psggc Privacy Policy

1 Introduction

psggc is committed to protecting the privacy and personal data of every Filipino player who uses our platform. This Privacy Policy has been prepared in accordance with Republic Act No. 10173 — the Data Privacy Act of 2012 (DPA) — its Implementing Rules and Regulations (IRR), and the guidelines issued by the National Privacy Commission (NPC) of the Philippines. It also reflects the data-related obligations imposed on psggc as a PAGCOR-regulated online gaming operator.

This Policy applies to all personal data collected through psggc.cam, the psggc mobile web interface, customer support channels, and any other psggc-operated touchpoint. It covers Filipino players based in Metro Manila, Cebu, Davao, and throughout the Philippines, as well as any individual who accesses psggc from another jurisdiction.

Please read this Policy carefully and in conjunction with our Terms & Conditions and Responsible Gaming Policy, which together form the complete legal framework governing your use of psggc.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, psggc is the Personal Information Controller (PIC) responsible for your personal data collected through the psggc platform. As PIC, psggc determines the purposes for which your personal data is collected and the manner in which it is processed.

psggc has designated a Data Protection Officer (DPO) responsible for overseeing data protection compliance, responding to data subject requests, and serving as the point of contact for the National Privacy Commission. Contact details for the psggc DPO are provided in Section 14 of this Policy.

Third-party service providers engaged by psggc to deliver platform functions — including game studios, payment processors, fraud detection services, and identity verification providers — act as Personal Information Processors (PIPs) under the DPA and process personal data only on psggc's documented instructions and subject to contractual data processing agreements.

3 Personal Data We Collect

psggc collects the following categories of personal data, based on legitimate purpose, legal obligation, or the necessity of processing for the delivery of contracted services:

psggc does not collect sensitive personal information as defined under Section 3(l) of the DPA — including racial or ethnic origin, political opinions, religious beliefs, health data, or sexual orientation — except where a player voluntarily discloses such information in the context of a responsible gaming or support interaction, and only to the extent necessary to provide appropriate assistance.

4 How We Collect Personal Data

4.1 Directly from You

The majority of personal data held by psggc is provided directly by you during account registration, KYC verification, payment transactions, customer support interactions, and responsible gaming tool setup. You are under no legal obligation to provide personal data to psggc; however, failure to provide required data will prevent psggc from opening or maintaining an account for you, as certain data is a legal requirement under PAGCOR and AMLA regulations.

4.2 Automatically via Platform Technology

When you access psggc.cam, technical data is collected automatically through standard internet technologies including server logs, session cookies, and browser fingerprinting. This data is used to maintain platform security, detect fraud, diagnose technical issues, and improve the player experience. See Section 7 for the full Cookies Policy.

4.3 From Third-Party Verification Services

psggc engages regulated third-party identity verification and fraud detection providers to assist with KYC processes required under PAGCOR licensing conditions and the Anti-Money Laundering Act. These providers may supply psggc with verification status data and risk scoring based on the identity documentation you submit. No raw financial account data from GCash, Maya, or Philippine banks is accessed by psggc beyond transaction reference identifiers necessary for payment reconciliation.

5 Purposes & Legal Basis for Processing

psggc processes personal data only for documented, specified, and legitimate purposes. The legal bases for processing under the Data Privacy Act of 2012 applicable to psggc's activities are:

• Contractual Necessity: Processing required to deliver the psggc gaming platform services you have registered and contracted for — including account management, game access, payment processing, and customer support;
• Legal Obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act of 2012, and other applicable Philippine laws — including KYC verification, transaction monitoring, and regulatory reporting;
• Legitimate Interests: Processing necessary for psggc's legitimate interests — including platform security, fraud prevention, responsible gaming monitoring, and service improvement — provided those interests are not overridden by your fundamental rights and freedoms as a data subject;
• Consent: Processing based on your freely given, specific, and informed consent — including the use of non-essential cookies and the sending of promotional communications. Consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal.

6 Sharing of Personal Data

6.1 Third-Party Service Providers

psggc shares personal data with carefully selected third-party service providers acting as Personal Information Processors, solely to the extent necessary for them to deliver their contracted services. These categories of providers include: identity verification and KYC technology providers; payment processing gateways including GCash, Maya, BPI, BDO, UnionBank, and Metrobank integration partners; live dealer game studio operators; fraud detection and cybersecurity services; customer support platform providers; and cloud infrastructure and data hosting services. All third-party processors are contractually bound to process personal data only on psggc's documented instructions and to maintain appropriate technical and organizational security measures.

6.2 Regulatory and Law Enforcement Disclosure

psggc is required by law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities upon lawful request, court order, or as required under applicable regulations. Such disclosures are made only to the extent required by law and do not constitute a waiver of your privacy rights beyond what the law mandates.

6.3 No Sale of Personal Data

psggc does not sell, rent, trade, or otherwise transfer your personal data to any third party for their own independent commercial purposes. Data-sharing relationships with third parties are exclusively service-delivery relationships governed by binding contractual obligations.

7 Cookies & Tracking Technologies

7.1 Types of Cookies Used

psggc uses the following categories of cookies on the platform:

• Strictly Necessary Cookies: Essential for core platform functionality — including maintaining your login session, processing payments, and enabling responsible gaming controls. These cannot be disabled without disrupting platform access;
• Functional Cookies: Retain your language preferences, display settings, and game lobby configuration to improve your experience across sessions;
• Analytics Cookies: Collect aggregated, anonymized data on platform usage patterns — including page visit frequency, session duration, and feature adoption — to help psggc improve service quality. No individual player is identifiable from analytics data;
• Security Cookies: Support fraud detection and session integrity verification. These are classified as strictly necessary and cannot be opted out of.

7.2 Managing Cookie Preferences

Non-essential cookies (functional and analytics) may be managed through your browser settings or the psggc cookie preference panel accessible from the platform footer. Disabling analytics cookies will not affect your ability to play games or process transactions on psggc. Disabling strictly necessary cookies will prevent normal platform operation.

8 Data Retention

psggc retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following retention periods apply:

• Account and Identity Data: Retained for the duration of the active account relationship plus five (5) years following permanent account closure, consistent with PAGCOR licensing obligations and Anti-Money Laundering Act record-keeping requirements;
• Financial Transaction Records: Retained for ten (10) years from the date of each transaction, as mandated by the AMLC and the PAGCOR regulatory framework for covered transaction reporting;
• Gaming History: Retained for the duration of the account relationship plus three (3) years for dispute resolution and responsible gaming audit purposes;
• Support Communications: Retained for three (3) years from the date of the interaction;
• Technical Logs: Retained for ninety (90) days unless flagged for security investigation;
• Responsible Gaming Records: Self-exclusion and cooling-off period records are retained for the duration of the exclusion period plus five (5) years, to prevent circumvention of exclusion commitments.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC data disposal guidelines. Anonymized data may be retained indefinitely for aggregate statistical analysis.

9 Data Security

psggc implements a comprehensive technical and organizational security framework to protect personal data against unauthorized access, disclosure, alteration, and destruction. Key security measures in place include:

• 256-bit SSL/TLS encryption for all data transmitted between player devices and psggc servers;
• At-rest encryption for all personally identifiable data stored in psggc databases;
• Role-based access controls restricting internal access to personal data to authorized personnel with documented business need;
• Two-factor authentication requirements for all psggc staff accessing production systems containing personal data;
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists;
• 24/7 automated intrusion detection and anomaly monitoring across psggc's infrastructure;
• Formal data breach response procedures aligned with NPC notification requirements under Section 20(f) of the DPA — including notification to affected players within 72 hours of confirmation of a breach where it is likely to result in significant harm.

While psggc employs industry-standard security measures, no online platform can guarantee absolute security against all threats. Players are encouraged to contribute to account security by maintaining a strong, unique psggc password, enabling two-factor authentication, and reporting suspicious account activity promptly.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by psggc. All requests are processed within thirty (30) calendar days of receipt, or within such extended period as permitted by applicable NPC guidelines where complex or high-volume requests require additional time.

To exercise any of your data subject rights, submit a written request to the psggc Data Protection Officer using the contact details provided in Section 14. psggc will verify your identity before processing any data subject request to ensure requests are acted upon only for the account holder concerned.

11 Children & Minors

The psggc platform is strictly for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. psggc does not knowingly collect personal data from minors. Our registration process includes mandatory date-of-birth collection and identity verification designed to prevent underage access.

If psggc discovers that personal data has been collected from a person under the age of 21, the account will be immediately closed, all data will be securely deleted as required by applicable law, and any deposited funds will be returned to the originating payment method pending identity verification, in accordance with PAGCOR responsible gaming requirements.

If you believe that a minor has accessed psggc or that their personal data has been inadvertently collected, please notify the psggc DPO immediately through the contact details in Section 14.

12 Cross-Border Data Transfers

Some of psggc's third-party service providers — including live dealer game studio operators and cloud infrastructure providers — may process personal data outside the Philippines. Where personal data is transferred outside the Philippines, psggc ensures that such transfers comply with Section 21 of the Data Privacy Act of 2012 and NPC Circular 16-01, and are subject to one of the following safeguards:

• The receiving jurisdiction provides an adequate level of protection for personal data as determined by the NPC;
• Appropriate contractual safeguards are in place through standard data processing agreements meeting NPC requirements; or
• The transfer is necessary for the performance of the contract between psggc and the player (e.g., live dealer game streaming).

psggc's primary data centers are located within the Philippines or in jurisdictions with contractually governed data processing arrangements. Information about specific cross-border data transfers may be requested from the psggc DPO.

13 Updates to This Privacy Policy

psggc may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. Material changes to this Policy will be communicated to registered players via the email address on file and through a notice displayed on the psggc platform, with a minimum of fourteen (14) days' advance notice before the revised Policy takes effect.

The effective date at the top of this Policy will be updated with each revision. It is your responsibility to review the current version of this Policy periodically. Your continued use of the psggc platform following the effective date of any revision constitutes your acknowledgment of the updated Policy.

The current version of this Privacy Policy is always accessible at psggc.cam/privacy-policy. Previous versions of the Policy are available upon request from the psggc DPO.

14 Contact & Data Protection Officer

For all privacy-related inquiries, data subject right requests, data breach reports, or questions regarding this Privacy Policy, please contact the psggc Data Protection Officer:

• Email: [email protected]
• Subject Line: "Privacy Request – [Your Registered Username]"
• Live Chat: Available 24/7 via the in-app support chat — select "Privacy & Data" as the inquiry category
• Response Time: Acknowledgment within 3 business days; full response within 30 calendar days as required by the DPA IRR

If you are not satisfied with psggc's response to a privacy inquiry, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC handles complaints from Philippine data subjects regarding violations of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.