playph Privacy Policy

1 Introduction

playph ("playph," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the playph online gaming platform at playph.vip. We understand that trust is the foundation of any relationship between a player and their gaming platform, and we take our data protection obligations seriously.

This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). Where applicable, we also observe the data protection requirements imposed by PAGCOR as part of our regulatory obligations.

This Policy describes the personal data we collect from you, the purposes for which we process it, the parties with whom we may share it, the security measures we apply to protect it, and the rights you have as a data subject under Philippine law. Please read this Policy carefully. If you have questions, our Data Protection Officer is available to assist you – contact details are provided in Section 14.

2 Personal Data We Collect

playph collects the following categories of personal data, depending on how you interact with the Platform:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (used to verify you are 21 years of age or older)
• Nationality and country of residence
• Email address and mobile phone number
• Residential address, including barangay, city or municipality, province, and postal code

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie photographs submitted for liveness verification purposes
• Source-of-funds documentation where required by anti-money laundering regulations

2.3 Financial Data

• GCash or PayMaya account numbers linked to your playph wallet
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank)
• Debit card details (card number, expiry date – we do not store full card numbers; these are tokenised by our payment processor)
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment methods

2.4 Gaming Activity Data

• Game session records, including games played, wagers placed, outcomes, and timestamps
• Account balance history and bonus usage records
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Customer support interaction records

2.5 Technical and Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Mobile network operator (Globe, Smart, DITO, etc.)
• Pages visited, features used, and time spent on the Platform
• Cookie identifiers and similar tracking technologies (see Section 7)

3 How We Collect Your Data

playph collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Data collected automatically when you access the Platform, including technical data collected via cookies, web beacons, and server logs.
• Third-party sources: Data received from identity verification service providers, payment processors, fraud prevention services, and PAGCOR or other regulatory bodies where required by law.
• Publicly available sources: In limited circumstances, data from publicly available sources such as government databases used for sanctions screening and anti-money laundering checks.

4 How We Use Your Personal Data

playph processes your personal data for the following purposes:

playph does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, playph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing and Disclosure

playph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

6.1 Service Providers and Data Processors

• Payment processors: GCash, PayMaya, and banking partners for the purpose of processing deposits and withdrawals in Philippine Peso (₱).
• Identity verification providers: Third-party KYC and liveness verification services used to confirm your identity and age.
• Fraud prevention and AML screening services: Providers that screen transactions and player profiles against sanctions lists and fraud databases.
• Cloud infrastructure and hosting providers: Secure data centre operators that host the playph Platform and its databases.
• Customer support platform providers: Tools used to manage and respond to player support enquiries.

All third-party service providers acting as data processors on our behalf are bound by data processing agreements that require them to process personal data only on our documented instructions and to implement appropriate security measures.

6.2 Regulatory and Law Enforcement Authorities

playph is required by Philippine law to disclose personal data to the following authorities in specified circumstances:

• PAGCOR: As our regulatory authority, PAGCOR may require access to player data for audit, compliance, and enforcement purposes.
• Anti-Money Laundering Council (AMLC): We are required to report covered and suspicious transactions to the AMLC under the Anti-Money Laundering Act.
• National Privacy Commission (NPC): In the event of a personal data breach, we are required to notify the NPC and affected data subjects within the timeframes prescribed by the DPA.
• Courts and law enforcement: Where required by a valid court order, subpoena, or lawful request from Philippine law enforcement authorities.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of playph's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. We will notify registered players of any such transfer via email or a prominent notice on the Platform prior to the transfer taking effect.

7 Cookies & Tracking Technologies

playph uses cookies and similar tracking technologies on the playph.vip website to enhance your experience, maintain session security, and gather analytics data that helps us improve the Platform.

7.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymised data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data is used solely to improve the Platform.
• Marketing cookies: Used only with your explicit consent to track the effectiveness of our promotional campaigns. These are not used to build profiles for third-party advertising.

7.2 Managing Cookies

You can control non-essential cookies through the cookie preference centre accessible from the footer of the playph.vip website. You may also configure your browser to block or delete cookies; however, disabling strictly necessary cookies will impair the functionality of the Platform and may prevent you from accessing your account.

playph does not use third-party advertising networks or social media tracking pixels that would allow external parties to build profiles of your browsing behaviour across other websites.

8 Data Retention

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

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA requirements.
• Gaming activity logs: Retained for three (3) years from the date of each session, or longer where required for dispute resolution or regulatory purposes.
• Customer support records: Retained for two (2) years from the date of resolution of the relevant support interaction.
• Marketing consent records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent, whichever is later.
• Technical and usage data: Anonymised or deleted within twelve (12) months of collection, unless required for ongoing security investigations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with playph's data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it is isolated from active processing until deletion is completed.

9 Data Security

playph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the playph Platform.
• Encryption at rest for all sensitive personal data and financial records stored in our databases.
• Multi-factor authentication for all administrative access to systems that process personal data.
• Role-based access controls ensuring that playph staff can only access personal data that is strictly necessary for their job function.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• 24/7 security monitoring with automated alerts for suspicious access patterns or potential data breaches.
• Tokenisation of payment data so that full financial account details are never stored on playph's servers.

While playph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying playph immediately if you suspect any unauthorised access to your account.

10 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by playph. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to obtain a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected without undue delay.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data on grounds of legitimate interests or for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

playph will respond to all data subject requests within fifteen (15) business days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further fifteen (15) business days, with prior notice to you. We may need to verify your identity before processing your request to protect against fraudulent access to another person's data.

11 Children's Privacy and Age Restrictions

The playph Platform is strictly intended for individuals who are 21 years of age or older, in accordance with the minimum legal age for casino-style gambling in the Philippines. playph does not knowingly collect personal data from individuals under the age of 21.

If playph becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the personal data in question, and return any deposits made, in accordance with our age verification procedures and applicable PAGCOR regulations.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account on the playph Platform, please contact our Data Protection Officer immediately using the contact details in Section 14.

12 International Data Transfers

playph primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from servers or service providers located outside the Philippines, for example where we use cloud infrastructure providers or third-party KYC verification services with operations in other countries.

Where personal data is transferred outside the Philippines, playph ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards may include:

• Data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission.
• Transfers to countries or organisations that the NPC has determined provide an adequate level of data protection.
• Binding corporate rules where transfers occur within a corporate group.

You may request further information about the specific safeguards applied to international transfers of your personal data by contacting our Data Protection Officer.

13 Changes to This Privacy Policy

playph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email and by posting a prominent notice on the playph.vip website at least fourteen (14) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how playph protects your personal data. Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgement of the updated Policy.

If you do not agree with any changes to this Privacy Policy, you should cease using the Platform and may request account closure by contacting our customer support team.

14 Contact & Data Protection Officer

playph has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO:

Our DPO is available to respond to data privacy enquiries during Philippine business hours, Monday to Friday, 9:00 AM to 6:00 PM (PHT). We aim to acknowledge all privacy-related enquiries within two (2) business days and to provide a substantive response within fifteen (15) business days.

If you are not satisfied with our response to your privacy enquiry, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about how to file a complaint with the NPC is available on the NPC's official website.