Privacy Policy

1. Who We Are (Data Controller)

playtame operates the online gaming platform accessible at playtame.org and serves as the Data Controller for personal data processed in connection with your playtame account and use of the platform. playtame is a PAGCOR-licensed online gaming operator registered and operating in the Republic of the Philippines.

As Data Controller, playtame determines the purposes and means by which your personal data is processed. All processing activities described in this Privacy Policy are carried out by playtame or by third-party processors acting under playtame's documented instructions, subject to data processing agreements consistent with the requirements of Republic Act 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations.

playtame has designated a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and this Privacy Policy. The DPO can be contacted through the contact details in Section 15 of this Policy.

2. Personal Data We Collect

The following categories of personal data are collected and processed by playtame in the course of operating the platform and your account:

3. How We Collect Your Data

playtame collects personal data through the following channels:

• Direct collection: Data you provide during account registration, KYC document submission, payment transactions, and customer support interactions.
• Automated collection: Technical data automatically collected when you access the playtame platform, including IP address, device identifiers, and session data via server logs and cookies.
• Third-party sources: Identity verification data received from PAGCOR-approved KYC verification providers in connection with the verification of identity documents submitted during registration.
• Payment processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners to confirm deposit and withdrawal completion.

playtame does not collect personal data from social media platforms, data brokers, or third-party marketing sources.

4. Lawful Basis for Processing

Under the Philippines Data Privacy Act, all personal data processing must have a lawful basis. playtame relies on the following lawful bases for processing personal data:

• Contractual necessity: Processing necessary to perform the contract between you and playtame — operating your account, processing transactions, providing gaming services, and managing bonuses.
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and Data Privacy Act requirements.
• Legitimate interests: Processing necessary for playtame's legitimate interests in fraud prevention, platform security, account integrity, and responsible gaming monitoring, where such interests do not override your fundamental privacy rights.
• Consent: Where required by law for processing not covered by the above bases, playtame will seek your express consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. How We Use Your Personal Data

playtame uses personal data for the following purposes:

• Creating and managing your playtame account, including authentication and security.
• Conducting KYC identity and age verification as required by PAGCOR and applicable Philippine law.
• Processing deposits and withdrawals through your selected payment methods.
• Providing access to gaming services, bonus programmes, and promotions.
• Monitoring gaming activity for responsible gaming purposes, including application of self-imposed limits and self-exclusion.
• Detecting, investigating, and preventing fraud, money laundering, and prohibited conduct in compliance with AMLA obligations.
• Providing customer support via live chat and email channels.
• Complying with PAGCOR reporting obligations, including regulatory data submissions and exclusion register reporting.
• Conducting platform security monitoring and fraud prevention analytics.
• Sending transactional communications including account activity notifications, withdrawal confirmations, and security alerts to your registered mobile number or email address.

playtame does not use personal data for automated decision-making that produces legal or similarly significant effects without human review, except where such processing is explicitly permitted under PAGCOR regulatory requirements.

6. Data Sharing and Disclosure

playtame shares personal data with third parties only in the following defined circumstances:

Regulatory and Law Enforcement Authorities

playtame is required to share certain personal data and transaction information with PAGCOR under its licensing obligations, including gaming activity reports and exclusion register notifications. playtame will also disclose personal data to the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities where legally required by court order, regulatory directive, or applicable law.

Payment Processors

Transaction data is shared with GCash (G-Xchange Inc.), PayMaya (Maya Bank Inc.), BPI, BDO, Metrobank, and 7-Eleven (E-Cliq) as necessary to process your deposits and withdrawals. These entities process data as independent controllers under their own privacy policies and applicable financial regulations.

KYC Verification Providers

Identity document data submitted during KYC verification is processed by playtame's PAGCOR-approved third-party identity verification provider solely for the purpose of verifying the authenticity of documents and confirming your identity and age.

Technology Providers

playtame's game software providers may receive gaming session data as necessary to deliver and operate their games on the playtame platform. These providers act as data processors under contractual data processing agreements consistent with RA 10173 requirements.

No Commercial Sale of Data

playtame does not sell, rent, trade, or commercially share personal data with any third party for marketing, advertising, or commercial purposes. This is an absolute commitment with no exceptions.

7. Cookies and Tracking Technologies

playtame uses cookies and similar tracking technologies to operate the platform and maintain session security. The following cookie categories are used:

• Essential cookies: Required for platform operation, including session authentication tokens that keep you logged in to your playtame account during an active session. These cannot be disabled without preventing platform access.
• Security cookies: Used to detect and prevent fraudulent access attempts, including CSRF protection tokens and device fingerprinting used for fraud risk assessment.
• Analytics cookies: Used to understand platform usage patterns and improve the player experience. Analytics data is aggregated and does not identify individual players in analytics reports.

playtame does not use third-party advertising or retargeting cookies. Your browser's cookie settings allow you to manage or delete cookies; however, disabling essential cookies will prevent you from accessing your playtame account.

8. Data Retention

playtame retains personal data for the following periods, after which data is securely deleted or anonymised:

• Account and identity data: Retained for the duration of the account relationship plus five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Philippines' Anti-Money Laundering Act.
• Transaction and financial data: Retained for five (5) years from the date of each transaction, as required by AMLA and PAGCOR regulatory obligations.
• KYC documentation: Retained for five (5) years following account closure or last transaction, whichever is later, as required by PAGCOR and AMLC regulations.
• Gaming session data: Retained for three (3) years from the date of each session, for regulatory reporting and dispute resolution purposes.
• Customer support records: Retained for two (2) years from the date of each interaction.
• Self-exclusion records: Retained permanently to prevent re-registration by self-excluded individuals, in compliance with PAGCOR responsible gaming requirements.

9. Data Security

playtame implements technical and organisational security measures appropriate to the sensitivity of personal data processed, including:

• 256-bit TLS/SSL encryption for all data transmitted between your device and playtame's servers.
• AES-256 encryption for sensitive data stored in playtame databases, including identity document data and financial account references.
• Role-based access controls limiting internal access to personal data to staff with a documented operational need, under individual accountability and audit logging.
• Two-factor authentication requirements for all playtame staff accessing production systems containing personal data.
• Regular penetration testing and vulnerability assessments of playtame's platform infrastructure.
• Third-party processor security assessments prior to engagement and on a periodic basis thereafter.

Notwithstanding these measures, no internet transmission or electronic storage system is guaranteed to be completely secure. In the event of a security breach affecting your personal data, playtame will notify you and the National Privacy Commission as described in Section 15 below and in compliance with NPC Circular 16-03.

10. Your Data Subject Rights

Under the Philippines Data Privacy Act (RA 10173), you have the following rights with respect to your personal data held by playtame:

• Right to be informed: The right to know that playtame is collecting and processing your personal data, as provided in this Privacy Policy.
• Right of access: The right to obtain confirmation of whether playtame processes your personal data and, if so, to receive a copy of the personal data held about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held in your playtame account.
• Right to erasure: The right to request deletion of your personal data, subject to playtame's mandatory retention obligations under PAGCOR licensing, AMLA, and other applicable laws, which may override deletion requests for specific data categories during their mandated retention periods.
• Right to object: The right to object to processing of your personal data carried out on the basis of legitimate interests, where you believe your fundamental rights override those interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to damages: The right to claim compensation for damages suffered as a result of inaccurate, incomplete, outdated, or unlawfully obtained personal data, as provided under RA 10173.

To exercise any of the above rights, contact playtame's Data Protection Officer using the contact details in Section 15. playtame will respond to data subject rights requests within 15 business days of receipt.

11. Children's Privacy — Under-21 Restriction

The playtame platform is strictly prohibited for use by individuals under 21 years of age. This is a mandatory requirement under PAGCOR regulation for casino-style online gaming in the Philippines, and it extends to the collection of personal data — playtame does not knowingly collect personal data from individuals under 21 years of age.

All registration attempts are subject to KYC age verification. Where playtame identifies or has reasonable grounds to believe that personal data has been submitted by or on behalf of an individual under 21 years of age, the account will be suspended immediately, all associated personal data will be deleted to the extent permissible under law, and the matter will be reported to PAGCOR.

If a parent or guardian believes that a minor has accessed or registered on the playtame platform, please contact playtame support immediately via live chat or email for urgent account review and data deletion where applicable.

12. Cross-Border Data Transfers

Some of playtame's third-party service providers — particularly game software providers and cloud infrastructure partners — may process personal data on servers located outside the Republic of the Philippines. Where personal data is transferred outside the Philippines, playtame ensures that such transfers are subject to appropriate safeguards, including:

• Data processing agreements containing standard contractual clauses consistent with the NPC's cross-border transfer requirements under RA 10173.
• Transfer only to countries or organisations that the NPC has determined provide an adequate level of data protection.
• Contractual requirements on third-party processors to implement security standards consistent with or exceeding playtame's own security requirements.

By creating and using a playtame account, you acknowledge that your personal data may be processed in jurisdictions outside the Philippines in the circumstances described above, subject to the safeguards specified herein.

13. Responsible Gaming Data Processing

playtame processes gaming session data, financial transaction patterns, and responsible gaming tool usage specifically for the purposes of administering PAGCOR-required responsible gaming obligations. This includes:

• Monitoring gaming behaviour against self-imposed limits and alerting account holders when limits are approaching or have been reached.
• Administering cooling-off periods and self-exclusion requests, including ensuring that self-excluded accounts cannot be re-registered during the exclusion period.
• Reporting self-excluded players to PAGCOR's central exclusion register as required under PAGCOR responsible gaming directives.
• Identifying gaming patterns that may indicate problem gambling behaviour, for the purpose of responsible gaming interventions as required under PAGCOR's responsible gaming framework.

Responsible gaming data, including self-exclusion records, is subject to extended retention periods as described in Section 8, and certain aspects of this processing cannot be restricted or objected to as they are mandatory under PAGCOR licensing conditions.

14. Changes to This Privacy Policy

playtame may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. Material changes to this Privacy Policy will be notified to active account holders via their registered email address or mobile number at least 14 days prior to the effective date of the change, except where earlier implementation is required by law or regulatory directive.

The effective date displayed at the top of this Privacy Policy indicates the date of the most recent revision. Continued use of the playtame platform after the effective date of any revised Privacy Policy constitutes acceptance of the revised terms. The current version of this Privacy Policy is always accessible at playtame.org/privacy-policy.

15. Contact Us & Data Protection Officer

For data subject rights requests, privacy queries, or to contact playtame's Data Protection Officer, please use the following channels:

• Live Chat: 24/7 via the playtame platform — fastest response for urgent matters including suspected unauthorised access
• Email: support @ playtame.org (plain text — not a clickable link)

For formal data subject rights requests, please include "Data Privacy Request" in the subject of your email along with your full name and registered playtame mobile number or email address to enable account verification. playtame will acknowledge receipt within 5 business days and respond substantively within 15 business days.

If you are not satisfied with playtame's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.