gerya Privacy Policy

1. Introduction

gerya ("gerya", "we", "us", "our") operates the online gaming platform accessible at gerya.net, offering Filipino players sports betting, live casino, slots, bingo, pool rummy, and card games. As a platform that collects and processes personal information from real people — our players — gerya takes its obligations as a personal information controller very seriously.

This Privacy Policy describes the personal data gerya collects from you when you access or use the platform, how that data is processed, the legal basis for processing, how long we keep it, who we share it with, and the rights you have over your own data. It applies to all gerya players, registered account holders, and website visitors based in the Philippines.

This policy should be read alongside gerya's Terms & Conditions, which govern the overall relationship between you and gerya. In the event of a conflict between this Privacy Policy and the Terms & Conditions on a privacy matter, this Privacy Policy shall take precedence.

If you do not agree with the practices described in this Privacy Policy, please do not register for or use the gerya platform.

2. Data Controller Identity

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, gerya acts as the Personal Information Controller (PIC) in respect of all personal data collected from players and users of the gerya.net platform.

As Personal Information Controller, gerya is responsible for determining the purposes and means of processing your personal data. gerya is registered under PAGCOR oversight and operates in compliance with applicable Philippine laws governing data privacy, anti-money laundering, and online gaming.

For all privacy-related inquiries, data subject requests, or complaints, you may contact gerya's designated Data Protection Officer (DPO) through the contact details provided in Section 13 of this policy.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register for a gerya account, complete KYC verification, make deposits or withdrawals, contact support, or use any feature of the platform, you provide us with personal data that includes:

3.2 Data Collected Automatically

When you access the gerya platform through any device, our systems automatically collect certain technical data necessary for security, fraud prevention, and platform performance:

• IP address and approximate geographic location derived from it;
• Device type, operating system version, and browser type;
• Session duration, pages visited, features accessed, and navigation patterns within the platform;
• Login timestamps, failed login attempts, and session security events;
• Cookie identifiers and similar tracking data as described in Section 8.

3.3 Data from Third Parties

In limited circumstances, gerya may receive personal data about you from third parties, including:

• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank) confirming transaction status;
• Identity verification service providers assisting with KYC document authentication;
• Fraud detection and anti-money laundering screening databases operated in compliance with Philippine law;
• PAGCOR or other Philippine regulatory bodies in the context of regulatory reporting obligations.

4. Purpose & Legal Basis for Processing

gerya processes your personal data only where there is a lawful basis to do so. The following table sets out the primary purposes for which gerya processes player data and the corresponding legal basis under the Data Privacy Act of 2012:

5. Sharing Your Personal Data

5.1 When gerya Shares Data

gerya does not sell, rent, or trade your personal data to any third party for commercial marketing purposes. Your data is shared only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: Transaction data is shared with GCash, PayMaya, BPI, BDO, Metrobank, and USDT processing partners solely to execute deposits and withdrawals on your behalf. These processors are bound by their own privacy obligations and applicable Philippine financial regulations.
• Game Content Providers: gerya integrates third-party game studios and live casino platform providers to deliver its gaming content. Your account identifier and session data are shared with these providers to the extent required for game delivery and fairness verification. Game providers are contractually prohibited from using this data for any independent purpose.
• KYC & Identity Verification Providers: gerya uses certified identity verification services to assist with document authentication during the KYC process. These providers process only the specific documents and data required for verification and are bound by data processing agreements.
• Regulatory Authorities: gerya is required by Philippine law to report certain information to PAGCOR and to the Anti-Money Laundering Council (AMLC) in connection with suspicious transaction reports, covered transaction reports, and regulatory compliance audits. gerya will comply with all lawful requests from Philippine government bodies.
• Law Enforcement: gerya will cooperate with the Philippine National Police, National Bureau of Investigation, and other law enforcement agencies where required by a valid legal order, court order, or search warrant in accordance with Philippine law.

5.2 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving gerya, your personal data may be transferred to a successor entity as part of that transaction. gerya will notify affected players via their registered email address prior to any such transfer, and the receiving entity will be required to honor the commitments made in this Privacy Policy.

6. Data Retention

gerya retains personal data for as long as your account remains active and for such additional period as is required by applicable Philippine law. The key retention periods are:

• Account and identity data: Retained for the lifetime of your active account plus five (5) years following permanent account closure, in compliance with PAGCOR licensing conditions and the Anti-Money Laundering Act (RA 9160).
• Transaction records (deposits, withdrawals, bets): Retained for a minimum of five (5) years from the date of each transaction, as required for AML compliance and regulatory audit purposes.
• KYC documents: Retained for five (5) years after account closure or as otherwise required by PAGCOR.
• Support communications: Retained for three (3) years from the date of communication to support dispute resolution.
• Technical log data: Retained for twelve (12) months for security and fraud prevention purposes, after which logs are deleted or anonymized.

Upon expiry of the applicable retention period, gerya will securely delete or irreversibly anonymize your personal data. Where full deletion is not technically possible for specific systems (such as backup archives), your data will be isolated and protected from further active processing until deletion is feasible.

7. Security Measures

gerya implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in transit: All data exchanged between your browser or app and the gerya platform is encrypted using Transport Layer Security (TLS 1.2 or higher).
• Encryption at rest: Sensitive personal data including KYC documents and payment information is stored using AES-256 encryption.
• Access controls: Internal access to player personal data is restricted on a strictly need-to-know basis. Staff with access undergo regular security training and are bound by confidentiality obligations.
• Two-factor authentication: gerya offers and encourages the use of two-factor authentication (2FA) for all player accounts to prevent unauthorized account access.
• Security monitoring: gerya maintains continuous monitoring of platform activity for security threats, intrusion attempts, and unusual access patterns.
• Penetration testing: gerya's infrastructure undergoes periodic security assessments to identify and remediate vulnerabilities.

While gerya takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials. If you believe your account has been compromised, contact gerya support via live chat immediately.

8. Cookies & Tracking Technologies

8.1 What Cookies gerya Uses

gerya uses cookies and similar technologies (such as local storage and session tokens) on its platform. The categories of cookies we use are:

• Essential / Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Preference Cookies: Remember your account settings and display preferences (such as language, game lobby layout, and responsible gaming tool configurations).
• Analytics Cookies: Collect anonymized data on how players navigate and use the platform, helping gerya improve performance and user experience. These do not identify you individually.

8.2 What gerya Does Not Use

gerya does not use third-party advertising cookies, retargeting pixels, or social media tracking scripts. gerya does not allow external advertising networks to place cookies on the gerya platform.

8.3 Managing Cookies

You can control and delete cookies through your browser settings. Note that disabling essential cookies will prevent you from logging in and using the gerya platform. For analytics and preference cookies, you can opt out through your browser's cookie management settings without affecting core platform functionality.

9. Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, you — as a data subject — have the following rights with respect to your personal data held by gerya:

• Right to be Informed: The right to know whether gerya holds personal data about you, the source of that data, how it is being used, and to whom it has been disclosed. This Privacy Policy fulfills that right.
• Right to Access: The right to obtain a copy of the personal data gerya holds about you, along with information about how it is being processed. Requests will be fulfilled within a reasonable timeframe and are subject to identity verification.
• Right to Correction / Rectification: The right to have inaccurate, outdated, or incomplete personal data corrected. You may update basic account information directly within your account settings, or contact support for changes that require document verification.
• Right to Erasure / Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where processing is unlawful. Note that gerya may be required to retain certain data under Philippine AML law regardless of an erasure request.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes, or where gerya relies on legitimate interest as the legal basis for processing. Objections will be assessed on a case-by-case basis.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated. The NPC can be reached at privacy.gov.ph.

10. Minors & Age Policy

The gerya platform is strictly restricted to individuals who are twenty-one (21) years of age or older, in accordance with PAGCOR regulations governing real-money gaming in the Philippines. gerya does not knowingly collect personal data from individuals under the age of 21.

All registration attempts are subject to age verification as part of the KYC process. Where gerya becomes aware that personal data has been collected from an individual below the required age, the relevant account will be suspended immediately, all associated funds will be held pending review, and the data will be deleted as required by applicable law.

If you are a parent or guardian and believe that a minor has registered for or accessed gerya, please contact gerya support immediately via live chat so we can take appropriate action promptly.

11. Cross-Border Data Transfers

gerya's primary data processing infrastructure is operated within, or in compliance with the standards applicable to, the Philippines. However, certain third-party service providers — such as game content providers and platform technology partners — may process data on servers located outside the Philippines.

Where personal data is transferred outside the Philippines, gerya ensures that such transfers occur only to recipients that provide an adequate level of data protection through: contractual data processing agreements incorporating standard data protection clauses; the recipient's certification under an applicable data protection framework recognized by the National Privacy Commission; or other lawful transfer mechanisms as recognized under the Data Privacy Act of 2012 and NPC issuances.

gerya does not transfer personal data to jurisdictions with no meaningful data protection framework without implementing compensating contractual protections.

12. Amendments to This Policy

gerya may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, gerya will notify registered players by email to the address on file and/or by a prominent notice on the platform prior to the changes taking effect.

The effective date at the top of this policy indicates when the current version was last updated. Your continued use of the gerya platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you disagree with a material change, you may close your account in accordance with the Terms & Conditions prior to the change taking effect.

Archived versions of previous Privacy Policies are available upon request by contacting gerya support.

13. Contact & Data Protection Officer

gerya has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this policy, you may reach the gerya DPO and support team through the following channels:

• Live Chat: Available 24/7 directly on the gerya platform — the fastest channel for data subject requests and privacy inquiries.
• Email (non-clickable): [email protected]

gerya aims to acknowledge all privacy-related communications within three (3) business days and to resolve substantive requests within fifteen (15) business days. For complex requests — such as large-scale data access requests or erasure requests involving regulatory retention obligations — gerya will inform you of any extended timeline required.

If you are not satisfied with gerya's response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines at privacy.gov.ph.