GXGX Link Privacy Policy

1 Scope and Who We Are

This Privacy Policy applies to all personal data collected, processed, and stored by GXGX Link ("gxgx link," "we," "us," or "our") in connection with your use of the gxgx link platform, website, mobile application, games, and related services (collectively the "Platform").

GXGX Link is a PAGCOR-licensed online gaming platform operating in the Philippines. As a data controller under the Philippines' Data Privacy Act of 2012 (Republic Act 10173), gxgx link is responsible for the lawful, fair, and transparent processing of all personal data collected from players and visitors on the Platform.

This policy should be read alongside our Terms and Conditions and our Responsible Gaming Policy, all of which form part of the agreement between you and gxgx link.

2 Personal Data We Collect

GXGX Link collects only the personal data that is necessary for the legitimate operation of the Platform and for meeting our obligations as a PAGCOR-licensed gaming operator. The categories of data we collect include:

2.1 Registration and Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — all players must be 18 or older)
• Mobile number and email address
• Username and hashed (encrypted) password
• Government-issued ID details (for KYC verification as required by PAGCOR)
• Residential address in the Philippines

2.2 Financial and Transaction Data

• GCash or Maya account number linked to your gxgx link account
• Bank account details provided for withdrawals via BDO, BPI, or UnionBank
• Records of all deposits, withdrawals, and in-game transactions on the Platform
• Bonus usage and promotional activity history

2.3 Gaming and Activity Data

• Game session logs, bet amounts, and game outcomes
• Login timestamps, session duration, and access device information
• Responsible gaming settings applied to your account
• Customer support communication history

2.4 Technical and Device Data

• IP address at the time of login and account activity
• Device type, operating system, and browser version
• Mobile network operator and approximate geographic location (city level)
• Cookie and session identifiers (see Section 10)

3 How We Collect Your Data

GXGX Link collects personal data through the following channels:

• Direct Submission: Data you provide when registering your gxgx link account, completing identity verification, making a deposit or withdrawal, contacting our support team, or participating in a promotion.
• Automated Platform Data: Data collected automatically as you use the Platform, including login events, game session activity, device identifiers, and browser data through cookies and similar tracking technologies.
• Third-Party Verification Services: Identity and age verification data from authorised third-party KYC providers used by gxgx link to comply with PAGCOR's player verification requirements.
• Payment Processors: Transaction confirmation data from GCash, Maya, banks, and other payment processors when you make deposits or request withdrawals on the gxgx link platform.

GXGX Link does not purchase personal data lists from third-party data brokers and will never contact you using data acquired from sources unrelated to your use of the Platform.

4 How We Use Your Personal Data

GXGX Link uses your personal data for the following purposes:

GXGX Link will not use your personal data for any purpose not listed above without first seeking your explicit consent or establishing a new lawful basis for processing.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, gxgx link processes your personal data on the following legal bases:

• Contract Performance: Processing necessary to provide you with the gxgx link gaming services you have registered for — including account management, transaction processing, and game delivery.
• Legal Obligation: Processing required by Philippine law, including PAGCOR regulatory requirements for identity verification, age verification, and transaction monitoring; and obligations under the Anti-Money Laundering Act (RA 9160, as amended).
• Legitimate Interest: Processing for fraud detection, platform security, analytics, and responsible gaming monitoring — provided these interests are not overridden by your rights and freedoms.
• Consent: For any processing not covered by the above — particularly marketing communications and optional data collection — gxgx link will seek your explicit, informed, and freely given consent before proceeding.

6 How We Share Your Data

GXGX Link does not sell, rent, or trade your personal data. We may share your data only in the following limited circumstances:

• Payment Processors: GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet providers, and partner banks require certain transaction details to process your deposits and withdrawals. Only the minimum data necessary is shared with each processor.
• Identity Verification Providers: Third-party KYC providers contracted by gxgx link to verify player identities as required by PAGCOR. These providers operate under strict data processing agreements and are not permitted to use your data for any other purpose.
• Game Providers: Licensed game providers (such as JILI) may receive anonymised gameplay data to support game operation and technical troubleshooting. Personally identifiable information is not shared with game providers except where technically required.
• Regulatory Authorities: PAGCOR and other Philippine government agencies including the Anti-Money Laundering Council (AMLC) and the National Privacy Commission (NPC) may require disclosure of player data pursuant to their lawful regulatory functions. GXGX Link will comply with all lawful government requests.
• Law Enforcement: Where required by a valid court order, warrant, or other lawful directive from Philippine law enforcement authorities.

7 How Long We Keep Your Data

GXGX Link retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account Data: Retained for the duration of your active gxgx link account plus 5 years after account closure, in compliance with PAGCOR record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of 5 years following the date of each transaction, in accordance with the Anti-Money Laundering Act and relevant PAGCOR regulations.
• KYC and Identity Documents: Retained for 5 years following account closure or the completion of any related investigation, whichever is later.
• Customer Support Communications: Retained for 3 years from the date of the communication to support dispute resolution and platform improvement.
• Marketing Consent Records: Retained for the duration of your consent and for 3 years following withdrawal of consent, to evidence compliance.
• Anonymised Analytics Data: May be retained indefinitely as it cannot be used to identify individual players.

When personal data is no longer required, gxgx link will securely delete or anonymise it in accordance with our internal data deletion procedures.

8 How We Secure Your Data

GXGX Link implements a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the gxgx link platform is encrypted using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Sensitive personal data stored on gxgx link servers is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within gxgx link's operations is restricted on a strict need-to-know basis. Staff accessing player data are bound by confidentiality obligations and undergo regular data privacy training.
• Two-Factor Authentication (2FA): Available to all gxgx link players to add an extra layer of security to their accounts.
• Regular Security Audits: GXGX Link's platform undergoes regular independent security assessments to identify and address vulnerabilities.
• Incident Response: In the event of a personal data breach, gxgx link will notify affected players and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by RA 10173 and NPC regulations.

9 Your Data Rights

Under the Data Privacy Act of 2012 (RA 10173), all Filipino data subjects have the following rights with respect to their personal data. GXGX Link is committed to honouring all of these rights promptly and without unnecessary obstacles:

To exercise any of these rights, contact the gxgx link Data Protection Officer at privacy@gxgxlink.com or through our customer support team. We will respond to all valid data rights requests within 15 business days. Where a request is complex or involves a high volume of data, we may extend this period by a further 15 business days with notification to you.

10 Cookies and Tracking Technologies

GXGX Link uses cookies and similar tracking technologies on the Platform to improve your experience, maintain your session, and analyse how the Platform is used. Here is a breakdown of the types of cookies we use:

• Essential Cookies: Necessary for the Platform to function. These include session cookies that keep you logged in during your gxgx link gaming session. You cannot opt out of these without disabling the Platform entirely.
• Analytics Cookies: Used to collect anonymised data about how players navigate the gxgx link platform — which pages are visited, how long sessions last, and which features are used most. This helps us improve the Platform. Analytics data is aggregated and not linked to individual players.
• Functional Cookies: Remember your preferences such as language, display settings, and previously selected game options to personalise your gxgx link experience.
• Marketing Cookies: Used only where you have given explicit consent, to present relevant promotions and bonus offers based on your in-platform activity. You can withdraw consent for marketing cookies at any time through your account settings.

11 Minors and Under-18 Protection

The gxgx link platform is strictly intended for use by adults aged 18 years and above. We do not knowingly collect personal data from individuals under 18 years of age. If you are under 18, you must not register for or use the gxgx link platform.

If GXGX Link becomes aware that a registered account belongs to a player under the age of 18, the account will be immediately suspended, all collected data will be deleted (except where required to be retained for legal compliance purposes), and any funds in the account will be handled in accordance with PAGCOR regulations.

Parents and guardians who believe their child has accessed or registered on the gxgx link platform should contact our support team immediately at support@gxgxlink.com so we can take appropriate action promptly.

12 Cross-Border Data Transfers

The gxgx link platform primarily stores and processes personal data within the Philippines. However, certain technical infrastructure, cloud services, and game provider systems may involve the transfer of data to servers located in other countries.

Where cross-border data transfers occur, gxgx link ensures that the receiving country or organisation provides an adequate level of protection for personal data — at minimum equivalent to the protections afforded by the Data Privacy Act of 2012. This is achieved through:

• Data processing agreements with all international data processors incorporating the NPC's standard contractual clauses
• Transfers only to jurisdictions with recognised adequate data protection standards
• Regular review of international partner compliance with data protection obligations

You have the right to request information about specific cross-border transfers involving your personal data by contacting our Data Protection Officer.

13 Changes to This Privacy Policy

GXGX Link may update this Privacy Policy from time to time to reflect changes in our data practices, changes to Philippine law, or new PAGCOR guidelines. When we make material changes to the Policy, we will notify you by:

• Sending a notification to the mobile number registered on your gxgx link account
• Displaying a notice on the gxgx link platform at login
• Updating the "Last Updated" date shown at the top of this page

If the changes are material and require your consent under RA 10173, we will ask for your explicit agreement before the new terms take effect. For non-material updates, your continued use of the gxgx link platform after the effective date of the revised policy will constitute your acceptance.

Previous versions of this Privacy Policy are available upon request from our Data Protection Officer.

14 Contact Our Data Protection Officer

GXGX Link has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to the way gxgx link handles your personal data, you can reach our DPO through the following channels:

• Email (DPO): privacy@gxgxlink.com
• General Support: support@gxgxlink.com
• Live Chat: Available 24/7 directly on the gxgx link platform
• FAQ: Visit our FAQ page for common privacy-related questions

We are committed to resolving all privacy-related concerns promptly and fairly. If, after contacting us, you remain unsatisfied with our response, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines.