playtame Privacy Policy

1. Who We Are (Data Controller)

playtame ("the Company", "we", "us", "our") is the data controller responsible for the personal information processed through the playtame website and mobile platform at playtame.app. playtame operates under a valid PAGCOR authorization and is subject to the data protection obligations applicable to licensed online gaming operators in the Philippines.

This Privacy Policy applies to all personal information collected from registered users, visitors to the Platform, and individuals who communicate with playtame via any channel including live chat, email, or support tickets. It does not apply to third-party websites or services that may be linked to or referenced on the Platform.

2. Personal Data We Collect

playtame collects personal data through your registration, use of the Platform, and interactions with our support team. The categories of data collected include:

playtame does not intentionally collect sensitive personal information (as defined under RA 10173) beyond what is strictly required for KYC, age verification, and PAGCOR-mandated responsible gaming compliance. We do not collect health information, political opinions, religious beliefs, or biometric data beyond facial photographs used for identity verification.

3. How We Use Your Personal Data

playtame uses your personal data for the following purposes:

• Account Registration & Management: To create and maintain your playtame account, verify your identity, enforce the 21+ age requirement, and process your KYC documentation.
• Transaction Processing: To process deposits via GCash, PayMaya, BPI, BDO, and other approved Philippine payment channels, and to process withdrawal requests to your verified payment method.
• Platform Delivery: To provide access to games, live dealer tables, sports betting, and all other Platform features your account is eligible for.
• Regulatory Compliance: To comply with PAGCOR operating requirements, Philippine Anti-Money Laundering Act (AMLA) obligations, and NPC data protection requirements including mandatory breach notification.
• Responsible Gaming: To monitor gaming patterns and enforce responsible gaming tools including deposit limits, session controls, and self-exclusion orders, in line with PAGCOR's responsible gaming framework.
• Security & Fraud Prevention: To detect and prevent unauthorized account access, bonus abuse, money laundering, and other fraudulent activity on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and maintain records of our communications with you.
• Marketing Communications: With your explicit consent, to send you promotions, bonus offers, and platform news relevant to your preferences. You may opt out at any time.
• Platform Improvement: To analyze aggregated, anonymized usage data to improve game offerings, payment flows, and the overall user experience on playtame.

4. Legal Basis for Processing

Under RA 10173, playtame processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to fulfil our agreement with you — account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLA reporting duties, and NPC-mandated data protection obligations.
• Legitimate Interest: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights.
• Consent: Marketing communications and certain cookie deployments, where your explicit opt-in consent has been obtained and can be withdrawn at any time.

5. Data Sharing & Third Parties

playtame does not sell your personal data. We share your data only with the following categories of recipients and only to the extent necessary for the stated purpose:

• PAGCOR: As required under our operating license, including player activity reports and responsible gaming compliance data.
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports and covered transaction reports as mandated by the AMLA.
• Payment Processors: GCash (G-Xchange Inc.), PayMaya (Maya Bank), BPI, BDO, and Metrobank — only the data necessary to process your specific transaction.
• KYC & Identity Verification Providers: Third-party identity verification services used to validate government IDs submitted during KYC, operating under strict data processing agreements.
• Game Providers: JILI, Pragmatic Play, Evolution, PG Soft, and other certified providers receive only a pseudonymous session token — not your full identity data.
• Cloud Infrastructure Providers: Hosting and data storage providers operating under contracts that include the data protection requirements of RA 10173.
• Law Enforcement: Where required by a valid Philippine court order or lawful request from a law enforcement authority.

6. Cookies & Tracking Technologies

playtame uses cookies and similar technologies to operate the Platform, maintain your login session, prevent fraud, and — with your consent — deliver relevant promotional content. The categories of cookies used are:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled.
• Functional Cookies: Remember your language preferences, game lobby layout, and responsible gaming settings between sessions.
• Analytics Cookies: Used in anonymized or aggregated form to understand how players navigate the Platform and identify areas for improvement. Deployed only with your consent.
• Marketing Cookies: Used to serve relevant playtame promotions within the Platform. Deployed only with your explicit consent, which can be withdrawn via your account privacy settings.

You can manage your cookie preferences via your playtame account settings or your browser's cookie management tools. Note that disabling strictly necessary cookies will impair Platform functionality.

7. Data Retention

playtame retains your personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with our legal obligations. Specific retention periods are as follows:

• Account & KYC Records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and AMLA record-keeping obligations.
• Financial Transaction Records: Retained for ten (10) years in compliance with the AMLA and Bureau of Internal Revenue requirements.
• Gaming Activity Logs: Retained for three (3) years for dispute resolution and responsible gaming audit purposes.
• Support Communications: Retained for two (2) years following resolution of the relevant inquiry or dispute.
• Marketing Consent Records: Retained for the duration of your account plus one (1) year following account closure.

When retention periods expire, playtame securely deletes or anonymizes the relevant data so that it can no longer be associated with you.

8. Data Security

playtame implements technical and organizational measures appropriate to the risks associated with processing personal data in the online gaming context. These measures include:

• TLS 1.3 encryption for all data in transit between your device and playtame servers.
• AES-256 encryption for sensitive data at rest, including stored payment method references and KYC documents.
• Multi-factor authentication requirements for administrative access to systems that process personal data.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular third-party penetration testing and security audits.
• A documented data breach response procedure with NPC notification timelines as required under RA 10173 IRR.

Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in harm to affected individuals, playtame will notify the NPC within 72 hours and affected users without undue delay, as required by Philippine law.

9. Your Rights as a Data Subject

Under RA 10173, all playtame users who are Philippine data subjects have the following rights with respect to their personal data:

• Right to Be Informed: To know what personal data playtame holds about you and how it is used — as set out in this Policy.
• Right of Access: To request a copy of the personal data playtame holds about you.
• Right to Rectification: To request correction of inaccurate or incomplete personal data.
• Right to Erasure: To request deletion of your personal data where there is no overriding legal basis for retention.
• Right to Object: To object to processing based on legitimate interests, including direct marketing.
• Right to Data Portability: To receive your personal data in a structured, commonly used format for transfer to another service, where technically feasible.
• Right to Lodge a Complaint: To file a complaint with the National Privacy Commission if you believe playtame has mishandled your personal data.

To exercise any of these rights, contact our Data Protection Officer at the details in Section 13. playtame will respond to verifiable requests within thirty (30) days, or sixty (60) days for complex requests, in accordance with NPC guidelines.

10. Children's Privacy — 21+ Requirement

The playtame Platform is strictly restricted to individuals who are at least 21 years of age, in compliance with Philippine online gambling regulations. playtame does not knowingly collect personal data from any person under 21 years of age. If we become aware that personal data has been collected from a person under 21, that account will be immediately suspended, the data will be deleted, and any balance will be refunded to the depositing payment method after identity verification.

11. Cross-Border Data Transfers

Certain service providers engaged by playtame — including cloud infrastructure providers and certified game studios — may process data outside the Philippines. Where such transfers occur, playtame ensures that appropriate safeguards are in place in accordance with Section 21 of RA 10173, including standard contractual clauses, data processing agreements that mandate equivalent data protection standards, and, where required, NPC notification of cross-border data sharing arrangements.

playtame does not transfer personal data to jurisdictions that the NPC has identified as providing inadequate data protection without implementing additional safeguards.

12. Policy Changes

playtame may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or PAGCOR regulatory requirements. Where changes are material, we will provide at least seven (7) days' advance notice via email to your registered address and a notice on the Platform dashboard. The "Last updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of the Platform following the effective date of any revision constitutes your acknowledgement of the updated Policy.

13. Contact & Data Protection Officer

For all data privacy inquiries, requests to exercise your data subject rights, or concerns about this Policy, please contact playtame's Data Protection Officer:

Data Protection Officer — playtame
Email: [email protected]
Subject line: "Data Privacy Request — [Your Full Name]"

Our DPO is available 24/7 via live chat on the Platform for general data privacy questions. For formal data subject requests, written correspondence via email is preferred to ensure a proper audit trail. playtame will acknowledge receipt of all formal requests within five (5) business days.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you are dissatisfied with playtame's handling of your personal data.