• Recipient entities are contractually obligated to process transferred personal data only for the specified purpose of the transfer and to maintain security standards equivalent to those required under Philippine law.
• vvll Casino maintains a register of all cross-border data transfers and the safeguards applied to each, which is available for review by the NPC upon request.

12 Changes to This Policy

vvll Casino reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, updates to Philippine privacy law, NPC guidance, or changes to the vvll platform. All updates will be posted on this page with a revised "Last Updated" date at the top of the Policy.

Where a proposed change is material — meaning it significantly affects the nature of data collected, the purposes for which it is used, or the rights available to you — vvll Casino will provide advance notice via the email address registered to your account at least fourteen (14) days before the change takes effect.

Your continued use of the vvll Casino platform following the publication of a revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with the revised Policy, you should close your account and cease using the platform before the effective date of the change.

13 Contact & DPO Details

If you have questions, concerns, or requests relating to this Privacy Policy or to your personal data held by vvll Casino, please contact our Data Protection Officer. We are available 24 hours a day, 7 days a week, and will respond to all privacy-related inquiries within five (5) business days.

Data Protection Officer — vvll Casino
Platform: vvll.app
Email: [email protected] (plain text — not a clickable link)
Operating Hours: 24/7, Philippine Standard Time (UTC+8)

If you are not satisfied with vvll Casino's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC accepts complaints from data subjects whose rights under RA 10173 have been violated. Information on the NPC complaints process is available through official Philippine government channels.