Privacy Policy — pirya Online Casino

1 Who We Are

pirya operates the online casino and sports betting platform accessible at pirya.net (the "Platform"), offering games, live dealer tables, bingo, slots, and sports markets to Filipino players. For the purposes of this Privacy Policy, pirya acts as the personal information controller of the data you provide when using the Platform.

As a personal information controller under Republic Act No. 10173 (the Data Privacy Act of 2012, or "DPA"), pirya is responsible for determining the purposes and means by which your personal data is processed, and for ensuring that such processing is carried out lawfully, fairly, and transparently.

If you have any questions about how pirya handles your personal data, you may reach our Data Protection Officer at [email protected].

2 Personal Data We Collect

pirya collects the following categories of personal data, depending on how you interact with the Platform:

2.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — you must be 21 or older to use pirya)
• Nationality and country of residence
• Email address and mobile number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Government-issued photo ID (e.g., Philippine passport, SSS ID, UMID, PhilHealth ID, driver's licence)
• Proof of address documents (e.g., utility bill, bank statement)
• Selfie or live photo for identity confirmation, where required

2.3 Financial & Transaction Data

• Deposit and withdrawal amounts, dates, and payment method references (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard)
• Transaction history and account balance records
• Bank account numbers or e-wallet identifiers (stored in encrypted form)

2.4 Gaming & Activity Data

• Game play history, bet amounts, win/loss records, and session durations
• Responsible gaming settings, deposit limits, and self-exclusion history
• Bonus and promotion claims and wagering activity

2.5 Technical & Device Data

• IP address, device type, operating system, and browser type
• Geolocation data (country/region level) derived from IP address
• Cookies, session tokens, and analytics identifiers
• Log files recording access times, pages visited, and error reports

2.6 Communications Data

• Records of customer support interactions via chat, email, or any other channel
• Survey responses and feedback submitted through the Platform
• Marketing communication preferences and opt-in/opt-out records

3 How We Collect Your Data

pirya collects your personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions on the pirya platform.
• Automatically: Through cookies, web beacons, log files, and similar tracking technologies when you access and interact with the pirya website or mobile interface.
• From payment providers: pirya receives confirmation and reference data from payment processors (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard) when you make financial transactions through the Platform.
• From identity verification services: Where pirya uses third-party KYC service providers to assist with document verification and fraud prevention.
• From fraud prevention and analytics partners: Aggregated or pseudonymised data shared by authorised service providers for the purpose of detecting suspicious activity and improving Platform performance.

4 Why We Use Your Personal Data

pirya processes your personal data for the following purposes:

5 Legal Bases for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, pirya processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and pirya — including account management, payments, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and tax reporting.
• Legitimate interests: Processing carried out for pirya's legitimate business interests, such as fraud prevention, security monitoring, platform analytics, and responsible gaming measures — provided that such interests are not overridden by your fundamental rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily in respect of direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

pirya does not sell your personal data. pirya may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection obligations:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard — to facilitate deposits and withdrawals.
• KYC and identity verification providers: Authorised third-party services that assist pirya in verifying member identities and conducting fraud checks.
• Game content providers: Licensed game studios whose software powers pirya's slot, live dealer, and table game offerings — limited to data necessary to operate game sessions.
• Cloud infrastructure and hosting providers: Service providers that host and maintain the pirya platform infrastructure under strict data processing agreements.
• Regulatory authorities: Philippine government agencies, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and courts or law enforcement, where required by law or court order.
• Professional advisors: Legal, audit, and compliance advisors bound by professional confidentiality obligations.

7 International Data Transfers

Some of pirya's authorised service providers may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection as the Philippines, pirya will ensure that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by the National Privacy Commission;
• Binding corporate rules applicable to the recipient organisation;
• The recipient country being recognised as providing adequate data protection standards; or
• Your explicit consent to the transfer, where required.

By using the pirya platform, you acknowledge and consent to the transfer of your personal data to service providers in jurisdictions outside the Philippines as described in this section, subject to the safeguards outlined above.

8 Data Retention

pirya retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your membership and for a minimum of five (5) years following account closure, in compliance with AML and KYC regulatory requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AML legislation.
• Gaming activity records: Retained for a minimum of three (3) years from the date of the gaming session.
• Customer support records: Retained for three (3) years from the date of the interaction, unless a longer period is required for dispute resolution purposes.
• Marketing preference records: Retained until you withdraw consent or request deletion, whichever is earlier, subject to legal retention obligations.

Upon expiry of the applicable retention period, pirya will securely delete or anonymise your personal data so that it can no longer be attributed to you.

9 Cookies & Tracking Technologies

pirya uses cookies and similar tracking technologies (such as web beacons and session tokens) to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management and secure login. These cannot be disabled.
• Performance and analytics cookies: Used to collect aggregated, anonymised information about how members use the Platform, helping pirya identify areas for improvement.
• Functionality cookies: Allow pirya to remember your preferences, such as language settings and responsible gaming limits, to provide a more personalised experience.
• Security cookies: Used to detect and prevent fraudulent activity, including session hijacking and account takeover attempts.

You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the pirya platform. pirya does not use third-party advertising or behavioural targeting cookies.

10 Your Data Rights

Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights with respect to your personal data held by pirya:

11 Children's Privacy

The pirya platform is strictly for adults aged 21 years and above. pirya does not knowingly collect personal data from individuals under the age of 21. The Platform employs age verification measures during registration and KYC processes to prevent underage access.

If pirya discovers that personal data has been collected from a person under 21 years of age, that account will be immediately suspended, all data will be deleted to the extent permitted by law, and the matter may be referred to the appropriate Philippine authorities.

If you believe that pirya has inadvertently collected personal data from a person under 21, please notify us immediately at [email protected].

12 Security Measures

pirya takes the security of your personal data seriously and implements the following technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction:

• TLS/SSL Encryption: All data transmitted between your device and the pirya platform is encrypted using TLS 1.2 or higher, providing industry-standard protection for data in transit.
• Data Encryption at Rest: Sensitive data stored in pirya's systems — including financial account references and identity documents — is encrypted using strong encryption standards.
• Access Controls: Access to personal data is restricted to pirya personnel and authorised service providers who have a legitimate need to process such data. All access is logged and auditable.
• Two-Factor Authentication: pirya supports two-factor authentication (2FA) for member accounts, adding an additional layer of security beyond username and password.
• Regular Security Audits: pirya conducts periodic security assessments and vulnerability testing to identify and address potential weaknesses in the platform infrastructure.
• Incident Response: pirya maintains a data breach response plan. In the event of a personal data breach that poses a risk to members, pirya will notify the National Privacy Commission and affected members in accordance with the timelines prescribed by the DPA.

While pirya employs robust security measures, no system is completely immune to security threats. Members are encouraged to use strong, unique passwords for their pirya accounts and to enable two-factor authentication where available.

13 Third-Party Links

The pirya platform may contain links to third-party websites or services for informational purposes, such as links to payment provider portals or regulatory bodies. This Privacy Policy applies solely to the pirya platform and does not govern the privacy practices of any third-party website or service.

pirya is not responsible for the privacy practices, content, or data handling of any third-party website. We encourage you to review the privacy policies of any third-party websites you visit through links on the pirya platform before providing any personal data to those sites.

14 Amendments to This Policy

pirya reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or pirya's data processing practices. When material changes are made, pirya will notify registered members by posting a prominent notice on the Platform or by sending a notification to your registered email address.

The date of the most recent revision is indicated at the top of this page. Your continued use of the pirya platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically.

15 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way pirya handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Response Time: pirya aims to respond to all privacy-related enquiries within fourteen (14) business days.
• Data Rights Requests: Handled within thirty (30) days in accordance with the DPA.

If you are not satisfied with pirya's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC), the supervisory authority responsible for enforcing the Data Privacy Act of 2012. You may contact the NPC through its official channels as published on the NPC's official government website.