ptgame Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by ptgame ("ptgame," "we," "us," "our") and applies to all personal data collected, processed, stored, and used in connection with your registration and use of the ptgame platform at ptgame.pro, including all games, services, promotions, account features, and customer support interactions.

ptgame is committed to protecting the privacy and personal data of every Filipino player who uses our platform. We operate under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

By registering a ptgame account, using any part of the ptgame platform, or submitting personal data to us through any channel, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with this Policy, you must not register an account or use ptgame's services.

This Policy should be read alongside ptgame's Terms and Conditions and Responsible Gaming Policy, both of which are incorporated by reference and govern the broader terms of your use of the ptgame platform.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, ptgame acts as the Personal Information Controller (PIC) with respect to the personal data you provide when using the ptgame platform.

As the Personal Information Controller, ptgame determines the purposes and means of processing your personal data, is responsible for ensuring that processing is carried out lawfully, and is accountable for compliance with applicable data protection obligations.

3 Personal Data We Collect

ptgame collects personal data in two categories: data you provide directly to us, and data we collect automatically as you use the platform. The specific data we collect is set out in the table below.

ptgame does not collect sensitive personal information as defined under RA 10173 (such as health data, religious beliefs, or political affiliations) except where explicitly required by PAGCOR's responsible gaming or self-exclusion procedures, in which case collection is limited strictly to what is necessary and your explicit consent is obtained.

4 How We Collect Your Data

ptgame collects your personal data through the following channels and methods:

4.1 Direct Collection

• Account Registration: When you create a ptgame account, you submit your name, date of birth, mobile number, and email address directly through the registration form;
• KYC Verification: When you submit government-issued identification documents and selfie photographs to complete identity verification;
• Payment Transactions: When you make deposits or request withdrawals, your payment method details are collected to process and verify transactions;
• Customer Support: When you contact ptgame's support team via live chat or email, the content of those communications is recorded for quality assurance and dispute resolution purposes;
• Promotions and Surveys: When you opt into ptgame promotions or respond to optional player surveys, any data you provide is collected directly.

4.2 Automated Collection

When you access the ptgame platform, our systems automatically collect certain technical and usage data through cookies, web beacons, pixel tags, device fingerprinting technology, and server log files. This automated collection occurs regardless of whether you are logged into your ptgame account. For full details on our use of cookies, see Section 8 of this Policy.

4.3 Third-Party Sources

In limited circumstances, ptgame may receive personal data about you from third parties, including: payment processors (GCash, Maya, BPI, BDO, Metrobank, and others) who provide transaction confirmation data; identity verification service providers who assist with KYC screening; and fraud prevention and anti-money laundering screening services. Data received from third-party sources is handled in accordance with this Policy and used only for the purposes for which it was obtained.

5 How We Use Your Personal Data

ptgame uses your personal data only for legitimate, specified purposes directly connected to the operation of the ptgame platform and compliance with our legal obligations. The specific purposes for which we process your data are:

• Account Management: Creating, maintaining, and securing your ptgame account; authenticating your identity at login; processing your ptgame account closure requests;
• Service Delivery: Enabling you to play games, place bets, participate in promotions, and access all features of the ptgame platform;
• Financial Processing: Processing deposit and withdrawal transactions through your selected Philippine payment channels; verifying payment method ownership; maintaining accurate transaction records;
• KYC and Regulatory Compliance: Verifying your age (21+ requirement), identity, and source of funds as required by PAGCOR's anti-money laundering (AML) and player protection guidelines;
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, bonus abuse, money laundering, multiple account creation, and unauthorized access to player accounts;
• Responsible Gaming: Monitoring gameplay patterns to identify problem gambling indicators; administering self-exclusion, deposit limit, and session limit tools; enforcing age restrictions;
• Customer Support: Responding to your queries, complaints, and disputes; providing technical assistance; escalating unresolved issues;
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve game offerings, platform performance, and user experience;
• Legal Compliance: Meeting our obligations under Philippine law, including RA 10173, the Anti-Money Laundering Act (AMLA), and PAGCOR's regulatory requirements; responding to lawful requests from government authorities.

ptgame does not use your personal data for the purpose of serving third-party advertisements, building advertising profiles, or selling data insights to marketing companies.

6 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, ptgame processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to perform the contract between ptgame and you (i.e., the Terms and Conditions), including account management, game delivery, and payment processing;
• Legal Obligation: Processing necessary to comply with ptgame's obligations under Philippine law, including PAGCOR regulatory requirements, AMLA compliance, KYC verification, and data retention mandates;
• Legitimate Interest: Processing necessary for ptgame's legitimate interests in fraud prevention, platform security, abuse detection, and responsible gaming enforcement — provided these interests are not overridden by your rights and interests;
• Consent: Where ptgame relies on your consent as the basis for processing (such as for optional marketing communications or sensitive personal information), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

ptgame does not sell, rent, or trade your personal data to any third party. We share your personal data only in the following limited and controlled circumstances:

7.1 Service Providers

ptgame engages trusted third-party service providers who process personal data on our behalf under strict data processing agreements. These include: payment processors (GCash, Maya, GrabPay, BPI, BDO, Metrobank, Coins.ph); KYC and identity verification providers; fraud detection and anti-money laundering screening services; customer support platform providers; cloud hosting and data storage providers; and RNG certification and game audit firms. All service providers are required to process your data only for the specific purpose for which they are engaged and in accordance with this Policy.

7.2 Regulatory Authorities

ptgame is required by law to share certain player data with PAGCOR and other Philippine regulatory bodies (including the Anti-Money Laundering Council, AMLC) in the performance of their regulatory and law enforcement functions. ptgame will comply with all lawful requests from government authorities and courts of competent jurisdiction.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of ptgame's assets, your personal data may be transferred to the acquiring entity, provided that the acquiring entity agrees to honor the commitments made in this Privacy Policy. You will be notified of any such transfer and your options in relation to your data prior to the transfer taking effect.

7.4 With Your Consent

ptgame will share your personal data with third parties outside of the categories described above only where you have provided your explicit, informed consent for such sharing.

8 Cookies & Tracking Technologies

ptgame uses cookies and similar tracking technologies on the ptgame platform to enable core functionality, improve performance, and protect the security of your session. The types of cookies we use are described below:

ptgame does not deploy third-party advertising cookies or allow external advertising networks to place cookies on the ptgame platform. You may manage your cookie preferences through your browser settings; however, disabling strictly necessary or security cookies may impair your ability to use the ptgame platform.

9 Data Retention

ptgame retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, and to resolve disputes or enforce our agreements. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your ptgame account and for a minimum of five (5) years following account closure, as required by PAGCOR's record-keeping obligations and Philippine AML regulations;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act (RA 9160, as amended);
• Gaming Activity Logs: Retained for three (3) years from the date of each gaming session;
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant KYC review, whichever is later;
• Customer Support Records: Retained for two (2) years from the date of the last interaction, unless a longer retention period is required for dispute resolution purposes;
• Technical and Usage Logs: Retained for twelve (12) months on a rolling basis.

Upon expiry of the applicable retention period, ptgame will securely delete or anonymize your personal data in accordance with our data disposal procedures. Where data has been anonymized such that you can no longer be identified from it, ptgame may retain and use such anonymized data indefinitely for analytical and platform improvement purposes.

10 Data Security

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

• Encryption: All data transmitted between your device and the ptgame platform is protected by 256-bit SSL/TLS encryption. Sensitive data stored in our systems, including financial account identifiers and KYC document references, is encrypted at rest;
• Access Controls: Access to personal data within ptgame's systems is strictly limited to employees and contractors who require it to perform their specific job functions, under a principle of least privilege;
• Two-Factor Authentication: ptgame encourages all players to enable two-factor authentication (2FA) on their ptgame accounts as an additional layer of account security;
• Penetration Testing: ptgame's platform infrastructure undergoes regular security assessments and penetration testing by independent security professionals;
• Incident Response: ptgame maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, ptgame will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players as required under RA 10173.

While ptgame takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your ptgame login credentials and for notifying ptgame immediately if you suspect any unauthorized access to your account.

11 Your Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by ptgame:

To exercise any of the above rights, please contact ptgame's Data Protection contact at [email protected]. ptgame will respond to your request within fifteen (15) business days of receipt, in accordance with the NPC's prescribed timelines. ptgame may request proof of identity before processing your request to ensure that personal data is not disclosed to unauthorized parties.

12 Children's Privacy

If you are a parent or guardian and believe that your child has registered a ptgame account without your knowledge, please contact us immediately at [email protected]. ptgame takes underage access extremely seriously and will act promptly to address any reported instance.

13 International Data Transfers

ptgame's primary operations and data storage are based in the Philippines. Where ptgame engages third-party service providers (such as cloud infrastructure, KYC verification services, or game audit firms) whose systems are located outside the Philippines, your personal data may be transferred to and processed in other jurisdictions.

Where such international transfers occur, ptgame ensures that appropriate safeguards are in place to protect your personal data in a manner consistent with the requirements of the Philippine Data Privacy Act of 2012. These safeguards include contractual data transfer agreements with receiving parties that impose data protection obligations equivalent to those applicable under RA 10173, or reliance on recognized frameworks for international data transfers as recognized by the National Privacy Commission.

By using the ptgame platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside the Philippines where such transfers are necessary for the delivery of ptgame's services, subject to the safeguards described in this section.

14 Updates to This Privacy Policy

ptgame reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to our platform's data protection measures. The "Last Updated" date at the top of this Policy will be revised whenever changes are made.

Where changes are material — meaning they significantly affect your rights or how we process your personal data — ptgame will provide advance notice to registered players via their registered email address and/or by displaying a prominent notice on the ptgame platform at least fourteen (14) days before the changes take effect.

Your continued use of the ptgame platform after the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed of how ptgame protects your personal data.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or ptgame's handling of your personal data, you may contact us through the following channels:

For complaints that remain unresolved after engaging with ptgame's support team, you have the right to file a complaint directly with the National Privacy Commission of the Philippines (NPC) through its official channels.