vvlj Privacy Policy — How We Handle Your Personal Data

1 Who We Are

vvlj operates the online gaming and sports betting platform accessible at vvlj.app. For the purposes of Philippine data privacy law, vvlj acts as the Personal Information Controller for all personal data collected through this platform and is responsible for ensuring that data is processed lawfully, fairly, and in accordance with this Privacy Policy.

This policy applies to all registered players, prospective players who initiate but do not complete registration, and visitors to the vvlj platform whose data is collected through cookies or analytics tools. It covers all personal information collected through the vvlj website, any associated mobile-optimised interface, and communications channels including email and support chat.

2 What Personal Data vvlj Collects

vvlj collects personal data across several categories. The specific data collected from you depends on how you interact with the platform — a visitor who never registers will have different data collected compared to a verified player who has made transactions.

vvlj does not collect sensitive personal information beyond what is listed above. In particular, vvlj does not collect information about racial or ethnic origin, political opinions, religious beliefs, health data (other than self-disclosed responsible gaming information), or biometric data.

3 Why vvlj Collects Your Personal Data

Every category of data vvlj collects serves a specific, identified purpose. We do not collect data speculatively or for purposes unrelated to running the platform. The primary purposes are:

• Account creation and management: To register your vvlj account, verify your identity, and maintain an accurate record of your account details and preferences.
• Payment processing: To process deposits and withdrawals in PHP ₱ through your chosen payment channel (GCash, Maya, bank transfer, or card) and to reconcile transaction records.
• Identity verification and compliance: To verify that you meet the minimum age and eligibility requirements to use vvlj, and to comply with anti-money laundering (AML) obligations and other applicable Philippine regulatory requirements.
• Platform operation and personalisation: To deliver game content, betting markets, and account features; to remember your preferences; and to improve the platform experience based on how it is actually used.
• Responsible gaming: To monitor account activity for patterns that may indicate problem gambling behaviour, to apply deposit and session limits you have set, and to enforce self-exclusion decisions you have made.
• Security and fraud prevention: To detect and investigate suspicious activity, prevent unauthorised account access, and protect both you and vvlj from fraud and abuse.
• Customer support: To respond to your queries, complaints, and requests through vvlj's support channels.
• Marketing communications (where consent is given): To send promotional offers, bonus notifications, and platform updates to players who have opted in to marketing communications. You can withdraw consent at any time through your account settings or by contacting support.
• Legal obligations: To maintain records required by Philippine law, respond to lawful requests from regulatory authorities, and comply with court orders.

4 Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, vvlj relies on the following legal bases to process your personal information:

• Contractual necessity: Processing your identity, contact, financial, and account activity data is necessary to fulfil the contractual relationship established when you register a vvlj account and agree to the Terms and Conditions.
• Compliance with a legal obligation: Identity verification, transaction record-keeping, and AML monitoring are required by Philippine law and regulation. Processing for these purposes is mandatory.
• Legitimate interests: Security monitoring, fraud detection, platform analytics, and responsible gaming monitoring are carried out based on vvlj's legitimate interest in operating a safe, secure, and compliant gaming platform — and in protecting players from financial harm.
• Consent: Marketing communications and the use of non-essential cookies are based on your freely given, informed, and specific consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Cookies and Tracking Technologies

vvlj uses cookies and similar technologies on the platform. Cookies are small text files stored on your device that help the platform function correctly, remember your preferences, and — where you have consented — collect analytics data to help improve the service.

The types of cookies used on vvlj include:

• Essential cookies: Required for the platform to function. These include session authentication cookies and security tokens. They cannot be disabled without breaking core platform functionality. No consent is required for essential cookies.
• Functional cookies: Remember your preferences — such as your preferred language, notification settings, and responsible gaming limits — so you do not need to re-enter them each session.
• Analytics cookies: Collect aggregated, anonymised data about how pages are used, which features are accessed, and how long sessions last. This data helps vvlj identify and fix problems and improve the platform. Analytics cookies require your consent.
• Marketing cookies: Only used where you have explicitly opted in to marketing communications from vvlj. These are not used to track you across third-party websites.

You can manage cookie preferences through the cookie settings panel on vvlj, or through your browser settings. Note that disabling essential cookies will prevent you from logging in and using the platform.

6 Who vvlj Shares Your Data With

vvlj does not sell your personal data. We share data only to the extent necessary to operate the platform, comply with legal obligations, and protect against fraud. Categories of recipients include:

• Payment processors: Your transaction data is shared with GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet, and card processing partners to process your deposits and withdrawals. These processors act under separate agreements and handle your data in accordance with their own privacy policies and applicable Philippine financial regulations.
• Identity verification providers: Third-party KYC (Know Your Customer) service providers may process your government-issued ID and related identity data to complete the verification required before withdrawals are processed. These providers operate under strict data processing agreements with vvlj.
• IT and infrastructure providers: Cloud hosting, database, and security service providers whose systems vvlj uses to operate the platform. These providers process data only as directed by vvlj and under binding data processing agreements.
• Regulatory authorities: vvlj will share data with Philippine government agencies, law enforcement, and regulators when required to do so by law, court order, or legitimate regulatory request. vvlj will not notify you of such disclosures where legally prohibited from doing so.
• Fraud prevention services: Data may be shared with industry fraud prevention databases to identify and block fraudulent activity, multi-accounting, and money laundering attempts. These services operate under strict access controls.

7 How Long vvlj Keeps Your Data

vvlj retains personal data only for as long as necessary for the purposes it was collected, or as required by Philippine law. In practice, this means:

• Active account data — retained for the full duration of your vvlj account being open and active.
• Transaction and financial records — retained for a minimum of five years from the date of the transaction, as required by Philippine AML regulations. This applies even after account closure.
• Identity verification documents — retained for a minimum of five years from account closure, or longer if required by ongoing regulatory proceedings.
• Responsible gaming records (including self-exclusion decisions) — retained for a minimum of five years from the end of the exclusion or restriction period, to prevent re-registration attempts during active exclusion periods.
• Support communications — retained for three years from the date of the communication, to support dispute resolution and quality assurance.
• Analytics and platform usage data — retained in aggregated, anonymised form indefinitely; identifiable usage data is retained for up to two years.
• Marketing consent records — retained for as long as your account is active or until you withdraw consent, whichever is earlier.

When data reaches the end of its retention period, vvlj securely deletes or anonymises it so that it can no longer be linked to you as an individual.

8 How vvlj Protects Your Data

vvlj implements technical and organisational measures appropriate to the risk level of the data processed. These measures are reviewed and updated as the threat landscape and technology evolve. Current security practices include:

• Encryption in transit: All data transmitted between your device and the vvlj platform is encrypted using TLS (Transport Layer Security). This applies to login sessions, payment requests, and all other platform communications.
• Encryption at rest: Sensitive data stored in vvlj's systems — including identity documents and financial transaction records — is encrypted at rest using industry-standard algorithms.
• Access control: Internal access to personal data is restricted to employees and contractors who need it to perform their job functions. Access is logged and reviewed. Staff who handle personal data are trained in data protection obligations.
• Account authentication: vvlj uses secure authentication methods for player accounts and requires identity verification before processing withdrawals or making changes to sensitive account details.
• Vulnerability management: vvlj performs regular security assessments and promptly addresses identified vulnerabilities in its systems and infrastructure.
• Incident response: vvlj maintains documented procedures for identifying, containing, and reporting data security incidents. In the event of a breach affecting your data, vvlj will notify you and the National Privacy Commission as required under the Data Privacy Act.

9 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by vvlj. These rights are available to all registered players and can be exercised by contacting vvlj at support@vvlj.app.

To exercise any of these rights, contact vvlj at support@vvlj.app with the subject line "Data Subject Request." Include your registered account email address and a description of the right you wish to exercise. vvlj will acknowledge your request within three business days and respond substantively within thirty days, or inform you if a longer period is required.

10 Children's Privacy

vvlj is strictly for adults. No person under the minimum legal age for gambling under Philippine law may register an account, access any vvlj service, or use the platform in any capacity. vvlj does not knowingly collect personal data from minors.

If vvlj becomes aware that personal data has been collected from a minor — whether through fraudulent registration or other means — the account will be immediately suspended, any deposited funds returned to the payment source pending investigation, and the data deleted to the extent permitted by law. Any associated account activity may be reported to relevant authorities.

If you believe a minor has used or is attempting to use a vvlj account, please contact support immediately at support@vvlj.app. Keep all devices and payment applications used to access vvlj secured and away from anyone who does not meet the minimum age requirement.

11 Cross-Border Data Transfers

Some of vvlj's service providers — including cloud infrastructure and IT security partners — may process data on servers located outside the Philippines. Where such transfers occur, vvlj ensures that appropriate safeguards are in place to protect your personal data to a standard at least equivalent to Philippine data privacy requirements.

Safeguards for cross-border transfers may include contractual clauses in data processing agreements with the recipient, or reliance on the recipient's certification under an approved data protection framework. vvlj will provide further information about specific cross-border transfers on request.

12 Updates to This Privacy Policy

vvlj may update this Privacy Policy from time to time to reflect changes in our data practices, the law, or the platform itself. When material changes are made, we will notify registered players through the contact details on file — typically by email — before the updated policy takes effect. The revised policy will be published at vvlj.app/privacy-policy with an updated effective date.

Continued use of the vvlj platform after notification of an update constitutes your acceptance of the revised Privacy Policy. If you do not agree with changes to this policy, you may request account closure and withdrawal of any available balance by contacting support.

We recommend reviewing this policy periodically — not only when you receive a notification — so you remain informed about how vvlj handles your data. Significant changes will always be communicated directly; minor editorial or clarifying changes may not trigger a direct notification.

13 Contact vvlj About Privacy

If you have questions about this Privacy Policy, want to exercise a data subject right, or need to report a data privacy concern, contact the vvlj data privacy team:

If you are not satisfied with vvlj's response to a data privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC) through the NPC's official complaints process. Contact details for the NPC are publicly available through Philippine government channels.