Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how penjoy ("Company," "we," "us," "our") collects, uses, processes, stores, discloses, and protects the personal information and data of users ("you," "your," "User," "Player") who access or use our online gaming platform located at https://penjoy.cam, including all associated websites, mobile applications, software, and services (collectively, the "Platform"). This Policy applies to all personal information collected through the Platform and explains your rights regarding your personal data under the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations in the Republic of the Philippines.

By creating an account, accessing the Platform, or using any penjoy services, you expressly acknowledge that you have read, understood, and consent to the collection, use, processing, storage, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with this Policy, you must immediately cease all use of the Platform and refrain from providing any personal information to penjoy. We are committed to protecting your privacy and implementing robust security measures to safeguard your personal data against unauthorized access, use, disclosure, alteration, or destruction.

2. Information We Collect

2.1 Information You Provide to Us

When you register for a penjoy account, we collect personal information that you voluntarily provide, including but not limited to:

• Identity Information: Full legal name, date of birth, nationality, gender, and government-issued identification details required for age verification and KYC (Know Your Customer) compliance
• Contact Information: Residential address, email address, mobile phone number, and alternative contact details
• Account Credentials: Username, password, security questions and answers, and authentication data
• Financial Information: Payment method details including GCash mobile number, PayMaya account information, bank account numbers, transaction history, deposit and withdrawal records, and billing information
• Verification Documents: Copies of government-issued identification cards (such as Philippine passport, driver's license, UMID, postal ID), proof of address documents (utility bills, bank statements), and selfie photographs for identity verification purposes
• Communication Data: Information contained in communications you send to our customer support team via email, live chat, telephone, or other channels

2.2 Information Automatically Collected

When you access or use the penjoy Platform, we automatically collect certain technical and usage information through cookies, web beacons, log files, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, unique device identifiers, mobile network information, and hardware specifications
• Connection Information: IP address, internet service provider (ISP), geographic location data derived from IP address, time zone settings, and connection timestamps
• Usage Information: Pages visited, features accessed, games played, bet history, time spent on pages, clickstream data, referring and exit pages, and search queries entered on the Platform
• Gaming Activity: Bets placed, games played, betting patterns, win/loss records, bonus usage, loyalty program activity, and gaming preferences
• Performance Data: Platform errors, system diagnostics, loading times, and technical performance metrics used to improve Platform functionality

2.3 Information from Third Parties

We may receive information about you from third-party sources, including payment processors (GCash, PayMaya, banks), identity verification services, fraud prevention agencies, credit reference agencies, and publicly available databases. This information is used to verify your identity, prevent fraud, comply with legal obligations, and enhance platform security.

3. How We Use Your Information

penjoy collects and processes your personal information for the following legitimate purposes:

• Account Management: Creating and maintaining your account, verifying your identity, authenticating login credentials, and managing account settings and preferences
• Service Provision: Processing deposits and withdrawals, facilitating gaming activities, settling bets, distributing winnings, managing bonuses and promotions, and providing customer support services
• Legal and Regulatory Compliance: Verifying that you meet age requirements (21+ years), complying with PAGCOR regulations, conducting KYC and AML (Anti-Money Laundering) checks, preventing fraud and financial crimes, and responding to legal requests from authorities
• Security and Fraud Prevention: Detecting and preventing fraudulent activity, unauthorized access, multiple account creation, bonus abuse, collusion, money laundering, and other prohibited activities that violate our Terms and Conditions
• Platform Improvement: Analyzing usage patterns, testing new features, conducting research and statistical analysis, optimizing platform performance, and enhancing user experience
• Marketing Communications: Sending promotional emails, SMS messages, push notifications, and in-platform messages about bonuses, promotions, new games, and platform updates (subject to your marketing preferences and consent)
• Responsible Gaming: Monitoring gambling behavior, identifying problem gambling patterns, implementing deposit limits and self-exclusion measures, and providing responsible gaming resources
• Dispute Resolution: Investigating and resolving disputes, complaints, or issues between you and penjoy, including bet settlement disputes and account-related concerns

4. How We Share Your Information

penjoy does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients under strict confidentiality obligations:

4.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including payment processing (GCash, PayMaya, banks), identity verification services, fraud detection and prevention, customer support software providers, email and SMS communication platforms, hosting and server providers, data analytics services, and marketing service providers. These service providers have access to personal information only as necessary to perform their functions and are contractually obligated to maintain confidentiality and security standards equivalent to those described in this Policy.

4.2 Legal and Regulatory Authorities

We may disclose your personal information to government authorities, law enforcement agencies, regulatory bodies (including PAGCOR), courts, and other authorized entities when required by law, legal process, subpoena, court order, or government request. We may also disclose information to comply with anti-money laundering regulations, prevent fraud and financial crimes, protect our legal rights, enforce our Terms and Conditions, or respond to threats to public safety or platform security.

4.3 Business Transfers

In the event of a merger, acquisition, corporate reorganization, sale of assets, bankruptcy, or other business transaction involving penjoy, your personal information may be transferred to the successor entity or acquiring party, subject to equivalent privacy protections and obligations under this Policy.

4.4 Consent-Based Sharing

We may share your information with third parties when you have provided explicit consent for such sharing, including participation in affiliate programs, referral bonuses, or third-party promotional offers.

5. Data Security Measures

penjoy implements comprehensive technical, administrative, and physical security measures to protect your personal information against unauthorized access, use, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard 256-bit SSL/TLS encryption protocols. Sensitive data stored in our databases is encrypted at rest using advanced encryption algorithms.
• Access Controls: Strict access controls ensure that only authorized personnel with legitimate business needs can access personal information. Access is granted on a need-to-know basis and subject to confidentiality agreements.
• Authentication Systems: Multi-factor authentication, secure password requirements, session timeout mechanisms, and account monitoring systems protect against unauthorized account access.
• Network Security: Firewalls, intrusion detection systems, anti-malware software, DDoS protection, and vulnerability scanning protect our infrastructure from external threats and cyber attacks.
• Regular Audits: We conduct regular security audits, penetration testing, and vulnerability assessments to identify and remediate potential security weaknesses.
• Secure Development: Our software development practices follow secure coding standards, including code reviews, security testing, and secure deployment procedures.
• Data Backup: Regular automated backups ensure data availability and recovery capabilities in the event of system failure or disaster.
• Employee Training: All employees with access to personal information undergo regular privacy and security training and are bound by strict confidentiality obligations.

While we implement robust security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your personal information. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us of any unauthorized access or security breach.

6. Data Retention

penjoy retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory requirements, resolve disputes, enforce our agreements, and maintain business records. Specific retention periods vary based on the type of information and legal obligations:

• Account Information: Retained for the duration of your active account plus seven (7) years after account closure to comply with PAGCOR regulations, tax requirements, and financial record-keeping obligations
• Transaction Records: Retained for ten (10) years to comply with anti-money laundering regulations and financial reporting requirements
• Verification Documents: Retained for seven (7) years after account closure or the last transaction, whichever is later
• Communication Records: Retained for three (3) years for customer service quality assurance and dispute resolution purposes
• Marketing Data: Retained until you withdraw consent or request deletion, subject to legal retention requirements

After retention periods expire, we securely delete or anonymize your personal information in accordance with our data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for statistical analysis and research purposes.

7. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

• Right to Access: You may request access to the personal information we hold about you and obtain a copy of such information in a structured, commonly used format.
• Right to Rectification: You may request correction of inaccurate or incomplete personal information. You can update certain information directly through your account settings.
• Right to Erasure: You may request deletion of your personal information, subject to legal retention requirements and legitimate business needs. Note that deletion may result in account closure and inability to access platform services.
• Right to Object: You may object to processing of your personal information for marketing purposes or based on legitimate interests. You can opt out of marketing communications at any time.
• Right to Data Portability: You may request transfer of your personal information to another service provider in a structured, machine-readable format, where technically feasible.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission of the Philippines if you believe your privacy rights have been violated.

To exercise your privacy rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within thirty (30) days. We may request additional information to verify your identity before processing requests.

8. Cookies and Tracking Technologies

penjoy uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience, analyze platform usage, personalize content, and deliver targeted advertising. Cookies are small text files stored on your device that allow us to recognize your browser and capture certain information.

8.1 Types of Cookies We Use

• Essential Cookies: Necessary for platform operation, authentication, security, and accessing features. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collect information about how you use the platform, pages visited, and errors encountered. This data helps us improve platform performance.
• Functionality Cookies: Remember your preferences, language settings, and customization choices to enhance user experience.
• Marketing Cookies: Track your browsing activity to deliver relevant advertisements and promotional content. These cookies may be set by third-party advertising partners.

You can control cookie settings through your browser preferences. Disabling cookies may affect platform functionality and your ability to access certain features. Most browsers allow you to refuse cookies or delete existing cookies. Please note that if you disable cookies, you may not be able to access all platform features or your experience may be limited.

9. Third-Party Links and Services

The penjoy Platform may contain links to third-party websites, services, or applications not operated by penjoy. This Privacy Policy does not apply to third-party websites or services. We are not responsible for the privacy practices, content, or security of third-party sites. We encourage you to review the privacy policies of any third-party websites or services before providing personal information. Third-party payment processors (GCash, PayMaya) operate under their own privacy policies and terms of service.

10. International Data Transfers

Your personal information is primarily stored and processed on servers located in the Philippines. However, we may transfer your information to service providers and affiliates located in other countries for the purposes described in this Policy. When we transfer personal information internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with Philippine data protection laws, including standard contractual clauses, adequacy decisions, or other lawful transfer mechanisms.

11. Children's Privacy

The penjoy Platform is intended exclusively for individuals who are at least twenty-one (21) years of age or older. We do not knowingly collect personal information from individuals under the age of twenty-one (21). If we become aware that we have collected personal information from a person under the legal gambling age, we will take immediate steps to delete such information and terminate the associated account. If you believe we have collected information from a minor, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

penjoy reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes to this Policy, we will notify you by posting the updated Policy on the Platform with a revised "Last Updated" date and, where required by law, by sending email notifications to registered users or displaying prominent notices on the Platform. Your continued use of the Platform after changes become effective constitutes acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information.

13. Contact Information

If you have questions, concerns, complaints, or requests regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer:

Data Protection Officer
penjoy
Email: [email protected]
Customer Support: [email protected]

We will acknowledge receipt of privacy-related inquiries within forty-eight (48) hours and provide a substantive response within thirty (30) days. For complaints regarding data protection violations, you may also contact the National Privacy Commission of the Philippines.