pesogame Privacy Policy —
How We Protect Your Data

1.1 pesogame is committed to protecting the privacy and personal data of all Filipino players who use its online gaming platform. This Privacy Policy sets out the principles and practices governing the collection, use, storage, disclosure, and protection of personal data by pesogame in connection with the operation of the pesogame.asia platform.

1.2 This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations (IRR), and the applicable issuances of the National Privacy Commission (NPC). It also reflects pesogame's obligations under PAGCOR's regulatory framework for online gaming operators.

1.3 This Policy applies to all data subjects whose personal data is processed by pesogame, including registered players, prospective players who have initiated but not completed registration, and visitors to the pesogame.asia platform who have not registered an account.

1.4 Where pesogame uses third-party service providers to process personal data on its behalf (such as payment processors or game providers), those entities act as data processors and are contractually bound to process data only in accordance with pesogame's instructions and to maintain appropriate data security standards.

2.1 For the purposes of the Data Privacy Act of 2012, pesogame is the data controller responsible for personal data collected through the pesogame.asia platform.

2.2 pesogame has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the DPA and this Privacy Policy. The DPO can be contacted at the support email address published in Section 14 of this Policy.

2.3 The pesogame.asia platform is operated in accordance with the online gaming regulatory framework administered by the Philippine Amusement and Gaming Corporation (PAGCOR). Data processing obligations arising from PAGCOR licensing requirements are conducted in compliance with both the DPA and applicable PAGCOR directives.

3.1 pesogame collects the following categories of personal data from players:

Identity and Contact Data:

• Full legal name as it appears on a Philippine government-issued ID
• Date of birth (for age verification and KYC compliance)
• Philippine mobile number (used for account verification and OTP delivery)
• Email address (used for account communications and password recovery)
• Residential address in the Philippines

KYC and Identity Verification Data:

• Copies or photographs of government-issued identification documents (Passport, SSS/UMID, Driver's License, PhilHealth ID, PhilSys ID, Voter's ID, or Postal ID)
• Selfie photographs submitted for facial verification purposes
• Tax Identification Number (TIN) where required by applicable Philippine tax reporting obligations

Financial and Transaction Data:

• GCash or PayMaya account numbers used for deposits and withdrawals
• Bank account details (BPI, BDO, Metrobank) where bank transfer is selected
• Deposit and withdrawal transaction history
• Account balance and bonus balance records

Gaming Activity Data:

• Game session history including game titles played, wager amounts, and outcomes
• Bingo room participation and result records
• Sports betting slip history including selected markets and settlement results
• Bonus and promotion history including claims and wagering progress
• Loyalty program tier status and points balance

Technical and Device Data:

• IP address at the time of each session
• Device type, operating system, and browser type
• Session duration and navigation patterns within the platform
• Cookies and similar tracking data as described in Section 7

Communications Data:

• Records of customer support interactions via live chat and email
• Complaint and dispute correspondence
• Marketing communication preferences and opt-in or opt-out records

pesogame collects personal data through the following channels:

• Account Registration: Information you provide when creating a pesogame account, including your name, mobile number, email address, date of birth, and chosen password.
• KYC Verification: Government ID documents and selfie photographs submitted through the pesogame verification interface or uploaded directly to the support team.
• Deposit and Withdrawal Transactions: Payment account details provided when processing financial transactions through GCash, PayMaya, BPI, BDO, or Metrobank.
• Gameplay: Data generated automatically by the pesogame platform as you engage with games, bingo rooms, and sports betting markets.
• Customer Support: Information you provide when contacting pesogame via live chat or email, including account details and descriptions of any issue you are reporting.
• Cookies and Tracking Technologies: Technical and behavioural data collected automatically when you access the platform, as described in Section 7.
• Third-Party Sources: Where legally permitted, pesogame may receive supplementary identity or fraud screening data from third-party identity verification or anti-fraud service providers operating under appropriate data processing agreements.

5.1 pesogame processes personal data for the following purposes, each resting on the applicable legal basis under the DPA:

• Account creation and management — necessary for the performance of the contract between pesogame and the player (DPA Section 13[b]).
• KYC identity and age verification — compliance with PAGCOR regulatory requirements and the legal obligation to prevent underage gambling (DPA Section 13[c]).
• Processing deposits and withdrawals — necessary for the performance of the contract and compliance with anti-money laundering obligations under Republic Act No. 9160 as amended (DPA Sections 13[b] and 13[c]).
• Fraud prevention and security monitoring — legitimate interests of pesogame in protecting the integrity of the platform and preventing financial crime (DPA Section 13[f]).
• Responsible gaming management — compliance with PAGCOR-mandated responsible gaming obligations, including the maintenance of self-exclusion records (DPA Section 13[c]).
• Customer support delivery — necessary for the performance of the contract and the legitimate interest in maintaining service quality (DPA Sections 13[b] and 13[f]).
• Marketing communications — based on your freely given and recorded consent at the time of opt-in. You may withdraw marketing consent at any time (DPA Section 13[a]).
• Regulatory reporting to PAGCOR and Philippine financial intelligence authorities — compliance with legal obligations (DPA Section 13[c]).
• Platform improvement and analytics — legitimate interests in improving the pesogame product for Filipino players, using aggregated and, where possible, anonymised data (DPA Section 13[f]).

5.2 pesogame will not use your personal data for any purpose materially different from those listed above without first providing you with prior notice and, where required by the DPA, obtaining your fresh consent.

6.1 pesogame does not sell, rent, or otherwise commercially transfer your personal data to unrelated third parties. Data is shared only in the following circumstances and only to the extent necessary for the specific purpose:

• Payment Processors: GCash (Mynt), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank receive the minimum transaction data necessary to process your deposits and withdrawals. These entities operate under their own privacy policies and applicable Philippine data privacy regulations.
• Game Providers: Certified game providers (such as JILI, Pragmatic Play, PG Soft, and Evolution Gaming) may receive limited player session identifiers necessary to deliver game content and maintain certified RNG systems. Game providers do not receive your full identity or financial data.
• KYC Verification Services: Third-party identity verification service providers may receive copies of your submitted ID documents for automated verification processing. These providers are contractually bound by data processing agreements consistent with the DPA.
• PAGCOR and Regulatory Authorities: pesogame is required by law to report certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine regulatory bodies in specified circumstances including suspicious transaction reports and self-exclusion register updates.
• Legal Proceedings: pesogame may disclose personal data where required to do so by a valid order of a Philippine court or other competent authority, or where disclosure is necessary to establish, exercise, or defend legal rights.
• Business Transfers: In the event of a merger, acquisition, or sale of pesogame's business operations, player data may be transferred to the acquiring entity subject to the same or equivalent data protection standards. Players will be notified of any such transfer in accordance with the DPA.

6.2 All third parties with whom pesogame shares personal data are subject to written data processing agreements that require them to process the data only in accordance with pesogame's instructions, to maintain appropriate security measures, and to comply with the DPA and applicable Philippine law.

7.1 The pesogame platform uses cookies and similar tracking technologies to provide certain platform functions, remember your session and preferences, and gather aggregated analytics data about platform usage. The types of cookies used are as follows:

• Essential Cookies: Required for the operation of the platform. These include session authentication cookies that maintain your logged-in state and security tokens. These cookies cannot be disabled without disrupting core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, session reminder configurations, and responsible gaming limit settings. Disabling functional cookies may affect your experience but will not prevent access to games.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate the platform — which pages are visited most often, session durations, and feature usage patterns. This data is used solely to improve the pesogame platform for Filipino players and is not linked to individual player identities.

7.2 pesogame does not use third-party advertising or behavioural targeting cookies. Analytics data collected on the pesogame platform is not shared with advertising networks or data brokers.

7.3 You may manage cookie preferences through your browser settings. Blocking essential cookies will prevent login and full platform access. For guidance on managing browser cookies, refer to your browser's help documentation.

8.1 pesogame implements technical and organisational security measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data in transit between player devices and pesogame servers
• AES-256 encryption for sensitive personal data stored at rest, including KYC documents and payment account references
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis
• Two-factor authentication options for player accounts to prevent unauthorised access
• Automated monitoring systems for suspicious login patterns and account access anomalies
• Regular internal security assessments and vulnerability management processes
• Staff training on data privacy obligations under the DPA and pesogame's internal data handling policies

8.2 Data Breach Response. In the event of a personal data breach that poses a real risk of serious harm to data subjects, pesogame will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular 16-03. Affected players will also be notified without undue delay where the breach is likely to result in high risk to their rights and freedoms.

8.3 While pesogame takes reasonable steps to secure your personal data, no electronic transmission or storage system is entirely infallible. You are responsible for maintaining the security of your own account credentials and for notifying pesogame promptly if you suspect unauthorised access to your account.

9.1 pesogame retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to any longer retention period required by applicable Philippine law or PAGCOR regulations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of an active Account relationship plus five (5) years following Account closure, in compliance with anti-money laundering record-keeping requirements under RA 9160.
• KYC Documents: Retained for five (5) years following Account closure or the date of the last transaction, whichever is later, as required by PAGCOR regulations and the AMLA.
• Financial Transaction Records: Retained for five (5) years following the date of each transaction, consistent with AMLC reporting obligations and PAGCOR record-keeping requirements.
• Gaming Activity Records: Retained for three (3) years following the date of each session, or longer where required for dispute resolution or regulatory purposes.
• Customer Support Records: Retained for two (2) years following the closure of each support interaction, or longer where related to an unresolved complaint or legal matter.
• Marketing Consent Records: Retained for the duration of any active marketing relationship plus two (2) years, as evidence of valid consent.

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

10.1 As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pesogame:

10.2 How to Exercise Your Rights. To exercise any of the rights listed above, submit a written request to the pesogame Data Protection Officer via the email address in Section 14. Include your full registered name and Account details for verification. pesogame will respond within fifteen (15) business days. Where a request cannot be fulfilled in full, pesogame will provide written reasons.

10.3 Complaints to the NPC. If you believe pesogame has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on NPC complaint procedures is available on the NPC's official website.

11.1 The pesogame platform is strictly restricted to individuals who are at least twenty-one (21) years of age. pesogame does not knowingly collect, store, or process the personal data of individuals under the age of 21.

11.2 As part of the KYC verification process, pesogame verifies the date of birth stated during registration against a submitted government-issued ID. Any account where the date of birth on the submitted ID indicates the holder is under 21 years of age is immediately suspended, the collected data is retained only for the minimum period required for regulatory reporting, and access to all gaming services is permanently denied to that individual.

11.3 If you have reason to believe that a minor has submitted personal data to pesogame or has registered an account, please contact our Data Protection Officer at the email address in Section 14 immediately. pesogame will promptly investigate and take appropriate action.

12.1 The pesogame platform is operated with Philippine players as its primary audience, and data processing is conducted primarily within the Philippines and through Philippine-compliant service providers. However, certain third-party service providers — including internationally certified game providers and cloud infrastructure services — may process or store data in server facilities located outside the Philippines.

12.2 Where personal data is transferred to a jurisdiction outside the Philippines, pesogame ensures that such transfers are carried out only where:

• The recipient jurisdiction has been assessed to provide an adequate level of data protection substantially equivalent to that provided by the DPA; or
• pesogame has entered into a data transfer agreement with the recipient that incorporates contractual clauses approved by the NPC or equivalent data protection authority; or
• The transfer is required for the performance of the contract between pesogame and the data subject; or
• The data subject has given explicit consent to the specific transfer after being informed of the possible risks.

12.3 pesogame maintains a register of all cross-border data transfers, which is available for review by the NPC upon request.

13.1 pesogame reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable Philippine law, PAGCOR regulatory requirements, the NPC's guidelines, or pesogame's data processing practices.

13.2 The date of the most recent revision to this Privacy Policy is displayed at the top of this page. Where a change is material — meaning it significantly alters how pesogame collects or uses personal data — pesogame will notify registered players via their registered email address or mobile number at least fourteen (14) days before the revised Policy takes effect.

13.3 Your continued use of the pesogame platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of and agreement to the revised terms. If you do not agree to a revised Privacy Policy, you should cease using the platform and may request Account closure in accordance with the pesogame Terms and Conditions.

14.1 For any queries, concerns, or requests relating to this Privacy Policy or pesogame's data processing practices, or to exercise any of your rights under the Data Privacy Act of 2012, please contact the pesogame Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 through the pesogame platform dashboard
• Subject Line: Please include "Privacy Request" or "Data Subject Rights" in your message subject for fastest routing

14.2 pesogame aims to acknowledge all data privacy requests within two (2) business days and to provide a substantive response within fifteen (15) business days. Complex requests involving large volumes of data or cross-system queries may take up to thirty (30) business days — pesogame will advise you of any extended timeframe in the acknowledgement response.

14.3 If you are not satisfied with pesogame's response to a data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC provides information on its complaint filing procedures on its official website.