noceph Privacy Policy — Your Data, Your Rights

Introduction

noceph is a PAGCOR-licensed online gaming platform serving Filipino players across the Philippines. We offer a range of gaming products including live bingo, JILI slots, fishing games, live casino tables, and competitive sports betting on PBA, NBA, UFC, and other major events. In order to deliver these services safely, legally, and responsibly, noceph must collect and process certain personal information about registered players.

We take data privacy seriously — not merely as a legal obligation, but as a core part of our commitment to the Filipino players who trust noceph with their information and their money. This Policy sets out our practices in plain, readable language while meeting the legal standards required under Philippine law.

The Data Protection Officer (DPO) of noceph is responsible for overseeing compliance with this Policy and with the Data Privacy Act of 2012. Contact details for the DPO are provided in Section 13 of this Policy.

Scope & Application

This Privacy Policy applies to all personal information collected by noceph through the following channels:

• The noceph website at noceph.net and all sub-pages thereof
• The noceph mobile-optimized web interface accessed via any device browser
• Email communications, live chat support sessions, and any other direct communication channels between noceph and a Player
• Third-party payment gateways and game providers operating within the noceph platform, to the extent that data is shared back to noceph
• KYC verification portals or document submission systems used by noceph

This Policy applies to all registered noceph players, prospective players who have initiated but not completed registration, and individuals who contact noceph support without holding a registered account. It applies solely to personal data of individuals physically located in and residents of the Republic of the Philippines, consistent with noceph's PAGCOR license scope.

Data We Collect

3.1 Registration Data

When you create a noceph account, we collect the following information which you provide directly:

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (to verify you are 21 years of age or older)
• Philippine mobile number (used for OTP verification and account communications)
• Email address
• Residential address within the Philippines
• Username and encrypted password (passwords are never stored in plaintext)

3.2 Identity Verification (KYC) Data

PAGCOR regulations require noceph to verify the identity of all players prior to processing withdrawal requests and in other compliance-related circumstances. KYC data collected may include:

• Scanned or photographed copies of government-issued Philippine ID documents (e.g., PhilSys National ID, passport, driver's license, UMID, SSS ID, PRC ID)
• Selfie or live photo for facial verification purposes
• Proof of registered mobile number
• Source of funds documentation in cases where AMLA compliance requires it

3.3 Financial Transaction Data

For deposit and withdrawal processing, noceph collects and retains records of:

• Payment method identifiers (e.g., GCash-registered mobile number, bank account name and number, Maya account details)
• Transaction amounts in Philippine Peso (PHP)
• Transaction timestamps, reference numbers, and processing status
• Cryptocurrency wallet addresses where USDT TRC20 is used

3.4 Gameplay and Betting Data

noceph maintains detailed records of all gaming activity on the platform, including:

• Game sessions, wager amounts, outcomes, and returns for all casino games
• Sports bets placed, markets selected, odds at time of placement, and settlement results
• Bingo ticket purchases, game participation, and winning records
• Bonus claims, wagering requirement progress, and promotion participation history

3.5 Technical and Device Data

When you access the noceph platform, our systems automatically collect certain technical data, including:

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Session timestamps, pages visited, and navigation patterns within the platform
• Cookie identifiers and similar tracking technologies (see Section 7)

3.6 Data Summary Table

How We Use Your Data

noceph uses collected personal data for the following documented purposes:

• Account creation and management: To register your account, verify your identity, maintain your player profile, and manage your balance and transaction history.
• Age and identity verification: To confirm that all players are 21 years of age or older as required by PAGCOR and Philippine law.
• Transaction processing: To process deposits and withdrawal requests via GCash, Maya, BPI, BDO, Metrobank, and other supported Philippine payment methods.
• Regulatory compliance: To fulfill noceph's obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws, including filing of required reports with the AMLC.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other prohibited conduct as defined in noceph's Terms & Conditions.
• Responsible gaming monitoring: To identify patterns of play that may indicate problem gambling behavior and to apply responsible gaming tools where appropriate, in accordance with PAGCOR responsible gaming standards.
• Customer support: To respond to your inquiries, resolve disputes, and provide assistance with account and transaction matters via live chat and email.
• Platform improvement: To analyze aggregated and anonymized usage data to improve the noceph platform's features, performance, and user experience for Filipino players.
• Promotional communications: To send you information about noceph promotions, bonuses, and new game releases where you have consented to receive such communications. You may withdraw consent at any time via Account Settings.

noceph does not use your personal data for automated decision-making that produces legal or similarly significant effects without human oversight, except where such automation is required for real-time fraud prevention systems. In such cases, you have the right to request human review of any automated decision affecting your account.

Legal Basis for Processing

noceph processes personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent: For non-essential data processing such as promotional communications, where you have provided clear, specific, informed, and freely given consent at the time of registration or subsequently in Account Settings.
• Contractual necessity: For processing required to fulfill noceph's obligations under the Player Agreement (Terms & Conditions), including account management, game delivery, and transaction processing.
• Legal obligation: For processing required to comply with PAGCOR regulations, the AMLA, the Data Privacy Act, and other applicable Philippine laws — including KYC verification and AMLC reporting.
• Legitimate interest: For fraud prevention, platform security, responsible gaming monitoring, and platform performance analytics, where noceph's legitimate interests are not overridden by your rights and freedoms as a Data Subject.

Data Sharing & Disclosure

6.1 Regulatory and Law Enforcement Authorities

noceph is required by law to share certain player data with Philippine regulatory and law enforcement bodies, including PAGCOR (as part of ongoing license compliance), the Anti-Money Laundering Council (AMLC), the National Bureau of Investigation (NBI), and other relevant Philippine government agencies when required by court order, regulatory demand, or applicable law. noceph will comply with all lawful data disclosure requests and will notify affected players of such disclosures where legally permitted to do so.

6.2 Third-Party Service Providers

noceph works with carefully selected third-party service providers who assist in delivering the noceph platform. These providers may process personal data on noceph's behalf strictly under written data processing agreements that prohibit any independent use of player data. Categories of third-party processors used by noceph include:

• Payment gateway providers (e.g., GCash, Maya, bank payment processors)
• KYC and identity verification technology providers
• Game software providers whose games are offered in the noceph casino lobby
• Cloud infrastructure and server hosting providers
• Customer support platform providers
• Fraud detection and cybersecurity service providers

6.3 Prohibited Disclosures

noceph strictly prohibits the following disclosures of player personal data:

• Sale, rental, or commercial transfer of player data to any third party for marketing or advertising purposes
• Sharing of personal data with affiliates, partners, or third parties outside of documented, contractually governed data processing relationships
• Transfer of personal data outside the Philippines except where required by applicable law or where adequate data protection safeguards are in place consistent with NPC guidelines

Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files stored on your device by your web browser when you visit the noceph platform. noceph uses cookies and similar technologies (such as local storage and session tokens) to ensure the proper functioning of the platform, maintain your logged-in session, and improve your experience.

7.2 Types of Cookies Used by noceph

• Strictly Necessary Cookies: Required for the noceph platform to function. These include session cookies that maintain your login state and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without impairing platform functionality.
• Functional Cookies: Store your preferences such as language settings and game lobby display preferences to provide a more personalized experience on return visits.
• Analytics Cookies: Collect anonymized and aggregated data about how players navigate and interact with the noceph platform, used solely to improve platform performance and user experience. These cookies do not identify individual players.
• Responsible Gaming Cookies: Track session duration and betting patterns as part of noceph's responsible gaming monitoring systems, consistent with PAGCOR responsible gaming standards.

7.3 Cookie Management

You may manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the noceph platform. noceph does not use third-party advertising cookies or behavioral tracking cookies for cross-site advertising purposes.

Data Retention

noceph retains personal data for defined periods based on the category of data and the applicable legal and regulatory requirements:

Upon expiry of the applicable retention period, personal data will be securely destroyed using methods appropriate to the sensitivity of the data (e.g., cryptographic erasure for digital data, secure shredding for physical documents). Where full erasure is not technically feasible, data will be anonymized such that it can no longer be linked to an identifiable individual.

Your Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules, every noceph player who is a Philippine resident has the following rights with respect to their personal data:

• Right to Be Informed: You have the right to be told what personal data noceph collects, why it is collected, how it is used, and with whom it is shared. This Privacy Policy fulfills that obligation.
• Right to Access: You may request a copy of the personal data noceph holds about you, including your account information, KYC records, transaction history, and gaming history. Access requests will be fulfilled within 15 business days.
• Right to Correction: If any personal data noceph holds about you is inaccurate, incomplete, or outdated, you have the right to request correction. noceph will process correction requests within 10 business days, subject to identity verification.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, where consent has been withdrawn and no other legal basis applies, or where processing is unlawful. Note that noceph may be legally required to retain certain data under AMLA and PAGCOR obligations, which would override an erasure request for that specific data.
• Right to Object: You may object to processing of your personal data where noceph relies on legitimate interest as the legal basis, including profiling for responsible gaming purposes. noceph will assess the objection and respond within 15 business days.
• Right to Data Portability: You may request that noceph provide your personal data in a structured, commonly used, machine-readable format for transfer to another service provider, where technically feasible.
• Right to Lodge a Complaint: If you believe noceph has violated your rights under the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.

Data Security

noceph implements a layered security framework to protect player personal data from unauthorized access, accidental loss, destruction, or disclosure. Key security measures in place include:

• Encryption: All personal data is encrypted at rest using AES-256 encryption. All data in transit is protected using TLS 1.2 or higher. Passwords are stored using strong one-way cryptographic hashing with salt.
• Access Controls: Access to player personal data within noceph's systems is restricted on a strict need-to-know basis. All staff with data access are subject to background checks, data protection training, and confidentiality obligations.
• Two-Factor Authentication: noceph's internal systems require multi-factor authentication for staff access to production data environments.
• Regular Security Audits: noceph engages independent cybersecurity firms to conduct regular penetration testing and vulnerability assessments of its platform and data infrastructure.
• Incident Response: noceph maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to player rights, noceph will notify the National Privacy Commission and affected players within 72 hours of becoming aware of the breach, as required by the Data Privacy Act.

While noceph takes all reasonable and technically practicable measures to protect your data, no online platform can guarantee absolute security. Players are encouraged to use strong, unique passwords, enable any available two-factor authentication on their noceph account, and report any suspicious account activity to noceph support immediately.

Minors & Age Verification

noceph is strictly prohibited from providing gaming services to individuals under 21 years of age. This is a non-negotiable requirement of noceph's PAGCOR license and of applicable Philippine gambling law. noceph does not knowingly collect personal data from individuals under 21.

If noceph discovers or is notified that a player is under 21 years of age, the following actions will be taken without delay:

• The account will be immediately suspended pending investigation
• All personal data collected from the underage individual will be identified and isolated
• Any deposited funds will be refunded to the original payment source after applicable deductions
• The matter will be reported to PAGCOR as required
• Following account closure, data will be retained only for the minimum period required by law, then securely destroyed

Policy Changes

noceph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, PAGCOR regulatory requirements, or platform features. When material changes are made to this Policy, noceph will notify registered players via the email address on file or through a prominent notice on the noceph platform, at least 7 days before the changes take effect.

The date of the most recent revision to this Policy is displayed at the top of the page. Continued use of the noceph platform following the effective date of any updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree with changes to this Policy, you should cease using noceph and request account closure before the effective date of the changes.

Previous versions of this Privacy Policy are available upon request from noceph's Data Protection Officer.

Contact & Data Protection Officer

noceph has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. Players may contact the DPO for any privacy-related inquiries, rights requests, or concerns through the following channels:

• Live Chat: Available 24/7 on the noceph platform — fastest response for urgent matters
• Email: [email protected] — for formal privacy rights requests, include "Data Privacy Rights Request" in the subject line

Players who are not satisfied with noceph's response to a privacy concern may escalate their complaint to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data protection matters in the Philippines.