chattg Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") describes how chattg ("chattg," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes the personal data of individuals ("you," "your," or "Data Subject") who access or use the chattg online gaming platform accessible at chattg.cam, including all associated subdomains, mobile interfaces, and related services (collectively, the "Platform").

This Policy applies to all personal data processed in connection with your use of the Platform, whether you are a registered Player, a visitor browsing the Platform without an account, or a person who contacts chattg customer support. It does not apply to third-party websites, applications, or services that may be linked from or integrated with the Platform, each of which operates under its own privacy practices.

This Policy should be read alongside the chattg Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference and govern your broader relationship with chattg. In the event of any inconsistency between this Policy and those documents on a privacy-specific matter, this Policy shall prevail.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations issued by the National Privacy Commission of the Philippines, chattg is the Personal Information Controller in respect of all personal data processed through the Platform. This means chattg determines the purposes and means of the processing of your personal data.

Where chattg engages third-party service providers to process personal data on its behalf — such as payment processors, KYC verification providers, and customer support platforms — those providers act as Personal Information Processors and are bound by contractual obligations that restrict their use of your data to the specific purposes for which it was shared.

Contact details for privacy-related enquiries, including the exercise of your data subject rights, are provided in Section 16 of this Policy.

3 Categories of Personal Data We Collect

The categories of personal data collected by chattg depend on the nature of your interaction with the Platform. The following table summarises the main categories:

chattg does not intentionally collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act (such as health data, biometric data for purposes other than identity verification, or political opinions) unless it is strictly necessary for regulatory compliance purposes and a lawful processing ground exists.

4 How We Collect Your Personal Data

chattg collects personal data through the following means:

4.1 Directly from You

The majority of your personal data is provided directly by you when you register an account, complete KYC verification, make deposits or withdrawal requests, contact our support team, or update your account settings. This includes all identity, contact, financial, and KYC data described in Section 3.

4.2 Automatically During Platform Use

When you access and use the chattg Platform, we automatically collect technical data including your IP address, device identifiers, browser type and version, operating system, referring URLs, pages visited, session duration, and gameplay activity logs. This data is collected through server logs, cookies, and similar tracking technologies described further in Section 9.

4.3 From Third-Party Service Providers

chattg may receive personal data about you from third-party providers who support Platform operations, including:

• Payment processors (GCash, Maya, InstaPay, BancNet) who confirm the outcome of deposit and withdrawal transactions.
• KYC and identity verification services that process your government ID documents and return a verification result.
• Fraud detection and anti-money laundering screening services that cross-reference your identity against watchlists and adverse media databases.
• Analytics providers who aggregate anonymised usage data to help chattg improve Platform performance.

5 Legal Bases for Processing

chattg processes your personal data only where a lawful basis exists under the Data Privacy Act of 2012. The applicable legal bases are as follows:

• Contractual Necessity: Processing your identity, contact, financial, and gaming activity data is necessary to perform the contract established when you register an account — including verifying your eligibility, enabling deposits and withdrawals, and providing gaming services.
• Legal Obligation: chattg is required by Philippine law — including the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and applicable PAGCOR regulations — to collect, process, and retain certain categories of your personal data for regulatory compliance, AML screening, and reporting purposes.
• Legitimate Interests: Where not overridden by your privacy rights, chattg processes technical and gaming activity data on the basis of its legitimate interests in maintaining Platform security, preventing fraud, improving service quality, and personalising your gaming experience in ways you would reasonably expect.
• Consent: Where chattg relies on your consent as the legal basis for processing — principally for direct marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal. See Section 14 for details on managing marketing preferences.

6 How We Use Your Personal Data

chattg uses your personal data for the following specific purposes:

• Account creation and management: registering and maintaining your chattg account, verifying your identity, processing login authentication, and enabling account security features such as two-factor authentication.
• KYC and regulatory compliance: verifying that you meet the 21+ age requirement, confirming your identity in accordance with AMLC regulations, screening your identity against national and international watchlists, and maintaining records required by Philippine gaming regulators.
• Payment processing: facilitating GCash, Maya, bank transfer, and other deposit and withdrawal transactions; verifying payment account ownership; and maintaining financial records for accounting and tax compliance.
• Provision of gaming services: enabling your access to slots, live casino, sports betting, bingo, and all other games on the Platform; recording game session data; administering bonuses; and resolving gaming disputes.
• Responsible gaming: monitoring gaming patterns to identify potential problem gambling behaviours; enforcing deposit limits, self-exclusion periods, and other protective measures you have set; and complying with responsible gaming obligations under Philippine regulations.
• Customer support: responding to enquiries, complaints, and account requests submitted via live chat or email.
• Security and fraud prevention: detecting, investigating, and preventing unauthorised account access, payment fraud, money laundering, bonus abuse, collusion, and other prohibited activities.
• Platform improvement and analytics: analysing aggregated and anonymised usage patterns to improve Platform performance, game selection, and user experience.
• Marketing and promotions: sending you information about chattg bonuses, promotions, new game launches, and other offers — subject to your marketing preferences and consent where required. See Section 14.

7 Data Sharing & Third-Party Disclosure

chattg does not sell your personal data to third parties. We disclose your personal data only in the following circumstances:

7.1 Service Providers (Processors)

chattg shares personal data with carefully selected third-party service providers who process data solely on our behalf and under our documented instructions. These providers include: payment processors (GCash/Maya infrastructure providers, BancNet), KYC and identity verification platforms, fraud detection and AML screening services, cloud hosting and data storage providers, customer support software vendors, and email communication platforms. All processors are contractually bound to implement appropriate data security measures and are prohibited from using your data for any purpose beyond the specific service they provide to chattg.

7.2 Game Content Providers

Certain game providers — including Evolution Gaming, Pragmatic Play, and other certified studios — may receive limited gameplay session data necessary for game delivery, dispute resolution, and RNG audit purposes. This data does not include your full identity details unless required for regulatory reasons.

7.3 Regulatory and Law Enforcement Authorities

chattg is legally required to disclose personal data to the Anti-Money Laundering Council (AMLC), National Privacy Commission (NPC), PAGCOR, and other competent Philippine authorities upon receipt of a valid legal request, court order, or subpoena. chattg will generally not notify you of such disclosures where prohibited by law from doing so.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a substantial part of chattg's business assets, your personal data may be transferred to the successor entity as part of that transaction, subject to equivalent privacy protections and notification to you where required by Philippine law.

8 Data Retention

chattg retains your personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods imposed by Philippine law and regulatory requirements:

• KYC and identity verification records: A minimum of five (5) years following account closure, as required by the AMLC and applicable PAGCOR regulations.
• Financial transaction records: A minimum of five (5) years from the date of each transaction, in line with AML obligations and BIR record-keeping requirements.
• Gaming activity records: Retained for the duration of your account and for a minimum of two (2) years following account closure, for responsible gaming monitoring and dispute resolution purposes.
• Customer support communications: Retained for three (3) years from the date of the last interaction, to support dispute resolution and continuous service improvement.
• Marketing preferences and consent records: Retained for the duration of your account and for two (2) years following account closure as evidence of consent or opt-out.

Following the expiry of the applicable retention period, personal data will be securely deleted, anonymised, or pseudonymised in accordance with chattg's data disposal procedures.

9 Cookies & Tracking Technologies

chattg uses cookies and similar tracking technologies (including web beacons and local storage) to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for Platform operation, including session authentication, security token management, and load balancing. These cannot be disabled without significantly impairing your ability to use the Platform.
• Functional Cookies: Remember your preferences — such as language settings, responsible gaming tool configurations, and last-visited game lobby — to provide a more personalised experience across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform to help chattg identify and fix technical issues and improve the user experience. Data collected by analytics cookies does not identify you personally.
• Marketing Cookies: Used to measure the effectiveness of chattg's promotional campaigns. Only placed where you have given consent in accordance with your marketing preferences.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect core Platform functionality. Detailed cookie information is available in the Platform's cookie management interface.

10 Data Security

chattg implements a layered approach to data security combining technical, organisational, and procedural safeguards proportionate to the sensitivity of the data processed and the risks presented by Platform operations. Key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the chattg Platform, equivalent to the encryption standard used by Philippine banking institutions.
• Encryption at rest for sensitive personal data including KYC documents and financial records stored on chattg servers.
• Access controls and role-based permissions limiting internal access to personal data to staff whose roles require it, with all access events logged for audit purposes.
• Two-factor authentication options for player accounts and mandatory for administrative access to production systems.
• Regular security assessments including penetration testing and vulnerability scanning of the Platform infrastructure.
• Incident response procedures to detect, contain, and notify the National Privacy Commission and affected Data Subjects of personal data breaches within the timeframes required by the Data Privacy Act.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by chattg. You may exercise any of these rights by contacting our Data Protection Officer using the details in Section 16:

chattg will respond to verified data subject rights requests within fifteen (15) business days of receipt. We may need to verify your identity before processing a request. Some rights are subject to limitations — for instance, the right to erasure does not apply to data chattg is legally required to retain under AML or PAGCOR regulations.

12 International Data Transfers

The chattg Platform is primarily operated to serve Filipino players in the Philippines. However, certain service providers engaged by chattg — including cloud infrastructure providers, game content studios, and fraud detection services — may process data on servers located outside the Philippines.

Where such international transfers occur, chattg ensures that adequate safeguards are in place in accordance with Section 21 of the Data Privacy Act and NPC Circular No. 16-01, including: contractual clauses requiring the recipient to apply data protection standards equivalent to Philippine law; verification that the recipient jurisdiction provides adequate data protection under NPC determinations; or obtaining your explicit consent to the transfer where required.

You may request information about specific international data transfers affecting your personal data by contacting our Data Protection Officer.

13 Minors and Age Restriction

chattg strictly prohibits the use of the Platform by persons under the age of twenty-one (21) years. The Platform is not directed at, and chattg does not knowingly collect personal data from, individuals under 21 years of age.

Age verification is conducted as a mandatory part of the KYC process for all registered Players. Where chattg discovers or has reasonable grounds to believe that an account has been registered by a minor, the account will be immediately suspended, gaming activity will be suspended pending investigation, and any funds held may be subject to regulatory review before return to the account holder.

14 Marketing Communications

With your consent, chattg may send you promotional communications about new games, deposit bonuses, cashback offers, tournaments, and other Platform features via email, SMS, or push notifications. Your marketing preferences can be managed at any time from your chattg account settings dashboard.

You may also opt out of marketing communications at any time by:

• Clicking the unsubscribe link included in any marketing email sent by chattg.
• Replying "STOP" to any marketing SMS received from chattg.
• Updating your notification preferences directly in your chattg account settings.
• Contacting the chattg Data Protection Officer at [email protected] with an opt-out request.

Please note that opting out of marketing communications does not affect transactional messages — such as deposit confirmations, withdrawal notifications, account security alerts, or mandatory regulatory communications — which will continue to be sent as part of the Platform service.

15 Amendments to This Privacy Policy

chattg reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance from the National Privacy Commission, changes to Platform operations, or improvements to our data practices.

When material changes are made to this Policy, chattg will notify registered Players by email to the address on file and/or by displaying a prominent notice on the Platform. The "Last updated" date at the top of this Policy will be revised to reflect the date of the most recent amendment.

Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not agree with any amendment, you must cease using the Platform and may request account closure in accordance with the chattg Terms & Conditions.

16 Contact Information & Data Protection Officer

chattg has appointed a Data Protection Officer (DPO) in accordance with Section 21(c) of the Data Privacy Act of 2012. The DPO is responsible for overseeing compliance with this Policy, the Data Privacy Act, and related NPC regulations, and serves as the primary point of contact for all data subject rights requests and privacy enquiries.

For complaints that cannot be resolved directly with chattg, you may escalate to the National Privacy Commission of the Philippines at privacy.gov.ph.