Privacy Policy — How ptgame Protects Your Personal Data

1. Introduction and Scope

This Privacy Policy ("Policy") describes how ptgame ("we," "us," "our," or "the Platform") collects, uses, stores, shares, and protects the personal data of users ("you," "your," or "data subject") who register and use the ptgame online gaming platform at ptgame.cam.

ptgame is committed to responsible and transparent data handling practices in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC). This Policy applies to all personal data collected through our website, mobile browser interface, customer support interactions, and any other point of contact between you and ptgame.

By registering an account or using any ptgame service, 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 any part of this Policy, you should not create or maintain a ptgame account.

2. Who We Are — Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012, ptgame acts as the Personal Information Controller (PIC) in respect of your personal data. This means ptgame determines the purposes and means by which your personal data is processed.

ptgame operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Our designated Data Protection Officer (DPO) is responsible for overseeing our data protection practices and serving as the point of contact for all data privacy matters.

For data privacy inquiries, please contact us at: [email protected] with the subject line "Data Privacy Inquiry — [Your Full Name]".

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register and use ptgame, we collect the following categories of personal data that you provide to us directly:

• Identity Data: Full legal name, date of birth, gender, and nationality as appearing on your government-issued identification documents.
• Contact Data: Email address, Philippine mobile phone number, and residential address (including city, province, and postal code).
• Identity Verification Documents: Copies of Philippine government-issued IDs (passport, driver's license, UMID, SSS card, PhilHealth card, Voter's ID, etc.) and proof of address documents submitted during KYC verification.
• Financial Data: Payment method details (GCash account number, PayMaya account, bank account details for BPI, BDO, Metrobank, or other accepted methods), deposit and withdrawal transaction history, and account balance information.
• Account Credentials: Username and encrypted password (ptgame never stores passwords in plain text).
• Communications Data: Records of your interactions with our customer support team, including live chat transcripts and email correspondence.
• Responsible Gaming Data: Self-imposed limits, cooling-off periods, and self-exclusion settings you configure on your account.

3.2 Data Collected Automatically

When you access ptgame, our systems automatically collect the following technical and behavioral data:

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, bets placed, session duration, login timestamps, and click-path data.
• Geolocation Data: Approximate location derived from your IP address for regulatory compliance purposes (to confirm you are located within the Philippines).
• Cookies and Tracking Data: Session cookies, persistent cookies, and similar tracking technologies as described in Section 9 of this Policy.

4. Legal Basis and Purposes of Processing

ptgame processes your personal data on the following lawful bases under RA 10173:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to — including account management, game delivery, payment processing, and customer support.
• Legal Obligation: Processing required to comply with PAGCOR licensing requirements, Anti-Money Laundering (AML) obligations, Counter-Terrorism Financing (CTF) regulations, and tax reporting duties under Philippine law.
• Legitimate Interests: Processing for fraud prevention, platform security, abuse detection, and the improvement of our services — where such interests do not override your fundamental rights and freedoms.
• Consent: Processing for optional services such as marketing communications, where we have obtained your explicit consent. You may withdraw this consent at any time.

The specific purposes for which we process your personal data include:

• Account registration, verification, and ongoing management;
• Processing deposits, withdrawals, and financial transactions;
• Fulfilling KYC and AML/CTF regulatory obligations;
• Delivering and improving game and platform services;
• Providing 24/7 customer support in English;
• Detecting and preventing fraud, cheating, and unauthorized access;
• Administering responsible gaming tools and monitoring for problem gambling indicators;
• Sending account-related notifications (security alerts, transaction confirmations, policy updates);
• Sending promotional communications where you have consented to receive them;
• Complying with regulatory reporting obligations to PAGCOR and other authorities.

5. How We Share Your Personal Data

5.1 Third-Party Service Providers

ptgame shares your personal data with trusted third-party service providers who process data on our behalf and under our strict instructions. These include:

• Payment Processors: GCash (Globe Telecom), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and other payment service providers — for the processing of your deposits and withdrawals.
• Game Software Providers: Providers such as Pragmatic Play, PG Soft, and others — who may collect limited technical data to deliver their game content.
• Identity Verification Services: Third-party KYC verification providers who assist in validating identity documents.
• Cloud Infrastructure Providers: Hosting, database, and cloud computing providers who store and process platform data under strict data processing agreements.

All third-party processors are bound by contractual data processing agreements that require them to handle your data solely in accordance with our instructions, maintain appropriate security measures, and comply with applicable Philippine privacy laws.

5.2 Regulatory and Legal Disclosure

ptgame may disclose your personal data to government authorities, law enforcement agencies, or regulatory bodies — including PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and Philippine courts — where required by law or where we have a good-faith belief that such disclosure is necessary to comply with a legal obligation, protect the rights and safety of ptgame or other users, or detect, prevent, or address fraud and illegal activity.

5.3 What We Will Never Do

6. Data Retention

ptgame retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years after account closure, in accordance with PAGCOR and AML/CTF record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years as required by Philippine AML regulations and the Anti-Money Laundering Act.
• KYC Documents: Identity verification documents are retained for five (5) years after account closure or the completion of any regulatory investigation, whichever is later.
• Support Communications: Customer support records are retained for three (3) years from the date of the last interaction.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications, whichever occurs first.

Upon expiry of the applicable retention period, ptgame will securely delete or anonymize your personal data in a manner that prevents reconstruction of the original information.

7. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ptgame:

Right	What It Means
Right to Access	You may request a copy of the personal data ptgame holds about you, along with information on how it is being used and with whom it has been shared.
Right to Rectification	You may request correction of any inaccurate or incomplete personal data in your ptgame account. Some corrections require re-verification of identity documents.
Right to Erasure	You may request deletion of your personal data where it is no longer necessary for the purposes collected, subject to our legal retention obligations under PAGCOR and AML requirements.
Right to Object	You may object to processing based on legitimate interests or for direct marketing purposes. Objection to marketing will result in immediate cessation of marketing communications.
Right to Block	You may request that ptgame temporarily suspend processing of your data in certain circumstances — for example, while accuracy of the data is under dispute.
Right to Damages	You have the right to be indemnified for any damages sustained due to unauthorized use, inaccurate, or unlawfully obtained personal data, as provided under RA 10173.
Right to Data Portability	You may request your personal data in a structured, commonly used, and machine-readable format for transfer to another controller, where technically feasible.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." ptgame will acknowledge your request within 5 business days and respond in full within 30 calendar days. Where requests are complex or numerous, we may extend this period by an additional 30 days with notification.

8. Data Security Measures

ptgame implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• Encryption in Transit: All data transmitted between your browser and ptgame servers is protected using TLS 1.2 or higher encryption.
• Encryption at Rest: Sensitive personal and financial data is encrypted when stored in our databases using AES-256 encryption standards.
• Access Controls: Strict role-based access controls ensure that only authorized ptgame personnel with a legitimate business need can access personal data.
• Multi-Factor Authentication: Internal systems require multi-factor authentication for staff access to systems containing personal data.
• Regular Security Audits: ptgame undergoes regular third-party security audits and penetration testing to identify and remediate vulnerabilities.
• Incident Response: ptgame maintains a documented data breach incident response plan. In the event of a personal data breach, we will notify affected data subjects and the National Privacy Commission within 72 hours of discovery, as required by NPC regulations.

9. Cookies and Tracking Technologies

9.1 How ptgame Uses Cookies

ptgame uses cookies and similar tracking technologies (such as web beacons and local storage) to deliver and improve our services. Cookies are small text files placed on your device when you visit our website. We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function correctly — including session management, login authentication, and security features. These cannot be disabled without rendering the platform unusable.
• Performance Cookies: Collect anonymous information about how you use ptgame — such as which pages you visit most frequently — to help us improve platform performance and user experience.
• Functionality Cookies: Remember your preferences — such as language, game settings, and display options — to personalize your experience across sessions.
• Analytics Cookies: Used by our analytics tools to understand aggregate user behavior and platform usage patterns, always in anonymized or pseudonymized form.

9.2 Managing Cookies

You can manage or disable cookies through your browser settings at any time. Note that disabling strictly necessary cookies will affect the functionality of the ptgame platform and may prevent you from accessing certain features, including the ability to log in. Disabling performance or analytics cookies will not affect your ability to use ptgame's core gaming services.

10. Children's Privacy

ptgame's services are strictly restricted to persons aged 21 years or older in accordance with PAGCOR regulations governing online gaming in the Philippines. We do not knowingly collect personal data from anyone under the age of 21. If ptgame becomes aware that personal data has been collected from a person under 21 — whether through fraudulent registration or otherwise — the relevant account will be immediately closed, all data will be deleted, and any deposits will be refunded to the originating payment method.

If you believe that a person under the age of 21 has registered a ptgame account, please notify us immediately at [email protected].

11. Cross-Border Data Transfers

ptgame primarily stores and processes data within systems accessible from the Philippines. Where data is processed by third-party service providers whose infrastructure is located outside the Philippines (such as cloud providers or game software vendors), ptgame ensures that appropriate safeguards are in place — including contractual data processing agreements that require equivalent data protection standards to those under Philippine law.

ptgame does not transfer personal data to countries or organizations that do not provide an adequate level of protection for personal data, without implementing appropriate safeguards as recognized under RA 10173.

12. Changes to This Privacy Policy

ptgame reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, ptgame will notify registered users via email and an in-platform notification at least 15 days prior to the changes taking effect. The "Last Updated" date at the top of this Policy will always reflect the most recent revision.

Your continued use of ptgame following the effective date of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how ptgame protects your data.

13. How to Contact Us — Data Privacy Concerns

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way ptgame handles your personal data, please contact our Data Protection Officer:

Email: [email protected] (Subject: "Data Privacy — [Your Concern]")
Support: Live chat available 24/7 within the ptgame platform

If you are not satisfied with ptgame's response to your data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines, which is the government body responsible for enforcing RA 10173.