Scope of this Policy: This Privacy Policy applies to all personal data collected by ambergame through the ambergame.one website, any associated mobile web interface, and all communications between ambergame and its registered Players. It covers data collected from account registration through to account closure. By registering an ambergame account and using our services, you acknowledge that you have read and understood this Policy.
1 Introduction
ambergame takes the privacy of its players seriously. As a platform serving Filipino players under PAGCOR regulatory oversight, we are bound by the requirements of Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).
This Privacy Policy is written in plain English to ensure that every Filipino player — whether based in Manila, Cebu, Davao, Iloilo, or elsewhere in the archipelago — can clearly understand how ambergame handles personal information. We have deliberately avoided impenetrable legal language where clarity is equally achievable.
The collection and processing of personal data at ambergame is not arbitrary. Every piece of information we request serves a specific, documented purpose: verifying your identity, processing your transactions, complying with anti-money laundering obligations, improving the platform experience, and protecting both you and ambergame from fraud. We do not collect data we don't need. We do not sell your personal information to advertisers.
2 Data Controller
For the purposes of the Data Privacy Act of 2012 and this Policy, the data controller responsible for your personal information is ambergame, operating the online gaming platform at ambergame.one under PAGCOR regulatory authorization.
As data controller, ambergame determines the purposes and means of processing your personal data. ambergame has appointed a Data Protection Officer (DPO) responsible for overseeing data protection compliance and serving as the primary point of contact for player data requests. Contact details for the DPO are provided in Section 16 of this Policy.
Your relationship with ambergame: When you create an account on ambergame, you enter into a direct relationship with ambergame as the data controller. Third-party game providers, payment processors, and technology partners who access your data do so as data processors acting under instruction from ambergame and bound by data processing agreements consistent with Philippine law.
3 Personal Data We Collect
The following categories of personal data are collected by ambergame in the course of operating the platform and providing services to registered Players:
| Category | Specific Data Points | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, government ID number and type | KYC verification |
| Contact Data | Philippine mobile number, email address (if provided) | Registration |
| Account Data | Account ID, login credentials (encrypted), account preferences, VIP tier | Registration & ongoing use |
| Financial Data | Deposit/withdrawal history, transaction amounts, payment method identifiers (e.g., GCash mobile number), wallet balance | All financial transactions |
| Gaming Activity | Game sessions, bet amounts, wins, losses, game history, session duration | During platform use |
| Technical Data | IP address, device type, browser type and version, operating system, session tokens | All platform access |
| KYC Documents | Scanned or photographed copies of government-issued Philippine ID documents | Identity verification |
| Communication Data | Support chat transcripts, SMS communication records, feedback and complaint records | Customer service interactions |
| Responsible Gaming | Deposit limits set, self-exclusion requests, cooling-off periods, problem gambling assessments | When tools are used |
ambergame does not collect biometric data (fingerprints, facial recognition data) except where expressly consented to for enhanced security verification and only where permitted under Philippine law. We do not collect sensitive personal information relating to health, political affiliations, or religious beliefs.
4 How We Collect Your Data
ambergame collects personal data through the following channels:
Information you provide directly to ambergame when you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, or respond to any ambergame survey or promotion. This is the primary source of personal data for ambergame registered Players.
Technical data is collected automatically whenever you access the ambergame platform, including your IP address, device identifiers, browser characteristics, and session activity. This data is generated by standard server-side logging systems and browser-based analytics tools and is collected without requiring any active input from you.
When you make a deposit or withdrawal via GCash, Maya, BPI, BDO, UnionBank, 7-Eleven CLiQQ, or USDT TRC20, the relevant payment processor provides ambergame with transaction confirmation data sufficient to credit your account or complete your withdrawal. ambergame does not receive your full GCash or bank account credentials — only the minimum transaction confirmation data necessary to process the payment.
During KYC verification, ambergame may use third-party identity verification technology to assist in validating the authenticity of Philippine government-issued identification documents. Such third parties operate under data processing agreements with ambergame and are not permitted to use your data for any independent purpose.
5 Purpose & Legal Basis for Processing
ambergame processes your personal data only where a valid legal basis under the Data Privacy Act of 2012 exists. The following table sets out the purposes for which we process personal data and the corresponding legal basis:
- Account creation and management — necessary for the performance of the contract between you and ambergame;
- Processing deposits and withdrawals — necessary for the performance of the contract and compliance with financial regulations;
- KYC identity and age verification — necessary for compliance with PAGCOR regulations and the Anti-Money Laundering Act (AMLA) of the Philippines;
- Prevention of fraud, money laundering, and prohibited activities — legitimate interests of ambergame and compliance with Applicable Law;
- Responsible gaming monitoring and intervention — legitimate interests of ambergame and compliance with PAGCOR responsible gaming requirements;
- Customer support and dispute resolution — necessary for the performance of the contract and legitimate interests of ambergame;
- Platform security and abuse prevention — legitimate interests of ambergame;
- Platform improvement and analytics — legitimate interests of ambergame, where anonymised or aggregated data is used;
- Marketing and promotional communications — your consent, provided at registration or subsequently via account preferences, which may be withdrawn at any time.
Consent Withdrawal: Where ambergame processes your data on the basis of your consent (primarily for marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. It does not affect ambergame's ability to process your data for other purposes where a different legal basis applies (such as contractual necessity or legal compliance).
6 Sharing of Personal Data
ambergame does not sell, rent, or trade your personal data to third parties for their independent commercial purposes. Personal data is shared with third parties only in the following circumstances:
ambergame engages third-party service providers who process personal data on ambergame's behalf under binding data processing agreements. These include: payment processing providers (GCash, Maya, banks), identity verification technology providers, cloud hosting infrastructure providers, customer support platform providers, and anti-fraud technology providers. All such providers are contractually prohibited from using your data for any purpose beyond providing services to ambergame.
Licensed game studios (including PG Soft, Pragmatic Play, Jili, JDB Gaming, and Evolution) receive session data necessary to operate the games you play. This typically includes your ambergame player identifier, session token, currency, and bet/win records. Game providers do not receive your name, mobile number, payment details, or KYC documents.
ambergame is legally required to share information with PAGCOR, the Anti-Money Laundering Council (AMLC) of the Philippines, and other competent Philippine authorities upon lawful request or as required by statute. Such disclosures may occur without prior notice to you where required by law. ambergame cooperates fully with all lawful regulatory inquiries.
In the event of a merger, acquisition, or sale of ambergame's business assets, your personal data may be transferred to the acquiring entity as part of that transaction, subject to the same data protection commitments set out in this Policy. You will be notified of any such transfer via the contact details on your ambergame account.
7 Cookies & Tracking Technologies
ambergame uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:
- Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without impacting your ability to use ambergame.
- Functional Cookies: Remember your preferences such as language settings, saved login state on trusted devices, and display preferences. Disabling these may reduce platform convenience.
- Analytics Cookies: Collect anonymised data about how Players use the ambergame platform — which pages are visited, how long sessions last, and where errors occur. This data helps ambergame improve the user experience. No individual player is identified in analytics reports.
- Security & Fraud Prevention Cookies: Used to detect unusual account behaviour, identify potentially fraudulent sessions, and protect the integrity of the platform.
ambergame does not use third-party advertising or behavioral targeting cookies. Your gaming habits and player profile are not shared with advertising networks.
Managing Cookies: You can control cookie behaviour through your browser settings. Disabling strictly necessary cookies will prevent you from logging in to ambergame. Most modern browsers (Chrome, Safari, Firefox) provide per-site cookie management. Refer to your browser's help documentation for specific instructions.
8 Data Retention
ambergame retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following retention guidelines:
- Active account data — retained for the duration of the account relationship plus a minimum of 5 years following account closure, as required by Philippine anti-money laundering regulations;
- KYC documents and identity records — retained for a minimum of 5 years from the date of the last transaction on the account, in accordance with PAGCOR and AMLC requirements;
- Financial transaction records — retained for 7 years from the transaction date, as required under Philippine financial regulations;
- Customer support communications — retained for 3 years from the date of the last support interaction;
- Technical and server logs — retained for 12 months from the date of generation, unless a longer period is required for an active security investigation or legal matter;
- Marketing consent records — retained for the duration of the consent plus 3 years to evidence compliance.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where data is anonymised and can no longer be attributed to an identifiable individual, the anonymised dataset may be retained indefinitely for statistical purposes.
9 Data Security
ambergame implements a multi-layered security framework to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Key measures include:
- 256-bit SSL/TLS encryption for all data transmitted between your device and ambergame servers — the same standard used by Philippine commercial banks;
- Encryption at rest for all stored personal data, including KYC documents and financial records, using AES-256 encryption;
- Password hashing — your account password is never stored in plaintext; it is hashed using a modern cryptographic algorithm with per-user salting;
- Access controls — internal access to personal data is restricted on a strict need-to-know basis with role-based access management, multi-factor authentication for system access, and comprehensive access audit logging;
- Regular security assessments — including penetration testing and vulnerability scanning conducted by independent cybersecurity specialists;
- Incident response procedures — ambergame maintains documented procedures for detecting, responding to, and reporting data security incidents consistent with NPC notification requirements.
Security Incident Notification: In the event of a data security incident that poses a real risk of serious harm to affected Players, ambergame will notify the National Privacy Commission within 72 hours of discovery, and will notify affected individuals without undue delay, consistent with the requirements of the Data Privacy Act and NPC Circular 16-03.
10 Your Data Rights
As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ambergame. You may exercise these rights by contacting ambergame's Data Protection Officer using the details in Section 16.
Right to Access
You have the right to request a copy of the personal data ambergame holds about you, together with information about how it is being processed and the legal basis for each processing activity. ambergame will respond to access requests within 30 calendar days.
Right to Rectification
If any personal data ambergame holds about you is inaccurate or incomplete, you have the right to request correction. Contact support or update your account profile directly for standard account data. KYC document corrections require re-submission through the verification process.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing was unlawful. This right is subject to ambergame's legal obligations to retain certain data under PAGCOR and AMLC requirements — data subject to mandatory regulatory retention periods cannot be deleted.
Right to Object
You may object to the processing of your personal data where ambergame relies on legitimate interests as the legal basis, including for marketing communications. Where you object to marketing, ambergame will cease processing your data for that purpose immediately upon receiving your request.
Right to Data Portability
Where technically feasible, you have the right to receive a copy of the personal data you provided to ambergame in a structured, commonly used, machine-readable format. This right applies to data processed on the basis of your consent or contract performance.
Right to Lodge a Complaint
If you believe ambergame has breached its data protection obligations, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). ambergame encourages Players to contact us first to attempt resolution, but acknowledges your right to go directly to the NPC.
11 Children's Privacy
No Minors Permitted: ambergame does not knowingly collect personal data from any individual under the age of 21. Under PAGCOR regulations, participation in real-money online gaming is restricted to individuals aged 21 and above. If ambergame discovers that personal data has been collected from an individual below the age of 21, the relevant account will be immediately suspended, all funds will be held pending review, and the personal data will be deleted unless retention is required for regulatory or investigative purposes.
If you are a parent or guardian and you believe that a person under 21 in your care has registered an ambergame account, please contact our Data Protection Officer immediately using the details in Section 16. ambergame will investigate and take appropriate action within 72 hours of receiving such a report.
12 Cross-Border Data Transfers
Some of the third-party service providers used by ambergame — including cloud infrastructure providers and game studios — may process personal data in jurisdictions outside the Philippines. Where such cross-border transfers occur, ambergame ensures that:
- The recipient country has been assessed as providing an adequate level of data protection, or
- Appropriate contractual safeguards (data processing agreements with standard contractual clauses) are in place to protect your data, consistent with the requirements of the Data Privacy Act and NPC guidelines on cross-border data transfers.
A list of the jurisdictions to which data may be transferred and the safeguards in place is available upon request from ambergame's Data Protection Officer.
13 Marketing Communications
ambergame sends promotional communications — including welcome bonus notifications, reload offers, cashback alerts, and VIP programme updates — to Players who have consented to receive such communications. Consent is obtained at registration and may be updated at any time through your account notification settings.
ambergame sends marketing communications via SMS to your registered Philippine mobile number. We do not send unsolicited marketing emails to addresses not associated with an ambergame account registration.
To stop receiving promotional SMS messages from ambergame, you may:
- Update your notification preferences in your ambergame account settings;
- Reply STOP to any ambergame SMS, which will automatically opt your number out of marketing messages; or
- Contact ambergame support directly to request removal from the marketing list.
Opting out of marketing communications does not affect ambergame's ability to send you transactional messages related to your account — such as OTP codes, deposit confirmations, withdrawal notifications, or security alerts. These are sent on the basis of contractual necessity and cannot be opted out of while your account remains active.
14 Regulatory Disclosures & Legal Compliance
As a PAGCOR-regulated online gaming operator, ambergame is subject to specific data collection, retention, and reporting obligations under Philippine law. These obligations exist independently of this Privacy Policy and take precedence over any conflicting provision herein:
- PAGCOR Reporting: ambergame may be required to submit player account data, transaction records, and gaming activity reports to PAGCOR as a condition of its operating authorization. Players consent to such disclosures by registering an account.
- AMLC Reporting: Transactions meeting or exceeding threshold amounts defined under the Anti-Money Laundering Act (as amended) are reported to the Anti-Money Laundering Council. Suspicious transactions may be reported regardless of amount.
- Law Enforcement: ambergame will disclose personal data to Philippine law enforcement agencies in response to a valid court order, subpoena, or other lawful legal process. ambergame will not voluntarily disclose personal data to law enforcement beyond its legal obligations.
- National Privacy Commission: ambergame cooperates fully with the National Privacy Commission in the exercise of its regulatory functions, including investigations, audits, and enforcement actions.
15 Changes to this Privacy Policy
ambergame reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform operations. Revised versions will be published on this page with an updated effective date. Where changes are material — meaning they significantly affect your rights or how your data is used — ambergame will provide advance notice via SMS to registered Players at least 14 days before the changes take effect.
Your continued use of the ambergame platform after the revised Policy takes effect constitutes your acceptance of the updated terms. If you do not agree with material changes to this Policy, you may close your account and request any outstanding balance be paid to your registered withdrawal method.
16 Contact & Data Protection Officer
For all matters relating to this Privacy Policy, including requests to exercise your data rights, questions about how ambergame processes your personal data, or to report a potential data breach, please contact ambergame's Data Protection Officer:
ambergame Data Protection Officer
Platform: ambergame.one
Email: [email protected]
Subject line: "Privacy — Data Rights Request" or "Privacy — DPO Enquiry"
Live Chat: Available 24/7 at ambergame.one (reference "Privacy Policy" in your opening message)
Response Time: Within 30 calendar days for formal data rights requests; within 3 business days for general privacy enquiries
If you are not satisfied with ambergame's response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.
Document Reference: ambergame Privacy Policy — Effective 1 January 2026. This document supersedes all previous versions of the ambergame Privacy Policy. © 2026 ambergame. All rights reserved.