Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how gerya ("we", "us", "our", or the "Company") collects, uses, processes, stores, shares, and protects personal information obtained from users ("you", "your", or "User") of our online casino platform accessible at https://gerya.cam and all related services, applications, and features (collectively, the "Platform"). This Policy applies to all personal data collected through the Platform, including information provided during account registration, gameplay sessions, payment transactions, customer support interactions, and any other engagement with gerya services.

By accessing or using the gerya Platform, creating an account, or providing personal information to us in any manner, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with our data collection and processing practices, you must immediately discontinue use of the Platform and refrain from providing any personal information to gerya. This Policy should be read in conjunction with our Terms and Conditions, which govern your overall use of the Platform and constitute part of the legal framework governing the relationship between you and gerya.

2. Information We Collect

2.1 Personal Information Provided Directly by You

gerya collects various categories of personal information that you voluntarily provide when registering an account, using Platform services, or communicating with us. This information is necessary for account creation, identity verification, regulatory compliance, payment processing, and service delivery. Personal information collected directly from you includes but is not limited to:

• Identity Information: Full legal name, date of birth, nationality, government-issued identification numbers (such as passport number, driver's license number, or national ID), copies of identification documents submitted for verification purposes, and photographic images contained in such documents.
• Contact Information: Residential address (street, barangay, city, province, postal code), email address, mobile telephone number, and alternative contact details provided for account recovery or communication purposes.
• Financial Information: Payment method details including GCash account information, PayMaya account details, bank account numbers for BPI, BDO, Metrobank, UnionBank or other Philippine banks, cryptocurrency wallet addresses where applicable, transaction history, deposit and withdrawal records, and payment card information if provided.
• Account Credentials: Username, password (stored in encrypted format), security questions and answers, and any other authentication information used to secure your gerya account.
• Communication Records: Content of messages sent through customer support channels including live chat transcripts, email correspondence, phone call recordings where legally permitted and disclosed, feedback submissions, and survey responses.
• Responsible Gaming Data: Self-imposed deposit limits, session time limits, self-exclusion requests, reality check preferences, and any communications regarding problem gambling concerns or requests for gambling addiction support resources.

2.2 Information Collected Automatically

In addition to information you provide directly, gerya automatically collects certain technical and usage data when you access and interact with the Platform. This automated data collection enables us to improve Platform functionality, detect fraud, ensure security, analyze user behavior, and enhance overall service quality. Automatically collected information includes:

• Device Information: Device type (mobile phone, tablet, desktop computer), operating system (Android, iOS, Windows, macOS), browser type and version (Chrome, Safari, Firefox), screen resolution, device identifier (IMEI, UDID), mobile network information, and device settings.
• Connection Data: IP address, internet service provider, geographic location (country, region, city derived from IP address), timestamp of access, and network connection type (WiFi, mobile data).
• Usage Analytics: Pages visited on the Platform, games played, bet amounts and outcomes, session duration, click patterns, navigation paths, features accessed, buttons clicked, and interaction sequences.
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, pixel tags, local storage, and similar tracking technologies that record your preferences, maintain logged-in status, track Platform usage, and enable targeted content delivery. For detailed information about our use of cookies, please refer to Section 8 of this Policy.
• Transaction Logs: Comprehensive records of all financial transactions including deposits, withdrawals, bonus claims, wagering activity, account balance changes, and associated timestamps and transaction identifiers.

3. How We Use Your Information

gerya processes personal information collected from users for specific, legitimate purposes necessary for Platform operation, regulatory compliance, fraud prevention, and service improvement. We do not use your information for purposes beyond those disclosed in this Policy without obtaining your explicit consent. The primary purposes for which gerya uses your personal information include:

3.1 Account Management and Service Delivery

• Creating and maintaining your gerya account with accurate profile information
• Authenticating your identity during login and verifying account ownership
• Processing deposits and withdrawals through GCash, PayMaya, bank transfers, and other payment methods
• Enabling gameplay functionality and recording game results accurately
• Managing bonus offers, promotions, and loyalty program participation
• Providing customer support and responding to inquiries, complaints, and requests
• Communicating important account notifications, security alerts, and service updates
• Facilitating responsible gaming tools including deposit limits, self-exclusion, and session reminders

3.2 Legal Compliance and Regulatory Obligations

• Verifying age eligibility (21+ requirement) in compliance with Philippine gambling regulations
• Conducting identity verification (Know Your Customer / KYC procedures) required by anti-money laundering laws
• Monitoring transactions for suspicious activity and reporting to regulatory authorities as legally required
• Maintaining records for audit, accounting, and tax compliance purposes
• Responding to legal requests, court orders, subpoenas, and government investigations
• Complying with Philippine Data Privacy Act requirements and other applicable privacy regulations
• Enforcing our Terms and Conditions, investigating Terms violations, and pursuing legal remedies when necessary

3.3 Security, Fraud Prevention, and Risk Management

• Detecting and preventing fraudulent account creation, identity theft, and payment fraud
• Identifying suspicious betting patterns, bonus abuse, and other prohibited activities
• Protecting against unauthorized account access, hacking attempts, and cybersecurity threats
• Investigating security incidents, policy violations, and potentially illegal activities
• Implementing risk assessment models to identify high-risk users or transactions
• Verifying legitimacy of payment sources to prevent money laundering
• Blocking access from prohibited jurisdictions or by self-excluded individuals

3.4 Platform Improvement and Analytics

• Analyzing usage patterns to understand how Filipino users interact with the Platform
• Identifying technical issues, bugs, and performance bottlenecks requiring optimization
• Conducting A/B testing to evaluate feature improvements and interface changes
• Developing new games, features, and services based on user preferences and feedback
• Optimizing mobile performance for Android and iOS devices commonly used in the Philippines
• Improving customer support quality through analysis of inquiry patterns and resolution effectiveness
• Personalizing user experience by recommending games and offers aligned with preferences

3.5 Marketing and Communication

• Sending promotional emails about new games, bonus offers, and special events (with opt-out option)
• Displaying personalized advertisements and content based on gameplay history and preferences
• Conducting surveys to gather feedback on Platform features and services
• Informing users about important updates, maintenance schedules, and policy changes
• Marketing communications are sent only to users who have consented to receive them, and you may opt out at any time by adjusting account settings or clicking unsubscribe links in emails

4. Legal Basis for Processing (Philippine Data Privacy Act)

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, personal data processing must be justified by a lawful basis. gerya processes your personal information based on the following legal grounds:

• Consent: You have provided explicit, informed consent for gerya to collect and process your personal information for specified purposes, which you grant by accepting this Privacy Policy during account registration.
• Contract Performance: Processing is necessary for the performance of the contract between you and gerya (Terms and Conditions), including account creation, service delivery, payment processing, and customer support.
• Legal Obligation: Processing is required to comply with legal obligations imposed on gerya by Philippine law, including age verification requirements, anti-money laundering regulations, tax reporting obligations, and data retention mandates.
• Legitimate Interests: Processing serves legitimate business interests of gerya such as fraud prevention, security enhancement, Platform improvement, and analytics, provided such interests do not override your fundamental rights and freedoms.
• Vital Interests: In rare circumstances, processing may be necessary to protect vital interests of users or other individuals, such as when responding to medical emergencies or preventing imminent harm.

5. Information Sharing and Disclosure

gerya does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with carefully selected third parties under specific circumstances necessary for Platform operation, regulatory compliance, and service delivery. Information sharing occurs only when necessary and subject to appropriate safeguards:

5.1 Service Providers and Business Partners

gerya engages third-party service providers to perform functions on our behalf, including payment processing (GCash, PayMaya, bank payment gateways), game content delivery (slot providers, live casino operators), identity verification services, customer support platforms, email delivery systems, analytics providers, cybersecurity firms, and hosting infrastructure. These service providers have access to personal information only to the extent necessary to perform their designated functions and are contractually obligated to maintain confidentiality and data security comparable to gerya standards.

5.2 Regulatory Authorities and Law Enforcement

gerya may disclose personal information to government authorities, regulatory bodies, law enforcement agencies, or other official entities when required by law, legal process, court order, or regulatory investigation. This includes compliance with anti-money laundering reporting requirements, tax authority requests, criminal investigations, or national security matters. We may also disclose information when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of gerya, our users, or the public.

5.3 Business Transfers

In the event that gerya undergoes a business transaction such as merger, acquisition, corporate restructuring, sale of assets, or bankruptcy proceeding, your personal information may be transferred to the acquiring entity or successor organization. In such circumstances, we will notify affected users and ensure that the receiving party commits to protecting personal information in accordance with this Privacy Policy or obtaining consent for any material changes to data processing practices.

5.4 Consent-Based Sharing

With your explicit consent, gerya may share personal information with third parties for purposes not described in this Policy. You will be informed about the specific purpose and recipient before such sharing occurs, and consent requests will clearly explain what information will be shared and how it will be used by the recipient.

6. Data Security and Protection Measures

gerya implements comprehensive technical, organizational, and administrative security measures designed to protect personal information from unauthorized access, disclosure, alteration, destruction, or loss. While we employ industry-standard safeguards, no security system is entirely impenetrable, and we cannot guarantee absolute security. Our security measures include:

• Encryption: All data transmitted between your device and gerya servers is encrypted using 256-bit SSL/TLS protocols. Sensitive information including passwords and payment details is encrypted both in transit and at rest using advanced encryption algorithms.
• Access Controls: Personal information is accessible only to authorized gerya employees, contractors, and service providers who require access to perform their job functions. Access is granted on a need-to-know basis and subject to strict confidentiality obligations.
• Authentication Systems: User accounts are protected by secure password requirements, and we encourage use of strong, unique passwords. Multi-factor authentication options are available for enhanced account security.
• Network Security: gerya infrastructure is protected by firewalls, intrusion detection systems, malware protection, and regular security audits conducted by independent cybersecurity professionals.
• Data Segregation: Personal information is stored separately from publicly accessible Platform areas, with database architecture designed to prevent unauthorized cross-access between user accounts.
• Monitoring and Incident Response: Security monitoring systems continuously scan for suspicious activities, and we maintain incident response protocols to address security breaches promptly. In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by Philippine Data Privacy Act regulations.
• Employee Training: gerya staff receive regular training on data protection principles, security best practices, and privacy obligations to ensure consistent adherence to security policies.

7. Data Retention and Deletion

gerya retains personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on data type and applicable legal requirements:

Data Category	Retention Period	Reason
Account Information	Duration of account plus 5 years	Legal compliance, audit requirements
Transaction Records	7 years from transaction date	Tax law, anti-money laundering regulations
Identity Verification Documents	5 years after account closure	Regulatory compliance, fraud prevention
Customer Support Communications	3 years	Quality assurance, dispute resolution
Marketing Preferences	Until consent withdrawn	Opt-out compliance
Usage Analytics	2 years	Platform improvement, trend analysis

Upon expiration of applicable retention periods, personal information is securely deleted or anonymized such that it can no longer identify you. Account closure requests are processed in accordance with legal obligations, meaning some information must be retained despite closure for compliance purposes. You may request deletion of personal information not subject to mandatory retention by contacting gerya privacy team, though this may result in inability to continue using Platform services.

8. Cookies and Tracking Technologies

gerya uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance user experience, analyze Platform usage, remember preferences, and deliver personalized content. Cookies are small text files stored on your device that enable recognition across sessions. Categories of cookies used on the gerya Platform include:

• Strictly Necessary Cookies: Essential for Platform functionality, enabling account login, session management, security features, and transaction processing. These cookies cannot be disabled without impairing Platform usability.
• Performance Cookies: Collect anonymous data about how users interact with the Platform, including page views, load times, error messages, and navigation patterns. This information helps gerya identify technical issues and optimize performance.
• Functionality Cookies: Remember user preferences such as language selection, display settings, and previously visited game categories to provide a more personalized experience across sessions.
• Targeting/Advertising Cookies: Track user behavior across sessions to deliver relevant promotional content, bonus offers, and game recommendations based on demonstrated interests and gameplay history.

You can control cookie settings through your browser preferences, including options to block or delete cookies. However, disabling certain cookies may limit Platform functionality and prevent access to some features. Most browsers accept cookies by default, but you can configure settings to receive notification when cookies are sent or reject cookies entirely.

9. Your Privacy Rights

Under the Philippine Data Privacy Act, you possess specific rights regarding your personal information held by gerya. We respect these rights and provide mechanisms for exercising them:

• Right to Access: You may request confirmation of whether gerya processes your personal data and obtain copies of such data along with details about processing purposes, categories, recipients, and retention periods.
• Right to Rectification: You may request correction of inaccurate personal information or completion of incomplete data. Account information can be updated directly through Platform settings.
• Right to Erasure: You may request deletion of personal information when it is no longer necessary for the purposes collected, consent is withdrawn, or processing is unlawful. This right is subject to legal retention obligations.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing communications. We will cease processing unless compelling legitimate grounds override your interests.
• Right to Data Portability: You may request personal data in structured, commonly used, machine-readable format and have the right to transmit such data to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time, though this does not affect lawfulness of processing prior to withdrawal.
• Right to Lodge Complaint: You may file complaints regarding gerya data processing practices with the Philippine National Privacy Commission (NPC) if you believe your privacy rights have been violated.

To exercise any privacy rights, please contact gerya privacy team through customer support channels. We will respond to requests within timeframes required by Philippine Data Privacy Act (generally within 30 days). Identity verification may be required to process requests and protect against fraudulent submissions.

10. International Data Transfers

gerya primarily operates within the Philippines and stores personal information on servers located in or accessible from the Philippines. However, certain service providers and business partners may be located outside the Philippines, potentially resulting in cross-border data transfers. When personal information is transferred internationally, gerya ensures adequate protection through mechanisms such as standard contractual clauses, binding corporate rules, or verification that destination countries provide adequate data protection levels as recognized by the Philippine National Privacy Commission. You consent to such international transfers when necessary for Platform operation by accepting this Privacy Policy.

11. Children's Privacy

gerya services are strictly intended for individuals aged 21 years or older in accordance with Philippine gambling regulations. We do not knowingly collect personal information from minors under the legal gambling age. If we become aware that personal information has been collected from an individual under 21 years of age, we will take immediate steps to delete such information and terminate the associated account. Parents or guardians who discover that a minor has provided personal information to gerya should contact us immediately so we can take appropriate remedial action.

12. Third-Party Links and Services

The gerya Platform may contain links to third-party websites, applications, or services not operated or controlled by gerya. This Privacy Policy applies solely to information collected by gerya and does not govern data practices of external sites or services. We are not responsible for privacy policies, practices, or content of third-party platforms. We encourage you to review privacy policies of any third-party services before providing personal information. Links to external sites do not constitute endorsement or responsibility for their data handling practices.

13. Changes to This Privacy Policy

gerya reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in data processing practices, legal requirements, or Platform features. When material changes are made, we will notify users through prominent notice on the Platform, email communication to registered addresses, or other reasonable means. The "Last Updated" date at the end of this Policy indicates when the most recent revision was made. Continued use of the Platform following notification of changes constitutes acceptance of the revised Privacy Policy. We encourage periodic review of this Policy to stay informed about how gerya protects your personal information.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or gerya data processing practices, please contact our Data Protection Officer or privacy team through the following channels:

For complaints or concerns not satisfactorily addressed by gerya, you may contact the Philippine National Privacy Commission at: