Privacy Policy

1. Who We Are

pinasplay ("pinasplay," "we," "us," or "our") operates the online casino and sports betting platform accessible at pinasplay.asia. pinasplay is the data controller responsible for the personal data collected through this Platform. We are committed to protecting the privacy and security of all personal information entrusted to us by our players and website visitors.

This Privacy Policy applies to all personal data collected through the pinasplay website, mobile-optimized platform, customer support channels, and any other touchpoints through which you interact with pinasplay. It does not apply to third-party websites or services that may be linked from our Platform.

By registering for a pinasplay account or using our Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, please do not use the pinasplay Platform.

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2. Personal Data We Collect

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

pinasplay does not intentionally collect special categories of sensitive personal data (such as health data, religious beliefs, or political opinions) unless specifically required by law or provided voluntarily by you in the context of a responsible gaming request.

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3. How We Collect Your Data

pinasplay collects personal data through the following means:

3.1 Direct Collection

Data you provide directly when you register for an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in promotions, or respond to surveys. This is the primary source of your personal data on the pinasplay Platform.

3.2 Automated Collection

Technical and usage data collected automatically when you access and use the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. This data helps us maintain platform security, detect fraud, and improve the user experience.

3.3 Third-Party Sources

In certain circumstances, pinasplay may receive personal data about you from third parties, including:

• Payment processors (e.g., GCash, PayMaya) for transaction verification
• Identity verification service providers for KYC purposes
• Fraud prevention and AML screening services
• Regulatory bodies and law enforcement agencies where required by law

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4. How We Use Your Personal Data

pinasplay uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your pinasplay account, including authentication and access control.
• Service Delivery: Providing access to games, processing bets, crediting winnings, and delivering all features of the pinasplay Platform.
• Payment Processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Identity Verification: Verifying your identity and age (21+) in compliance with applicable Philippine gaming regulations and KYC requirements.
• Regulatory Compliance: Meeting our obligations under Philippine gaming regulations, the Data Privacy Act of 2012, and anti-money laundering laws.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, cheating, money laundering, and other prohibited conduct.
• Responsible Gaming: Monitoring gaming activity to identify potential problem gambling patterns and administering responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: Analyzing usage patterns to improve the performance, features, and user experience of the pinasplay Platform.

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5. Legal Basis for Processing

Under the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, pinasplay processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you (i.e., operating your account and delivering gaming services).
• Legal Obligation: Processing required to comply with applicable Philippine laws, including gaming regulations, AML laws, and tax obligations.
• Legitimate Interests: Processing necessary for pinasplay's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and certain cookie-based tracking. You may withdraw consent at any time without affecting the lawfulness of prior processing.

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6. Data Sharing and Disclosure

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

6.1 Service Providers

Third-party vendors who provide services on our behalf, including payment processors, KYC verification providers, cloud hosting providers, customer support platforms, and analytics services. All service providers are contractually bound to process your data only on pinasplay's instructions and in accordance with applicable data protection laws.

6.2 Regulatory and Law Enforcement Authorities

Philippine government agencies, regulatory bodies, and law enforcement authorities where disclosure is required by law, court order, or regulatory directive. This includes reporting obligations under AML regulations and gaming licensing requirements.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of pinasplay's assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

6.4 With Your Consent

In any other circumstances where you have given your explicit consent to the sharing of your personal data with a specific third party for a specific purpose.

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7. Cookies and Tracking Technologies

pinasplay uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies may be set when you use the Platform:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming limits you have set.
• Analytics Cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent and can be withdrawn at any time via your browser settings.

You can control cookie settings through your browser preferences. Disabling certain cookies may affect the functionality of the Platform. For detailed information on the specific cookies we use, please contact our Data Protection Officer.

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8. Data Retention

pinasplay retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your account and for a minimum of 5 years after account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction and Financial Data: Retained for a minimum of 5 years from the date of the transaction, as required by applicable financial regulations.
• KYC Verification Documents: Retained for a minimum of 5 years after account closure or the last transaction, whichever is later.
• Customer Support Communications: Retained for 3 years from the date of the interaction, or longer if related to an ongoing dispute or regulatory matter.
• Technical and Usage Data: Retained for up to 24 months from collection, after which it is anonymized or deleted.
• Marketing Consent Records: Retained for the duration of your consent and for 3 years thereafter as evidence of consent.

When personal data is no longer required, pinasplay will securely delete or anonymize it in accordance with our data disposal procedures.

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9. Data Security

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

• TLS/SSL encryption for all data transmitted between your device and the pinasplay Platform
• AES-256 encryption for sensitive data stored at rest, including financial information and identity documents
• Multi-factor authentication (MFA) options for player accounts
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits, vulnerability assessments, and penetration testing
• Intrusion detection and prevention systems monitoring the Platform 24/7
• Staff training on data protection and information security best practices
• Incident response procedures for managing and reporting data breaches

While pinasplay takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

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10. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by pinasplay:

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. pinasplay will respond to all data subject requests within 15 business days of receipt. We may need to verify your identity before processing your request.

If you believe pinasplay has not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

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11. Children's Privacy

The pinasplay Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. pinasplay does not knowingly collect personal data from individuals under the age of 21.

If pinasplay becomes aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete the personal data, and return any deposited funds subject to verification. If you believe a minor has registered on the pinasplay Platform, please contact our support team immediately via live chat.

pinasplay employs age verification procedures during registration and KYC processes to prevent underage access to the Platform. We take our responsibility to protect minors from gambling harm very seriously.

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12. Cross-Border Data Transfers

pinasplay primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines, for example when using cloud infrastructure or third-party service providers with operations in other jurisdictions.

Where such transfers occur, pinasplay ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to provide a level of data protection equivalent to that required under Philippine law. pinasplay will not transfer your personal data to a country that does not provide adequate data protection without your explicit consent or without implementing appropriate safeguards.

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13. Third-Party Links

The pinasplay Platform may contain links to third-party websites or services. This Privacy Policy applies only to the pinasplay Platform and does not cover the privacy practices of any third-party websites. pinasplay is not responsible for the content or privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

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14. Changes to This Privacy Policy

pinasplay 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 material changes are made, we will notify registered players via their registered email address or mobile number, or by displaying a prominent notice on the Platform, at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page reflects when this Privacy Policy was most recently revised. We encourage you to review this Privacy Policy periodically. Your continued use of the pinasplay Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the changes.

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15. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or pinasplay's data processing practices, please contact our designated Data Protection Officer (DPO):

• Live Chat: Available 24/7 directly on the pinasplay Platform — the fastest way to reach us
• Email: [email protected]

Please include "Privacy Request" in the subject line of your email and provide sufficient detail to allow us to identify your account and understand your request. We will acknowledge receipt of your request within 3 business days and provide a full response within 15 business days.

If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

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