Sportplay Privacy Policy

1. Introduction

Sportplay ("Sportplay", "we", "us", "our") operates the online gaming platform accessible at sportplay.asia and any associated subdomains or mobile interfaces (collectively, the "Platform"). This Privacy Policy ("Policy") describes how Sportplay collects, processes, stores, shares, and protects personal data relating to individuals who register an account, visit the Platform, or otherwise interact with Sportplay's services ("you", "your", "Player").

Sportplay is committed to protecting the privacy and personal data of all Filipino players and Platform visitors. We process personal data in accordance with applicable data protection legislation, including the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its implementing rules and regulations. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside Sportplay's Terms & Conditions, which govern your use of the Platform and are incorporated herein by reference. In the event of any conflict between this Policy and the Terms & Conditions, the Terms & Conditions shall prevail.

2. Personal Data We Collect

Sportplay collects the following categories of personal data in connection with your use of the Platform:

Sportplay does not collect or process special categories of sensitive personal data (such as health data, biometric data, or political opinions) except where strictly required by applicable law or regulatory obligation and with your explicit consent.

3. How We Collect Your Data

Sportplay collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion
• Automated technologies: Data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and similar tracking technologies (see Section 7)
• Third-party sources: Data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), identity verification service providers, fraud prevention agencies, and credit reference agencies, where permitted by applicable law
• Publicly available sources: Data obtained from publicly accessible databases, government registries, or social media platforms where relevant to fraud prevention or regulatory compliance

4. How We Use Your Personal Data

Sportplay uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your Sportplay account, including processing registrations, verifying your identity, and managing your account preferences
• Service delivery: To provide access to the Platform's games, features, and services, including processing deposits, withdrawals, and bonus credits
• Legal and regulatory compliance: To fulfil our obligations under applicable law, including anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and PAGCOR-compliant responsible gaming obligations
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform
• Responsible gaming: To monitor gaming behaviour, enforce responsible gaming limits, and identify players who may be at risk of gambling-related harm
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance
• Marketing and promotions: To send you information about Sportplay promotions, bonuses, and new features, where you have consented to receive such communications
• Platform improvement: To analyse usage patterns, conduct research, and improve the functionality, performance, and user experience of the Platform
• Legal proceedings: To establish, exercise, or defend legal claims in connection with your use of the Platform

5. Legal Basis for Processing

Sportplay processes your personal data on the following legal bases, as applicable under the Data Privacy Act of 2012 and other applicable legislation:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions, including account management, payment processing, and service delivery
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML, KYC, and responsible gaming requirements
• Legitimate interests: Processing carried out in pursuit of Sportplay's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for direct marketing communications. You may withdraw your consent at any time by contacting Sportplay's customer support team or updating your account preferences

6. Data Sharing and Disclosure

Sportplay does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and assess fraud risk
• Game content providers: Software providers whose games are available on the Platform, to the extent necessary for game operation and dispute resolution
• Regulatory authorities: PAGCOR and other competent regulatory or law enforcement authorities, where required by applicable law or regulatory obligation
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by Sportplay in connection with its business operations
• Business transfers: In the event of a merger, acquisition, or sale of all or part of Sportplay's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations

All third parties with whom Sportplay shares personal data are required to process that data in accordance with applicable data protection law and Sportplay's data processing requirements.

7. Cookies and Tracking Technologies

Sportplay uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support fraud prevention and security functions. Cookies are small text files stored on your device when you visit the Platform.

Sportplay uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, authentication, and security. These cookies cannot be disabled.
• Performance cookies: Used to collect anonymised data about how visitors use the Platform, including pages visited and error messages encountered, to help us improve Platform performance.
• Functional cookies: Used to remember your preferences and settings, such as language preference and responsible gaming limits, to provide a more personalised experience.
• Targeting and analytics cookies: Used to understand your interests and deliver relevant content and promotions, where you have consented to such use.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information about managing cookies, refer to your browser's help documentation.

8. Data Retention

Sportplay retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and regulatory record-keeping requirements
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with applicable financial regulations
• KYC and verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction
• Customer support communications: Retained for a minimum of two (2) years from the date of the communication
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications

Upon expiry of the applicable retention period, Sportplay will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Data Security

Sportplay implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform
• Encryption of sensitive data at rest, including financial data and identity documents
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security audits, penetration testing, and vulnerability assessments
• Multi-factor authentication for administrative access to systems containing personal data
• Incident response procedures for the detection, reporting, and remediation of data security incidents

While Sportplay takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, Sportplay will notify you and the relevant regulatory authority in accordance with applicable law.

10. Your Data Protection Rights

Under the Data Privacy Act of 2012 and applicable data protection legislation, you have the following rights in relation to your personal data held by Sportplay :

• Right to be informed: You have the right to be informed about how Sportplay collects and uses your personal data, as set out in this Policy
• Right of access: You have the right to request a copy of the personal data Sportplay holds about you, together with information about how it is processed
• Right to rectification: You have the right to request that Sportplay correct any inaccurate or incomplete personal data held about you
• Right to erasure: You have the right to request that Sportplay delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to Sportplay's legal and regulatory retention obligations
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time, and to object to processing based on legitimate interests where your rights and interests override those of Sportplay
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe that Sportplay has processed your personal data in a manner that violates applicable data protection law

To exercise any of the above rights, please contact Sportplay's Data Protection Officer via the contact details set out in Section 14 of this Policy. Sportplay will respond to all verified requests within thirty (30) days of receipt. We may request proof of identity before processing your request to ensure the security of your personal data.

11. Children's Privacy

The Sportplay Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gambling in the Philippines. Sportplay does not knowingly collect, process, or store personal data relating to individuals under the age of 21.

If Sportplay becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on the Platform, please contact Sportplay's customer support team immediately so that appropriate action can be taken.

Sportplay employs age verification procedures at the point of registration and at the point of first withdrawal to enforce this requirement. Parents and guardians are encouraged to make use of parental control software to prevent minors from accessing online gambling platforms.

12. Third-Party Links

The Sportplay Platform may contain links to third-party websites or services for informational or operational purposes. Sportplay is not responsible for the privacy practices or content of any third-party website. This Policy applies solely to personal data collected and processed by Sportplay in connection with the Platform.

We encourage you to review the privacy policies of any third-party websites you visit via links on the Platform. Sportplay accepts no liability for the data practices of third-party operators.

13. Changes to This Privacy Policy

Sportplay reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or Sportplay's data processing practices. Any changes will be published on this page with an updated effective date. Where the changes are material, Sportplay will endeavour to provide reasonable advance notice to registered players via email or an on-platform notification.

Your continued use of the Sportplay Platform following the publication of any amended Policy constitutes your acknowledgement of the changes. It is your responsibility to review this Policy periodically. If you do not agree to the amended Policy, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or Sportplay's data processing practices, please contact our Data Protection Officer. Our team is available 24 hours a day, 7 days a week, and is fluent in both Filipino and English.

You may reach us via the live chat feature available on the Platform, or by email at [email protected]. Please note that this email address is provided for informational purposes as plain text only and is not a clickable link. When contacting us regarding a data protection matter, please include your registered account username, a clear description of your request, and a copy of a valid government-issued identification document so that we can verify your identity before processing your request.

Sportplay aims to acknowledge all data protection requests within five (5) business days and to resolve the majority of requests within thirty (30) days. Complex matters may take longer, in which case we will keep you informed of progress.