Rollem88 Privacy Policy

1. Introduction

Rollem88 ("Rollem88," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the Rollem88 online gaming platform, available at rollem88.app and through any associated mobile applications (collectively, the "Platform").

This Privacy Policy has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. It describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in connection with your use of the Rollem88 Platform.

By registering an account on Rollem88 or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not use the Rollem88 Platform.

This Privacy Policy should be read together with our Terms and Conditions and our Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, the data controller responsible for your personal data is Rollem88, operating the Platform at rollem88.app. Our designated Data Protection Officer (DPO) can be contacted at the email address provided in Section 14 of this Policy.

All inquiries, requests, and complaints relating to the processing of your personal data should be directed to our DPO in the first instance.

3. Personal Data We Collect

Rollem88 collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is processed. The categories of personal data we collect include:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (for age verification purposes);
• Philippine mobile number;
• Email address;
• Residential address within the Philippines;
• Government-issued identification number (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS number) where required for KYC verification.

3.2 Financial Data

• GCash or PayMaya account details (mobile number associated with the wallet);
• BPI, BDO, or Metrobank account details where used for deposits or withdrawals;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment references;
• Account balance information.

3.3 Gaming and Behavioural Data

• Game session history, including games played, wager amounts, outcomes, and session duration;
• Bonus and promotion usage history;
• Responsible gaming tool settings, including deposit limits and self-exclusion status;
• Customer support interaction records.

3.4 Technical and Device Data

• IP address and approximate geolocation derived therefrom;
• Device type, operating system, and browser type;
• Unique device identifiers;
• Log data, including access times, pages visited, and error reports;
• Cookie identifiers and similar tracking data (see Section 9).

4. How We Collect Your Data

Rollem88 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey or promotion;
• Automatically — through cookies, web beacons, and similar technologies when you access and use the Platform (see Section 9);
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud prevention services, and regulatory authorities where permitted or required by law.

5. Purpose and Legal Basis for Processing

Rollem88 processes your personal data only for specified, explicit, and legitimate purposes. The table below sets out the primary purposes for which we process your data and the corresponding legal basis under the Data Privacy Act of 2012:

• Account registration and management — necessary for the performance of the contract between you and Rollem88;
• Identity and age verification (KYC) — compliance with a legal obligation under applicable Philippine gaming and anti-money laundering regulations;
• Processing deposits and withdrawals — necessary for the performance of the contract;
• Delivering gaming services and personalising your experience — necessary for the performance of the contract and our legitimate interests in improving the Platform;
• Fraud prevention and platform security — compliance with legal obligations and our legitimate interests in protecting the Platform and its users;
• Anti-money laundering (AML) compliance — compliance with legal obligations under the Anti-Money Laundering Act (AMLA) and related regulations;
• Responsible gaming monitoring and intervention — compliance with applicable gaming regulations and our legitimate interests in player welfare;
• Customer support — necessary for the performance of the contract;
• Marketing communications — based on your consent, which you may withdraw at any time;
• Analytics and Platform improvement — our legitimate interests in understanding how the Platform is used and improving its performance.

Rollem88 will not process your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6. Sharing Your Personal Data

Rollem88 does not sell, rent, or trade your personal data to any third party for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers necessary to process your deposits and withdrawals;
• Identity verification providers — third-party KYC and AML compliance service providers engaged to verify your identity and comply with regulatory requirements;
• Game technology providers — software providers whose games are made available on the Rollem88 Platform, to the extent necessary for game delivery and RNG certification;
• Regulatory and law enforcement authorities — the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent authorities where disclosure is required by law, regulation, or court order;
• Fraud prevention and security services — third-party providers engaged to detect and prevent fraudulent activity, cheating, and platform abuse;
• Professional advisers — lawyers, auditors, and accountants engaged by Rollem88 in connection with the operation of the Platform, subject to professional confidentiality obligations.

All third parties with whom Rollem88 shares personal data are required to process that data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable Philippine data privacy law. Where Rollem88 engages third-party processors, we enter into data processing agreements that impose obligations consistent with the Data Privacy Act of 2012.

7. Data Retention

Rollem88 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with applicable AML and gaming regulatory requirements;
• Financial transaction records — retained for a minimum of five (5) years from the date of the transaction, as required under the AMLA and related regulations;
• Gaming session data — retained for a minimum of three (3) years from the date of the session;
• Customer support records — retained for three (3) years from the date of the interaction;
• Marketing consent records — retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with Rollem88's data disposal procedures. Where data is anonymised, it may be retained indefinitely for analytical purposes as it will no longer constitute personal data.

8. Data Security

Rollem88 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption of personal data in transit using industry-standard TLS protocols;
• Encryption of sensitive data at rest using AES-256 or equivalent standards;
• Access controls limiting data access to authorised personnel on a strict need-to-know basis;
• Multi-factor authentication for administrative access to systems containing personal data;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Staff training on data privacy obligations and information security best practices;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Rollem88 will notify the National Privacy Commission and, where required, affected data subjects in accordance with the timeframes prescribed by the Data Privacy Act of 2012 and NPC regulations.

9. Cookies and Tracking Technologies

Rollem88 uses cookies and similar tracking technologies to operate and improve the Platform, personalise your experience, and analyse usage patterns. A cookie is a small text file placed on your device when you visit the Platform. The following categories of cookies are used:

• Strictly necessary cookies — essential for the Platform to function correctly, including session management and security. These cannot be disabled.
• Functional cookies — remember your preferences and settings, such as language and display options, to improve your experience.
• Analytics cookies — collect aggregated, anonymised information about how users interact with the Platform, helping us identify areas for improvement.
• Marketing cookies — used to deliver relevant promotional content within the Platform, based on your gaming activity and preferences, subject to your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by Rollem88:

• Right to be informed — you have the right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy;
• Right of access — you have the right to request a copy of the personal data Rollem88 holds about you and information about how it is processed;
• Right to rectification — you have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to erasure — you have the right to request deletion of your personal data in certain circumstances, including where the data is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations;
• Right to object — you have the right to object to the processing of your personal data where that processing is based on our legitimate interests or for direct marketing purposes;
• Right to data portability — you have the right to receive your personal data in a structured, commonly used, and machine-readable format where processing is carried out by automated means;
• Right to lodge a complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that Rollem88 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 14. We will respond to all verified requests within fifteen (15) business days. We may require you to verify your identity before processing your request.

Where you have provided consent as the legal basis for processing (for example, for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, please contact our DPO or update your communication preferences in your account settings.

11. Minors and Age Restrictions

The Rollem88 Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with applicable Philippine gaming regulations. Rollem88 does not knowingly collect personal data from individuals under the age of 21.

If Rollem88 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and terminate the associated account. If you believe that a minor has registered an account on Rollem88, please contact us immediately using the details in Section 14.

12. Cross-Border Data Transfers

Rollem88 primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to recipients located outside the Philippines — for example, to international game technology providers or cloud infrastructure providers — Rollem88 will ensure that such transfers are carried out in compliance with the Data Privacy Act of 2012 and applicable NPC regulations.

Cross-border transfers of personal data will only be made where: (a) the recipient country provides an adequate level of data protection as determined by the NPC; (b) appropriate safeguards are in place, such as contractual clauses approved by the NPC; or (c) you have provided explicit consent to the transfer after being informed of the risks.

13. Amendments to This Privacy Policy

Rollem88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. Where amendments are material, we will notify registered users via email or in-platform notification prior to the changes taking effect.

The effective date of the current version of this Privacy Policy is stated at the top of this page. Your continued use of the Rollem88 Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of how we protect your data.

14. Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Rollem88, please contact our Data Protection Officer:

Data Protection Officer, Rollem88
Email: [email protected]

Please note that this email address is provided for correspondence purposes only and is not a clickable link. Our DPO will acknowledge receipt of your inquiry within forty-eight (48) hours and will aim to provide a substantive response within fifteen (15) business days.

If you are not satisfied with our response, or if you believe that Rollem88 has processed your personal data in violation of the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available through official Philippine government channels.