Privacy Policy — playpalph

1.1 playpalph is committed to protecting the privacy and personal data of every Filipino player who uses our platform. We understand that trust is the foundation of everything we do — and that trust extends to how we handle your personal information.

1.2 This Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC). It also reflects the data protection requirements applicable to online gaming operators under the regulatory framework of PAGCOR.

1.3 playpalph acts as the personal information controller in respect of the personal data collected through the Platform. This means we determine the purposes and means of processing your personal data and are responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

1.4 This Policy applies to all personal data collected from players located in the Philippines, including players in Metro Manila, Cebu, Davao, Quezon City, Makati, and all other regions of the Philippines.

2.1 playpalph collects the following categories of personal data from players and Platform users:

2.2 playpalph does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive data (such as government ID numbers) is collected, it is handled with the highest level of care and stored in encrypted form.

3.1 playpalph collects personal data through the following means:

• Direct collection: Information you provide when registering a playpalph account, completing identity verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and similar tracking technologies.
• Third-party sources: Identity verification data from government-issued ID documents you submit; payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank; fraud prevention data from third-party security providers.

3.2 You are not obligated to provide all requested personal data; however, failure to provide certain information (such as identity verification documents) may prevent playpalph from opening or maintaining your account or processing your transactions.

4.1 playpalph uses your personal data for the following purposes:

• To create, verify, and manage your playpalph account
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (₱)
• To verify your identity and age (21+) in compliance with PAGCOR requirements
• To comply with anti-money laundering (AML) and know-your-customer (KYC) obligations under Philippine law
• To detect, investigate, and prevent fraud, cheating, and other prohibited conduct
• To provide customer support and respond to your enquiries
• To send you transactional notifications (e.g., deposit confirmations, withdrawal updates)
• To send you promotional communications about playpalph offers and bonuses, where you have consented to receive such communications
• To personalise your experience on the playpalph Platform
• To monitor gameplay patterns for responsible gaming purposes and to identify players who may need support
• To improve the playpalph Platform, games, and services
• To comply with applicable Philippine laws and regulatory requirements

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

• Contractual necessity: Processing required to fulfil our obligations under the playpalph Terms & Conditions, including account management, transaction processing, and customer support.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, KYC requirements, PAGCOR reporting obligations, and tax laws.
• Legitimate interests: Processing carried out for playpalph's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, such as the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6.1 playpalph 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 only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and identity verification service providers who assist playpalph in verifying player identities and ages.
• Fraud prevention and security providers: Third-party providers who assist playpalph in detecting and preventing fraud, money laundering, and other prohibited activities.
• IT and platform service providers: Cloud hosting, data storage, and technology service providers who support the operation of the playpalph Platform.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by playpalph in connection with legal proceedings or compliance matters.

6.2 All third-party service providers engaged by playpalph are required to handle your personal data in accordance with applicable data protection laws and are prohibited from using your data for any purpose other than the specific service they provide to playpalph.

7.1 The playpalph Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and collect usage data. Cookies are small text files stored on your device when you visit the Platform.

7.2 playpalph uses the following types of cookies:

• Essential cookies: Necessary for the Platform to function correctly, including maintaining your login session and enabling secure transactions. These cookies cannot be disabled.
• Performance cookies: Used to collect anonymised data about how players use the Platform, helping us identify areas for improvement.
• Functional cookies: Used to remember your preferences and personalise your experience on the playpalph Platform.
• Analytics cookies: Used to understand player behaviour in aggregate, helping playpalph improve its games and services.

7.3 You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the playpalph Platform. For more information on managing cookies, refer to your browser's help documentation.

8.1 playpalph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the playpalph Platform
• Encryption of sensitive data stored in playpalph's databases
• Access controls limiting employee access to personal data on a need-to-know basis
• Regular security assessments and vulnerability testing
• Two-factor authentication options for player accounts
• Continuous monitoring for suspicious activity and potential security breaches

8.2 While playpalph takes all reasonable steps to protect your personal data, no data transmission over the internet or electronic storage system is completely secure. You are responsible for maintaining the security of your playpalph account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

9.1 playpalph retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law and PAGCOR regulations. Specifically:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and KYC regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Support and communications data: Retained for up to three (3) years following the resolution of the relevant matter.
• Technical and usage data: Retained for up to two (2) years, after which it is anonymised or deleted.

9.2 When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, playpalph will securely delete or anonymise the data in accordance with its data disposal procedures.

10.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by playpalph:

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data playpalph holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• 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 applicable legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

10.2 To exercise any of the above rights, please contact the playpalph Data Privacy Officer via our support team. playpalph will respond to your request within thirty (30) days, or within such other period as may be prescribed by the NPC.

11.1 The playpalph Platform is strictly intended for individuals aged 21 years and above. playpalph does not knowingly collect personal data from persons under the age of 21. This minimum age requirement is mandated by Philippine law and PAGCOR regulations governing online gaming.

11.2 If playpalph becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered a playpalph account, please contact our support team immediately.

12.1 The playpalph Platform may contain links to third-party websites or services. This Privacy Policy applies solely to the playpalph Platform and does not extend to any third-party websites. playpalph is not responsible for the privacy practices of third-party websites and encourages you to review the privacy policies of any third-party sites you visit.

12.2 The inclusion of any link on the playpalph Platform does not constitute an endorsement of the linked website or its privacy practices by playpalph.

13.1 playpalph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, playpalph will notify registered players via email or in-platform notification prior to the changes taking effect.

13.2 The most current version of this Privacy Policy will always be available on this page. The date of the most recent revision is indicated at the top of this document. Your continued use of the playpalph Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms.

13.3 We encourage you to review this Privacy Policy periodically to stay informed about how playpalph protects your personal data.

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the way playpalph handles your personal data, please contact our Data Privacy Officer and support team:

14.2 You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that playpalph has not handled your personal data in accordance with the Data Privacy Act of 2012. The NPC can be reached through its official government channels.

14.3 playpalph is committed to resolving all data privacy concerns promptly and professionally. Our dedicated support team is available around the clock to assist Filipino players with any questions about this Privacy Policy or your playpalph account.