niceph Privacy Policy

01 Introduction

niceph ("niceph," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the niceph online gaming platform ("Platform"). This Privacy Policy ("Policy") describes how niceph collects, uses, stores, discloses, and protects personal information provided by or collected from players and visitors ("you" or "your") in connection with your use of the Platform.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). By registering an account on niceph or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

02 Data Controller

niceph is the data controller responsible for your personal data collected through the Platform. As data controller, niceph determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data protection law.

niceph has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection legislation. Contact details for the DPO are provided in Section 16 of this Policy.

03 Data We Collect

niceph collects the following categories of personal data from players and Platform visitors:

Identity Data:

• Full legal name as it appears on your government-issued identification
• Date of birth
• Gender
• Nationality
• Government-issued ID number (e.g., passport, SSS, UMID, PhilSys)
• Photograph or selfie submitted for identity verification

Contact Data:

• Residential address (including barangay, city/municipality, province)
• Email address
• Mobile phone number

Financial Data:

• GCash or PayMaya account number (mobile number)
• Bank account details (account name, account number, bank name) for withdrawal processing
• Debit card details (card number, expiry date — stored in tokenized form only)
• Transaction history including deposits, withdrawals, and gaming activity

Technical Data:

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Session logs including login timestamps and session duration
• Cookies and similar tracking technologies (see Section 10)

Gaming Data:

• Game history, bet amounts, win/loss records
• Responsible gaming settings and self-exclusion status
• Bonus and promotion participation history

Communications Data:

• Records of your communications with niceph customer support
• Feedback, complaints, and dispute records

04 How We Collect Data

niceph collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs.
• Third-party sources: Identity verification data from licensed KYC service providers; fraud prevention data from anti-money laundering screening services; payment data from GCash, PayMaya, and banking partners.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with licensing compliance or investigations.

05 How We Use Your Data

niceph processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your niceph player account, including identity verification and KYC compliance.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver customer support.
• Legal and regulatory compliance: To comply with anti-money laundering (AML) obligations, PAGCOR reporting requirements, tax obligations, and other applicable Philippine laws.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: To monitor gaming behavior, enforce responsible gaming limits, and 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 consented to receive such communications.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features and performance of the niceph Platform.
• Dispute resolution: To investigate and resolve complaints, disputes, and legal claims.

06 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, niceph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you (i.e., the niceph Terms & Conditions), including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing conditions, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and business analytics, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

07 Data Sharing

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

• Game providers: Licensed third-party game suppliers who provide the games available on the niceph Platform. These providers receive only the data necessary to deliver game services.
• Payment processors: GCash, PayMaya, and banking partners who process your deposits and withdrawals. Financial data is shared only as required to complete transactions.
• KYC and identity verification providers: Licensed third-party services that assist niceph in verifying player identities and screening against AML watchlists.
• Fraud prevention services: Third-party providers that help niceph detect and prevent fraudulent activity on the Platform.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine government agencies, where disclosure is required by law or regulatory obligation.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by niceph, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or part of niceph's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

08 International Transfers

Some of niceph's third-party service providers, including game suppliers and technical infrastructure providers, may be located outside the Philippines. Where your personal data is transferred to a country that does not provide an equivalent level of data protection to the Philippines, niceph will implement appropriate safeguards to protect your data, including contractual clauses approved by the National Privacy Commission or equivalent mechanisms.

By using the niceph Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described in this section.

09 Data Retention

niceph retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML and PAGCOR record-keeping requirements.
• Transaction and gaming records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Customer support communications: Retained for three (3) years from the date of the communication, or longer if related to an ongoing dispute or legal claim.
• Marketing consent records: Retained for the duration of your consent and for three (3) years thereafter as evidence of consent.
• Technical and log data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.

When personal data is no longer required for any of the above purposes, niceph will securely delete or anonymize it in accordance with applicable data protection standards.

10 Cookies & Tracking Technologies

niceph uses cookies and similar tracking technologies on the Platform to enhance your user experience, remember your preferences, and analyze how the Platform is used. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that prevent fraudulent use. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics cookies: Used to collect anonymized information about how visitors use the Platform, including pages visited, time spent, and navigation paths. This data helps niceph improve Platform performance and content.
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of niceph marketing campaigns. These cookies are only set with your consent.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the niceph Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

11 Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by niceph:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data niceph holds about you, together with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update certain account information directly through your niceph account settings.
• 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 niceph's 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 niceph's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that niceph has processed your personal data in violation of the DPA.

To exercise any of the above rights, please contact the niceph Data Protection Officer using the contact details provided in Section 16. niceph will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

12 Children's Privacy

The niceph Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. niceph does not knowingly collect personal data from individuals under the age of 21.

If niceph becomes aware that personal data has been collected from a person under 21 years of age, niceph will immediately suspend the relevant account, delete the personal data, and report the matter to the appropriate regulatory authority where required. If you believe that a minor has registered on the niceph Platform, please contact our support team immediately.

13 Security Measures

niceph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the niceph Platform
• Encryption of sensitive data at rest, including financial data and identity documents
• Multi-factor authentication (MFA) for player accounts and internal systems
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular penetration testing and vulnerability assessments conducted by independent security specialists
• Real-time fraud detection and anomaly monitoring systems
• Secure data centers with physical access controls and environmental safeguards
• Regular staff training on data protection and information security obligations

While niceph takes all reasonable steps to protect your personal data, no security system is completely impenetrable. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, niceph will notify the National Privacy Commission and affected data subjects in accordance with the DPA's breach notification requirements.

14 Third-Party Links

The niceph Platform may contain links to third-party websites or services, including game provider portals and payment gateway interfaces. niceph is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through the Platform.

This Policy applies solely to personal data collected by niceph through the niceph Platform. It does not apply to data collected by third-party websites or services, even if accessed via a link on the niceph Platform.

15 Policy Updates

niceph reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, niceph will notify registered players via email or in-platform notification at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the niceph Platform after the effective date of any update constitutes your acceptance of the revised Policy. If you do not agree to the updated Policy, you must cease using the Platform and may request account closure by contacting our support team.

16 Contact & DPO

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by niceph, please contact our Data Protection Officer:

• Data Protection Officer: niceph DPO Office
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the niceph Platform
• Response Time: Data subject requests will be acknowledged within 72 hours and resolved within 30 days

If you are not satisfied with niceph's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.