Privacy Policy

1. Introduction

melbe ("we," "us," "our," or "the Company") operates the online gaming platform accessible at melbe.cam (the "Website" or "Platform"). We are committed to protecting the privacy and security of your personal information in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (the "DPA"), its implementing rules and regulations issued by the National Privacy Commission (NPC), and the regulatory requirements of the Philippine Amusement and Gaming Corporation (PAGCOR).

This Privacy Policy explains how melbe collects, uses, discloses, stores, and protects the personal data of users who access or register accounts on our Platform. By using melbe's services, you acknowledge that you have read, understood, and consent to the data processing practices described in this Privacy Policy. If you do not agree with any aspect of this Privacy Policy, you must immediately cease using our Platform and refrain from registering an account.

melbe processes personal data only for legitimate purposes related to providing online gaming services, ensuring regulatory compliance, preventing fraud, and maintaining the security and integrity of our Platform. We do not sell, rent, or trade your personal information to third parties for marketing purposes without your explicit consent.

2. Data Controller and Contact Information

melbe is the data controller responsible for the processing of personal data collected through the Platform. For inquiries, complaints, or requests regarding your personal data or this Privacy Policy, you may contact our Data Protection Officer (DPO) through the following channels:

• Email: [email protected]
• Customer Support: Available 24/7 via live chat on the Website
• Phone Support: Accessible through your account dashboard
• Mailing Address: Data Protection Officer, melbe, Metro Manila, Philippines (full address available upon request)

Our DPO is responsible for overseeing melbe's compliance with the Data Privacy Act, handling data subject requests, and serving as the primary point of contact with the National Privacy Commission.

3. Types of Personal Data Collected

melbe collects various categories of personal data necessary to provide gaming services, verify user identity, process financial transactions, comply with legal obligations, and maintain the security of our Platform. The types of personal data we collect include:

3.1. Registration and Account Information

• Personal Identification Data: Full legal name, date of birth, nationality, gender, and government-issued identification numbers (e.g., passport number, driver's license number, Philippine National ID number)
• Contact Information: Residential address, email address, mobile phone number, and preferred communication method
• Account Credentials: Username, password (stored in encrypted form), and security questions
• Verification Documents: Digital copies of government-issued photo identification, proof of address (utility bills, bank statements), and selfie photographs for identity verification

3.2. Financial Transaction Data

• Payment Information: Bank account details, GCash or Maya account numbers, credit or debit card information (last four digits only), and payment processor transaction IDs
• Transaction History: Records of deposits, withdrawals, wagers, winnings, bonuses claimed, and account balance changes
• Source of Funds Documentation: For enhanced due diligence purposes, we may request bank statements, employment verification, or other documents demonstrating the legitimate source of funds used for gaming activities

3.3. Usage and Technical Data

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers
• Behavioral Data: Pages visited, games played, betting patterns, session duration, clickstream data, and interaction with promotional materials
• Location Data: Geolocation information derived from IP address to verify physical presence within the Philippines and comply with geographic restrictions
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, and similar technologies to personalize user experience, maintain session state, and analyze Platform usage

3.4. Communications and Customer Support

• Support Interactions: Chat transcripts, email correspondence, phone call recordings, and support ticket histories
• Marketing Preferences: Opt-in or opt-out status for promotional emails, SMS messages, and push notifications

4. Legal Basis for Processing Personal Data

Under the Data Privacy Act, melbe processes your personal data based on the following legal grounds:

• Consent: You explicitly consent to the processing of your personal data by registering an account and accepting this Privacy Policy. Consent may be withdrawn at any time, subject to legal and contractual limitations.
• Performance of Contract: Processing is necessary to fulfill our contractual obligations to provide gaming services, process deposits and withdrawals, and manage your account.
• Legal Obligation: Processing is required to comply with PAGCOR regulations, anti-money laundering (AML) laws (Republic Act No. 9160, as amended), Know Your Customer (KYC) requirements, tax reporting obligations, and other applicable Philippine laws.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security monitoring, dispute resolution, and improving Platform functionality, provided such interests do not override your fundamental rights and freedoms.

5. How We Use Your Personal Data

melbe uses the personal data we collect for the following purposes:

5.1. Account Management and Service Provision

• Creating and managing user accounts
• Verifying user identity and age (21+ requirement)
• Processing deposits, withdrawals, and financial transactions
• Enabling gameplay and managing game sessions
• Applying bonus terms, loyalty rewards, and promotional offers
• Providing customer support and responding to inquiries

5.2. Regulatory Compliance and Legal Obligations

• Complying with PAGCOR licensing requirements and reporting obligations
• Conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures
• Monitoring and reporting suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Maintaining records for audit and regulatory inspection purposes
• Responding to lawful requests from government authorities, law enforcement, and regulatory bodies

5.3. Security, Fraud Prevention, and Risk Management

• Detecting and preventing fraudulent activity, collusion, and bonus abuse
• Monitoring account activity for signs of problem gambling or underage gambling
• Investigating disputes, chargebacks, and policy violations
• Protecting the security and integrity of the Platform and its users
• Enforcing Terms and Conditions and other Platform policies

5.4. Marketing and Communication

• Sending promotional emails, SMS messages, and push notifications about new games, bonuses, and special offers (only with your consent)
• Personalizing content and recommendations based on gaming preferences
• Conducting surveys and gathering feedback to improve services

5.5. Platform Improvement and Analytics

• Analyzing user behavior and Platform usage to identify trends and improve functionality
• Testing new features, games, and payment methods
• Optimizing user interface and user experience
• Generating anonymized or aggregated data for business intelligence purposes

6. Data Sharing and Disclosure

melbe does not sell, rent, or trade your personal data to third parties for their marketing purposes. However, we may share your personal data with the following categories of recipients under specific circumstances:

6.1. Service Providers and Business Partners

We engage trusted third-party service providers to assist in operating our Platform and delivering services, including:

• Payment Processors: GCash, Maya, online banking partners, and other payment gateways that facilitate deposits and withdrawals
• Identity Verification Services: Third-party providers that verify user identity, age, and address using government databases and document authentication technology
• Game Providers: Software developers and gaming studios that supply casino games, slots, live dealer tables, and other gaming content
• Cloud Hosting Services: Infrastructure providers that host our servers, databases, and backup systems
• Customer Support Tools: Live chat platforms, helpdesk software, and communication tools used to provide customer service
• Marketing and Analytics Partners: Email service providers, SMS gateways, and analytics platforms that help us communicate with users and analyze Platform usage

All service providers are contractually obligated to process personal data only for the purposes specified by melbe, maintain appropriate security measures, and comply with applicable data protection laws.

6.2. Regulatory and Government Authorities

melbe may disclose personal data to regulatory bodies, government agencies, and law enforcement when required by law or when necessary to:

• Comply with PAGCOR reporting and audit requirements
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Respond to subpoenas, court orders, or lawful requests for information
• Cooperate with tax authorities such as the Bureau of Internal Revenue (BIR)
• Assist in investigations of criminal activity, fraud, or policy violations

6.3. Corporate Transactions

In the event of a merger, acquisition, sale of assets, or other corporate restructuring, your personal data may be transferred to the acquiring entity, provided the new entity agrees to protect your personal data in accordance with this Privacy Policy and applicable laws.

7. International Data Transfers

melbe primarily processes personal data within the Philippines. However, some of our service providers and business partners may be located in other jurisdictions. When personal data is transferred outside the Philippines, melbe ensures that adequate safeguards are in place, such as:

• Contractual clauses requiring the recipient to maintain equivalent data protection standards
• Verification that the destination country provides adequate data protection as recognized by the National Privacy Commission
• Compliance with applicable cross-border data transfer requirements under the Data Privacy Act

8. Data Retention

melbe retains personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our policies. Specific retention periods include:

• Account Data: Retained for the duration of account activity and for seven (7) years after account closure to comply with PAGCOR and AML record-keeping requirements
• Transaction Records: Retained for seven (7) years from the date of transaction to comply with financial and tax regulations
• Identity Verification Documents: Retained for seven (7) years after account closure or as required by regulatory authorities
• Marketing Communications: Retained until you withdraw consent or for three (3) years from the last interaction
• Technical Logs: Retained for six (6) months to two (2) years for security monitoring and system maintenance purposes

After the applicable retention period expires, personal data is securely deleted or anonymized in accordance with data protection best practices.

9. Data Security Measures

melbe implements robust technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, destruction, or loss. Our security measures include:

• Encryption: All sensitive data, including passwords and payment information, is encrypted using industry-standard encryption protocols (SSL/TLS for data in transit, AES-256 for data at rest)
• Access Controls: Strict role-based access controls ensure that only authorized personnel can access personal data on a need-to-know basis
• Secure Infrastructure: Our servers and databases are hosted in secure data centers with physical and network security controls, including firewalls, intrusion detection systems, and regular security audits
• Regular Security Assessments: We conduct periodic vulnerability assessments, penetration testing, and security reviews to identify and remediate potential weaknesses
• Employee Training: All employees with access to personal data undergo mandatory data protection and cybersecurity training
• Incident Response Plan: We maintain a documented incident response plan to quickly detect, contain, and remediate data breaches

Despite our best efforts, no method of data transmission or storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

10. Your Rights as a Data Subject

Under the Data Privacy Act, you have the following rights regarding your personal data:

• Right to Be Informed: You have the right to be informed about the collection and processing of your personal data, as described in this Privacy Policy.
• Right of Access: You have the right to request access to your personal data held by melbe, including the right to obtain copies of your data.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or based on legitimate interests.
• Right to Erasure or Blocking: You have the right to request the suspension, withdrawal, or deletion of your personal data, subject to legal and contractual retention requirements.
• Right to Rectification: You have the right to correct inaccurate or incomplete personal data.
• Right to Data Portability: You have the right to obtain your personal data in a structured, commonly used, and machine-readable format and transmit it to another data controller, where technically feasible.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission if you believe melbe has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within the timeframe required by law, typically within fifteen (15) days, and may request additional information to verify your identity before processing your request.

11. Cookies and Tracking Technologies

melbe uses cookies, web beacons, and similar tracking technologies to enhance user experience, maintain session state, personalize content, and analyze Platform usage. Cookies are small text files stored on your device that allow us to recognize your browser and remember your preferences.

11.1. Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly, including authentication, security, and session management
• Functional Cookies: Enable personalized features such as language preferences, account settings, and game history
• Analytics Cookies: Collect anonymized data about how users interact with the Platform to improve functionality and performance
• Marketing Cookies: Track user behavior across websites to deliver targeted advertising and promotional offers (only with your consent)

11.2. Managing Cookies

You can manage or disable cookies through your browser settings. However, disabling essential cookies may prevent you from accessing certain features of the Platform or logging into your account.

12. Third-Party Links and Services

The melbe Platform may contain links to third-party websites, payment processors, and social media platforms. melbe is not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party services you access through our Platform.

13. Changes to This Privacy Policy

melbe reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. When we make material changes, we will notify you by posting the updated Privacy Policy on the Website and updating the "Last Updated" date at the top of this document. Significant changes may also be communicated via email or through a prominent notice on the Platform. Your continued use of melbe's services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

14. Contact Information and Complaints

If you have questions, concerns, or complaints about this Privacy Policy or melbe's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 on the Website
• Customer Support: Accessible through your account dashboard

If you are not satisfied with our response or believe we have violated your data privacy rights, you may file a complaint with the National Privacy Commission:

• National Privacy Commission (NPC)
• Website: www.privacy.gov.ph
• Email: [email protected]
• Address: 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto St., Pasay City, Metro Manila