pinasplay Privacy Policy

1. INTRODUCTION

This Privacy Policy ("Policy") describes how pinasplay ("the Company," "we," "us," or "our") collects, processes, stores, and protects the personal data of users ("you," "User," or "Player") who access or use the pinasplay online gaming platform, including the website at pinasplay.app, any associated mobile applications, and all related services (collectively, the "Platform").

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission ("NPC"). We also adhere to relevant guidelines issued by the Philippine Amusement and Gaming Corporation ("PAGCOR") regarding player data handling in the context of licensed gaming operations.

By registering an account or using any feature of the pinasplay Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the Platform.

2. DATA CONTROLLER

pinasplay acts as the Data Controller in respect of personal data collected through the Platform. As Data Controller, pinasplay determines the purposes and means of processing your personal information and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 and all applicable regulations.

We have appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy and with Philippine data privacy law. Contact details for the DPO are set out in Section 14 of this Policy.

3. PERSONAL DATA WE COLLECT

3.1 Information You Provide Directly

When you register, verify your identity, make transactions, or contact support, pinasplay may collect the following categories of personal data:

• Full legal name, date of birth, and nationality;
• Email address and Philippine mobile number;
• Residential address (barangay, city/municipality, province);
• Government-issued identification documents (e.g., Philippine passport, SSS, UMID, PhilSys ID, driver's license) submitted for KYC verification;
• Financial information, including GCash account numbers, Maya account details, bank account references (BDO, BPI), and transaction records;
• Source of funds declarations where required by AML compliance procedures.

3.2 Information Collected Automatically

When you access the Platform, certain technical data is collected automatically, including:

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser information;
• Session data, including login timestamps, session duration, and navigation paths;
• Game activity records, betting history, and wagering patterns;
• Cookie and tracking technology data as described in Section 7.

3.3 Information from Third Parties

pinasplay may receive personal data about you from third-party sources including payment processors (GCash, Maya, BDO, BPI), identity verification service providers, fraud prevention agencies, and PAGCOR in the context of regulatory compliance.

4. HOW WE USE YOUR PERSONAL DATA

pinasplay processes your personal data for the following purposes:

• Account Management: To create, maintain, and secure your pinasplay player account, including authentication and session management;
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and Philippine AML regulations;
• Payment Processing: To process deposits and withdrawals via GCash, Maya, BDO, BPI, 7-Eleven, USDT, and Coins.ph, and to maintain accurate financial records;
• Regulatory Compliance: To comply with obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, money laundering, multi-accounting, and other prohibited activities;
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To monitor gaming patterns and implement responsible gaming measures, including applying deposit limits and self-exclusion tools requested by the player;
• Service Improvement: To analyze Platform usage patterns, improve game offerings, and optimize the user experience for Filipino players;
• Marketing Communications: To send promotional offers, bonus notifications, and relevant updates where you have provided consent. You may withdraw marketing consent at any time via your account settings.

5. LEGAL BASIS FOR PROCESSING

pinasplay processes your personal data under the following legal bases as recognized by the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to provide the Platform services as agreed in the pinasplay Terms and Conditions, including account management, payment processing, and gameplay;
• Legal Obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, tax reporting requirements, and NPC directives;
• Legitimate Interest: Processing for fraud prevention, security monitoring, Platform improvement, and responsible gaming monitoring, where such interests do not override your data privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. Consent may be withdrawn at any time.

6. DATA SHARING AND DISCLOSURE

pinasplay does not sell your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash (GXI / GCash), Maya Philippines, BDO Unibank, Bank of the Philippine Islands, and other payment service providers necessary to process financial transactions;
• Identity Verification Providers: KYC and AML compliance service providers who assist in verifying identity documents and screening against sanctions lists;
• Game Content Providers: Licensed third-party game studios and live casino operators who may receive session data to facilitate gameplay;
• Regulatory Authorities: PAGCOR and other Philippine government agencies as required by law, court order, or regulatory directive;
• Technology and Cloud Service Providers: Infrastructure, hosting, analytics, and security service providers operating under data processing agreements that bind them to confidentiality and security obligations consistent with this Policy.

All third parties with whom pinasplay shares personal data are required to implement appropriate data protection measures and to process such data only for the specified purposes and in accordance with applicable Philippine law.

7. COOKIES AND TRACKING TECHNOLOGIES

The pinasplay Platform uses cookies and similar tracking technologies to operate certain Platform features, improve user experience, and support analytics. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled;
• Functional Cookies: Store your preferences, such as language settings and responsible gaming limit configurations;
• Analytics Cookies: Collect anonymized or aggregated data about Platform usage to help us understand how players interact with pinasplay and improve our services;
• Marketing Cookies: Used where you have provided consent to receive targeted promotions. These may be disabled via your browser settings or account preferences.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may impair Platform functionality, including login and session management.

8. DATA RETENTION

pinasplay retains your personal data for as long as your account is active and for a minimum period thereafter as required by law. Specific retention periods are as follows:

• Account and identity data: Retained for the duration of your account plus a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AMLA obligations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, consistent with AMLA and BIR requirements;
• Game and betting history: Retained for a minimum of one (1) year for dispute resolution purposes, and up to five (5) years where required by regulatory record-keeping obligations;
• Customer support communications: Retained for a minimum of two (2) years from the date of the communication;
• Marketing consent records: Retained for the duration of consent and for one (1) year following withdrawal of consent to document compliance.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

9. DATA SECURITY

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

• Transport Layer Security (TLS 1.3) encryption for all data transmitted between your device and our servers;
• Encryption at rest for sensitive personal and financial data stored on pinasplay infrastructure;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication for administrative systems and privileged access accounts;
• Regular security assessments, penetration testing, and vulnerability management programs;
• Incident response procedures with NPC notification protocols in the event of a personal data breach.

10. YOUR DATA SUBJECT RIGHTS

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pinasplay:

• Right to Be Informed: You have the right to be informed of how your personal data is collected and processed, as provided in this Policy;
• Right to Access: You may request a copy of the personal data pinasplay holds about you, along with information about how it is processed;
• Right to Correction: You may request correction of inaccurate or incomplete personal data in your pinasplay account;
• Right to Erasure / Right to be Forgotten: You may request deletion of your personal data where retention is no longer necessary for the purposes collected or where you have withdrawn consent, subject to legal retention obligations;
• Right to Object: You may object to processing of your personal data for direct marketing purposes or on grounds relating to your particular situation where processing is based on legitimate interest;
• Right to Data Portability: Where technically feasible, you may request a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the details in Section 14. pinasplay will respond to verified data subject requests within thirty (30) days. Identity verification may be required before processing a request.

11. CHILDREN'S PRIVACY

The pinasplay Platform is strictly intended for adults aged 21 years and above, consistent with Philippine law governing gambling. pinasplay does not knowingly collect personal data from persons under the age of 21. If we discover that personal data has been collected from a person under 21 years of age, we will immediately delete such data, close the associated account, and forfeit any associated balances in accordance with our Terms and Conditions.

If you have reason to believe that a minor has registered on the Platform, please notify us immediately at the contact details in Section 14.

12. INTERNATIONAL DATA TRANSFERS

Some of pinasplay's service providers and game content partners operate from outside the Philippines. Where personal data is transferred to countries outside the Philippines, pinasplay ensures that such transfers are made only:

• To countries recognized by the NPC as providing an adequate level of data protection; or
• Subject to appropriate contractual safeguards, including standard data processing agreements that impose obligations on the recipient consistent with the Data Privacy Act of 2012; or
• Where you have provided explicit consent to the transfer.

You may request information about the safeguards in place for international transfers of your data by contacting our Data Protection Officer.

13. UPDATES TO THIS POLICY

pinasplay may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance from the NPC or PAGCOR. When material changes are made, we will notify registered Players via email or in-Platform notification prior to the changes taking effect.

The effective date at the top of this Policy indicates when it was last revised. Continued use of the Platform following notification of changes constitutes your acknowledgement of the updated Policy. We encourage you to review this Policy periodically.

14. CONTACT THE DATA PROTECTION OFFICER

For questions about this Privacy Policy, to exercise your data subject rights, or to report a privacy concern, please contact the pinasplay Data Protection Officer:

You also have the right to file a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by pinasplay.