ppgame Privacy Policy

01 Data Controller Identity

For the purposes of this Privacy Policy and applicable Philippine data protection law, ppgame ("we," "us," "our") is the data controller responsible for the personal information collected through the ppgame.win platform and all associated services. As data controller, ppgame determines the purposes and means of processing your personal data and is accountable for ensuring that such processing is conducted lawfully, fairly, and transparently.

ppgame's designated Data Protection Officer (DPO) can be reached via the contact details provided in Section 14 of this Policy. Filipino players who wish to raise a data privacy concern are encouraged to contact the DPO directly in the first instance before escalating to the National Privacy Commission.

02 Personal Data We Collect

ppgame collects personal data through multiple touchpoints — account registration, identity verification, payment processing, gameplay activity, customer support interactions, and platform usage analytics. The specific categories of data collected are set out below.

When you create a ppgame account, we collect your full legal name, date of birth, Philippine mobile number, chosen username, and account password (stored in encrypted form only — ppgame does not store passwords in plain text).

To comply with anti-money laundering obligations and confirm your age (21+), ppgame collects copies of valid Philippine government-issued identification documents (e.g., Philippine Passport, UMID, SSS ID, PhilHealth ID, Driver's License, Voter's ID), selfie verification images where required, and proof of address documentation in certain cases.

ppgame processes transaction data associated with your deposits and withdrawals, including GCash account reference numbers, Maya wallet identifiers, bank account details (where applicable), USDT wallet addresses, transaction amounts, timestamps, and status records. ppgame does not store full payment card numbers on its systems.

We collect records of your game sessions including games played, bet amounts, outcomes, session durations, bonus usage, wagering progress, and win/loss history. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory reporting.

ppgame automatically collects IP address, device type and model, operating system, browser type and version, screen resolution, session timestamps, and clickstream data when you access the Platform. This information is used to maintain platform security, prevent fraud, and improve user experience.

When you contact ppgame through live chat, email, or any other support channel, we retain records of those communications including timestamps, agent notes, and any attachments you provide. This data is used to manage your support requests and for training and quality assurance purposes.

03 How ppgame Uses Your Personal Data

ppgame uses the personal data it collects for the following specific purposes:

• Account creation and management — registering your account, authenticating your identity at login, and maintaining your account profile.
• Transaction processing — processing deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, 7-Eleven, USDT TRC20, and Coins.ph.
• Identity and age verification — conducting KYC checks to confirm you are aged 21 or above and to verify your identity in compliance with applicable Philippine law.
• Anti-money laundering (AML) compliance — monitoring transactions for suspicious activity and fulfilling mandatory reporting obligations.
• Customer support — handling your inquiries, resolving disputes, and processing complaints through our 24/7 live chat and email support channels.
• Platform security and fraud prevention — detecting, investigating, and preventing unauthorized account access, payment fraud, collusion, and abuse of promotional offers.
• Responsible gaming — monitoring gameplay patterns to identify signs of problem gambling behavior, administering deposit limits, cooling-off periods, and self-exclusion requests.
• Personalization and product improvement — analyzing aggregated usage data to improve the ppgame platform, game lobby, and user experience for Filipino players.
• Marketing communications — sending promotional offers, bonus notifications, and platform updates to registered players who have not opted out of such communications.
• Legal and regulatory compliance — maintaining records required by law and responding to lawful requests from regulatory bodies and law enforcement authorities.

04 Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), ppgame relies on the following legal bases for processing your personal data:

• Contractual necessity — processing required to perform our obligations under your ppgame account agreement, including account management, payment processing, and game service delivery.
• Legal obligation — processing required to comply with applicable Philippine law, including AML regulations, age verification requirements, and tax and financial reporting obligations.
• Legitimate interests — processing necessary for ppgame's legitimate business interests, including fraud prevention, platform security, product improvement, and responsible gaming monitoring, provided these interests are not overridden by your data protection rights.
• Consent — processing based on your freely given, specific, informed, and unambiguous consent, primarily for marketing communications. You may withdraw consent at any time without detriment to your account status.

05 Data Sharing & Disclosure

ppgame does not sell your personal data. We share your data only in the following limited circumstances and only to the extent necessary for the stated purpose:

To deliver game content, ppgame shares necessary session and account data with licensed game providers (including but not limited to JILI Games, PG Soft, Pragmatic Play, and Evolution Gaming). These providers are contractually bound to use your data only to deliver game services on the ppgame platform.

Transaction data is shared with payment service providers (including GCash, Maya, BPI, BDO, Metrobank, and others) solely to process your deposits and withdrawals. ppgame does not transmit more data than is required to complete the specific transaction.

ppgame may use third-party identity verification services to assist with KYC processes. These providers process your identity documents under strict confidentiality and data processing agreements and are not permitted to retain or use your data for their own purposes.

ppgame will disclose personal data to Philippine regulatory bodies (including PAGCOR and the Anti-Money Laundering Council where applicable), the National Privacy Commission, and law enforcement authorities where required by law or valid legal process. ppgame will endeavor to notify you of such disclosure where legally permitted to do so.

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of ppgame's assets, your personal data may be transferred as part of that transaction. You will be notified of any material change to the data controller's identity through the Platform or by direct communication to your registered contact details.

06 Cookies & Tracking Technologies

ppgame uses cookies and similar tracking technologies on its platform to operate core functionality, maintain your login session, detect fraud, and analyze platform usage. The categories of cookies used are as follows:

• Strictly Necessary Cookies: Essential for the operation of the ppgame platform, including session management and login authentication. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your language preferences, last-played games, and display settings to personalize your ppgame experience between sessions.
• Analytics Cookies: Collect aggregated, anonymized data about how players navigate and interact with the ppgame platform, used to improve product features and user flows. No personally identifiable information is included in analytics data sets.
• Security Cookies: Support ppgame's fraud detection and account security systems, including device fingerprinting to identify suspicious login attempts.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the ppgame platform. ppgame does not currently use third-party advertising cookies.

07 Data Retention

ppgame retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following retention schedules:

• Active account data — retained for the duration of your ppgame account and for a minimum of 5 years following account closure, to satisfy AML record-keeping obligations under Philippine law.
• KYC and identity documents — retained for a minimum of 5 years following account closure or the date of the last transaction, whichever is later.
• Transaction records — retained for a minimum of 5 years from the date of each transaction for AML and financial regulatory compliance.
• Customer support communications — retained for 3 years from the date of the interaction, unless a longer period is required for an ongoing dispute or legal proceeding.
• Technical and device logs — retained for 12 months from collection, unless required for an active security investigation.
• Marketing consent records — retained for the duration of your account and 3 years following withdrawal of consent, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification.

08 Data Security Measures

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ppgame platform.
• Encryption at rest for sensitive personal data fields including passwords (stored as one-way cryptographic hashes), payment references, and identity document copies.
• Role-based access controls ensuring that only authorized ppgame personnel with a documented need can access personal data, restricted to the minimum data necessary for their role.
• Multi-factor authentication required for ppgame staff access to systems containing personal data.
• Regular third-party security audits and penetration testing of ppgame's platform infrastructure.
• Comprehensive incident response procedures for detecting, containing, and reporting personal data breaches.

09 Your Data Rights as a Filipino Player

Under the Philippine Data Privacy Act of 2012 (RA 10173) and its implementing rules, you hold the following rights with respect to your personal data held by ppgame. To exercise any of these rights, please contact ppgame's Data Protection Officer via the details in Section 14. ppgame will respond to all verified requests within 30 calendar days.

If you believe ppgame has not adequately addressed your data rights request, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC) at privacy.gov.ph.

10 Children's Privacy — 21+ Only

The ppgame platform is strictly intended for adults aged 21 years and above. ppgame does not knowingly collect personal data from any individual under the age of 21. Account registration requires a Philippine mobile number and undergoes mandatory age verification as part of the KYC process. If ppgame becomes aware that an account has been created by an individual under 21, that account will be immediately closed, all data associated with it will be deleted or anonymized, and any deposited funds will be returned to the originating payment method.

11 Cross-Border Data Transfers

Some personal data processed by ppgame may be transferred to and processed by service providers located outside the Philippines — for example, game providers with servers in other jurisdictions or cloud infrastructure providers operating across multiple regions. Where such transfers occur, ppgame ensures that an adequate level of data protection is in place through one or more of the following mechanisms:

• Data processing agreements incorporating the standard contractual clauses approved by the National Privacy Commission.
• Transfer to jurisdictions that the NPC has recognized as providing an adequate level of data protection.
• Binding corporate rules where the transfer is within a group of companies with an approved BCR program.

ppgame will not transfer personal data to a third country or international organization unless appropriate safeguards are in place and enforceable data subject rights are available to you.

12 Third-Party Services & Game Providers

The ppgame platform integrates games and services provided by third-party game studios and software providers, including JILI Games, PG Soft, Pragmatic Play, Evolution Gaming, Habanero, Spadegaming, and others. When you play a game on ppgame, limited technical data (such as a session token and bet/result data) is transmitted to the relevant game provider to deliver the game experience.

This Privacy Policy does not govern the data practices of third-party game providers beyond the scope of their contractual obligations to ppgame. ppgame requires all game providers to comply with applicable data protection standards under their data processing agreements. However, ppgame encourages players to review the privacy policies of individual game providers if they have specific concerns about how those providers handle data.

13 Amendments to This Privacy Policy

ppgame reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory guidance, or platform features. Where changes are material, ppgame will notify registered players via the Platform, by SMS to your registered Philippine mobile number, or by email where available, at least 15 days prior to the changes taking effect.

The "Last Updated" date in the Table of Contents reflects the date this Policy was most recently revised. Your continued use of the ppgame platform following the effective date of any amendment constitutes your acknowledgment of the updated Policy. If you do not agree with material changes, you should discontinue use of the Platform and may request account closure in accordance with the Terms and Conditions.

14 Contact, DPO & Complaints

For any questions, concerns, or requests relating to your personal data and this Privacy Policy, please contact ppgame's Data Protection Officer through the following channels:

• Live Chat: Available 24/7 inside the ppgame platform — fastest response for urgent matters.
• Email: [email protected] — for data rights requests, please include "Data Privacy Request" in the subject line. ppgame aims to respond within 5 business days of receipt.

If you are not satisfied with ppgame's response to your data privacy concern, or if you believe ppgame is processing your personal data in breach of the Data Privacy Act of 2012, you have the right to file a complaint with the Philippine National Privacy Commission (NPC). Details on how to file an NPC complaint are available at the NPC's official website.