goerya Privacy
Policy

1 Introduction

This Privacy Policy ("Policy") describes how goerya ("goerya," "we," "us," or "our"), operator of the online gaming platform at goerya.net, collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who register for and use the goerya Platform.

goerya is committed to protecting the privacy and personal data of its Players, particularly those located in the Philippines. Our data practices are designed to align with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering an Account on goerya or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. This Policy is to be read together with our Terms & Conditions.

2 Data Controller

For the purposes of applicable data privacy law, goerya acts as the Data Controller in respect of personal data collected from Players through the goerya Platform. As Data Controller, goerya determines the purposes and means by which your personal data is processed.

goerya also engages certain third-party service providers who act as Data Processors on our behalf — processing your data only on our instructions and for the specific purposes described in this Policy. All Data Processors engaged by goerya are contractually bound to process your data securely and in accordance with applicable data privacy law.

For all data privacy enquiries, requests, and complaints, you may contact goerya's designated Data Privacy Officer at: [email protected] — please include "Data Privacy" in the subject line of your message.

3 Information We Collect

goerya collects personal data from and about you through several channels. The categories of personal data we collect, and the contexts in which we collect them, are set out below.

3.1 Information You Provide Directly

• Registration Data: Full legal name, date of birth, gender, nationality, email address, mobile number, and residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, or Makati).
• KYC / Identity Verification Documents: Copies of government-issued photo ID (e.g., Philippine passport, SSS card, UMID, driver's licence, voter's ID), proof of address documents, and any selfie or video verification materials submitted during the identity verification process.
• Financial Data: Payment method details (e.g., GCash account number, PayMaya account reference, BPI/BDO/Metrobank/UnionBank account details) as required to process deposits and withdrawals. goerya does not store full card numbers or bank login credentials.
• Communications Data: Records of your correspondence with goerya's customer support team via email, live chat, or any other communication channel, including the content of messages sent and received.
• Responsible Gaming Data: Voluntary information you provide when using goerya's responsible gaming tools, such as self-exclusion requests, deposit limit preferences, and cooling-off period settings.

3.2 Information Collected Automatically

• Technical Data: IP address, device type, browser type and version, operating system, screen resolution, and referring URL collected when you access the Platform.
• Usage Data: Pages visited, features used, games played, session duration, bet history, game outcome history, and navigation patterns on the Platform.
• Cookie Data: Data collected through cookies and similar tracking technologies as described in Section 7 of this Policy.

4 How We Use Your Data

goerya uses the personal data it collects for the following specific purposes:

goerya will not use your personal data for any purpose that is incompatible with the purposes listed above without first providing you with appropriate notice and, where required by law, obtaining your consent.

5 Legal Basis for Processing

goerya processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 and applicable regulations:

• Contractual Necessity: Processing that is necessary to perform our contract with you — specifically, to operate your goerya Account, process your transactions, and provide you with access to the Platform's games and services.
• Legal Obligation: Processing that is necessary for goerya to comply with its legal obligations, including anti-money laundering regulations, age verification requirements, and reporting obligations to relevant Philippine regulatory authorities.
• Legitimate Interests: Processing undertaken to further goerya's legitimate business interests — such as fraud prevention, network and information security, and Platform analytics — where such interests are not overridden by your data privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw your consent at any time by updating your communication preferences in your Account settings or by contacting support.

6 Sharing Your Data

6.1 Third-Party Service Providers. goerya shares your personal data with carefully selected third-party service providers who assist us in operating the Platform. These include: payment processing partners (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank and their respective technology providers); identity verification and KYC service providers; game software providers; cloud hosting and infrastructure providers; customer support platform providers; and fraud detection and analytics services. All such providers are contractually obligated to process your data only on goerya's instructions and to maintain appropriate security standards.

6.2 Regulatory and Law Enforcement Authorities. goerya may disclose your personal data to Philippine regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, court order, or other legal process. goerya will, where permitted by law, endeavour to notify you of such a disclosure.

6.3 Business Transfers. In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of goerya's assets, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and of any material change to the terms under which your data is held.

6.4 What We Do Not Do. goerya does not sell, rent, lease, or otherwise transfer your personal data to third parties for their own independent marketing or advertising purposes. Period.

7 Cookies & Tracking Technologies

goerya uses cookies and similar tracking technologies (such as web beacons and local storage objects) on the Platform. These technologies serve the following functions:

• Strictly Necessary Cookies: Essential for the Platform to function — including maintaining your login session, remembering your language and currency preferences, and enabling core security features. These cookies cannot be disabled without significantly impairing your experience.
• Functional Cookies: Allow the Platform to remember your preferences and settings — such as your preferred game categories, responsible gaming tool configurations, and display settings — to provide a more personalised experience.
• Analytics Cookies: Used by goerya to understand how Players interact with the Platform — including which pages are visited most frequently, how long sessions last, and where players encounter difficulties. This data is used in aggregate to improve the Platform.
• Marketing Cookies: Used, with your consent, to deliver relevant promotional communications and to measure the effectiveness of goerya's marketing campaigns. You may opt out of marketing cookies via your Account settings.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent certain features of the goerya Platform from functioning correctly. goerya's cookie policy is reviewed and updated periodically; the current version is always available at goerya.net/privacy-policy.

8 Data Retention

goerya retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC Data: Retained for a minimum of five (5) years following Account closure, in compliance with applicable anti-money laundering record-keeping requirements.
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of each transaction, as required by applicable Philippine financial regulations.
• Customer Support Communications: Retained for three (3) years following the resolution of the relevant support interaction.
• Marketing Consent Records: Retained for as long as goerya sends you marketing communications, and for a reasonable period thereafter as evidence of consent.
• Technical and Usage Logs: Retained for up to twelve (12) months in aggregate or anonymised form for Platform analytics purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with goerya's internal data disposal procedures.

9 Your Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by goerya. To exercise any of these rights, please contact us at [email protected] with "Data Privacy Request" in the subject line. goerya will respond to all valid requests within thirty (30) calendar days.

If you believe goerya has not adequately addressed your data privacy concerns, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10 Data Security

goerya implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-Bit SSL/TLS Encryption for all data transmitted between your device and goerya's servers;
• Encryption at rest for sensitive personal data and financial records stored in goerya's databases;
• Role-based access controls ensuring that only authorised goerya personnel with a legitimate business need can access personal data;
• Multi-factor authentication requirements for internal systems that hold personal data;
• Regular security audits and penetration testing conducted by independent third-party security specialists;
• Staff data protection training delivered on a regular basis to all employees who handle personal data;
• Incident response procedures to detect, contain, and respond to personal data breaches in a timely manner.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, goerya will notify the National Privacy Commission and, where required, affected Players, within the timeframes prescribed by applicable law.

11 Children & Minors

The goerya Platform is strictly for adults aged 21 years and above. goerya does not knowingly collect or process personal data relating to persons under the age of 21. Registration by persons under the age of 21 is strictly prohibited under goerya's Terms & Conditions.

If goerya becomes aware that personal data relating to a person under the age of 21 has been collected through the Platform, goerya will promptly delete such data and close the associated Account. Any Real Money Balance held in such an Account will be returned to the originating payment method; any winnings will be forfeited.

If you have reason to believe that a minor has registered on or accessed the goerya Platform, please notify us immediately at [email protected].

12 Third-Party Links

The goerya Platform may contain links to third-party websites or services (for example, payment provider portals). This Privacy Policy applies solely to the goerya Platform and does not extend to any third-party websites or services. goerya is not responsible for the privacy practices or content of any third-party websites, even if accessed through a link on the goerya Platform.

We recommend that you review the privacy policy of any third-party website you visit before providing personal information to that website.

13 Changes to This Policy

goerya reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or business operations. Material changes to this Policy will be communicated to registered Players via email to the address associated with their Account and/or via a notice on the goerya Platform, no less than seven (7) days prior to the changes taking effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the goerya Platform following any update to this Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, please stop using the Platform and contact support to close your Account.

goerya recommends that you review this Privacy Policy periodically to remain informed about how your personal data is being protected and used.

14 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or goerya's data practices, please contact us through the following channels:

• Email: [email protected] — please include "Data Privacy" in your subject line
• Live Chat: Available 24/7 through the goerya Platform
• Live Agents: Available 8 AM – 12 MN Philippine Standard Time (PST)

goerya will acknowledge receipt of data privacy requests within two (2) business days and will provide a substantive response within thirty (30) calendar days. Complex requests may require additional time, in which case goerya will inform you of the expected timeline.

If you are not satisfied with goerya's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.