CPunkPlay Privacy Policy — How We Handle Your Personal Data

CPunkPlay takes your privacy seriously — not as a legal formality, but as a genuine commitment to every Filipino player who trusts us with their personal information. This Privacy Policy explains how CPunkPlay collects, uses, stores, and protects your personal data when you register, deposit, play, or otherwise interact with the CPunkPlay platform at cpunkplay.app.

This policy applies to all CPunkPlay services and to all registered and prospective users located in the Philippines. By registering an account or continuing to use the CPunkPlay platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

CPunkPlay operates in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations. We treat all personal data in a manner consistent with the principles of transparency, legitimate purpose, and proportionality as defined under Philippine law.

CPunkPlay is an online gaming platform operating at cpunkplay.app, serving Filipino players aged 21 and above across the Philippines. CPunkPlay is the data controller for all personal information collected through the platform. This means CPunkPlay determines the purposes for which your personal data is processed and the means by which that processing takes place.

If you have any questions about how CPunkPlay handles your personal data, or if you wish to exercise any of your data rights, you can contact our Data Protection Officer (DPO) at support@cpunkplay.app. We aim to respond to all privacy-related enquiries within five (5) business days.

CPunkPlay collects personal data in different ways depending on how you interact with the platform. Below is a comprehensive overview of the categories of data we collect and the contexts in which we collect them.

CPunkPlay only collects data that is necessary for a legitimate purpose. We do not collect sensitive personal information such as racial or ethnic origin, religious beliefs, or health data, except where gaming activity data is used to administer our responsible gaming tools (e.g., detecting problem gambling patterns for player protection purposes).

CPunkPlay collects and processes your personal data for specific, declared purposes only. We will not use your data in a way that is incompatible with the purpose for which it was originally collected without your explicit consent.

• Account creation and management: To register you as a CPunkPlay player, maintain your account, verify your identity, and manage your profile settings.
• Payment processing: To facilitate deposits and withdrawals in Philippine Peso via GCash, Maya, bank transfers, and other supported local payment channels. CPunkPlay needs your payment account details to process transactions accurately.
• Game delivery and fairness: To deliver CPunkPlay's gaming services — Tongits, Pusoy, Bingo, Slots, Live Casino, PBA Betting — and to maintain the integrity and fairness of all games, including detection of fraudulent activity and collusion.
• Bonuses and promotions: To verify your eligibility for CPunkPlay's promotional offers, credit bonuses to qualifying accounts, and prevent duplicate or fraudulent bonus claims.
• Legal and regulatory compliance: To meet CPunkPlay's obligations under Philippine gaming regulation and the Data Privacy Act of 2012, including Know Your Customer (KYC) requirements, anti-money laundering (AML) monitoring, and age verification.
• Responsible gaming: To monitor gaming activity for patterns consistent with problem gambling, to administer self-exclusion tools, deposit limits, and loss limits, and to fulfil CPunkPlay's duty of care to the Filipino player community.
• Customer support: To respond to your enquiries, resolve disputes, and process complaints efficiently and accurately.
• Platform improvement: To analyse aggregated, anonymised usage patterns and improve CPunkPlay's features, performance, and user experience over time.
• Marketing communications: Where you have opted in, to send you information about CPunkPlay promotions, new game releases, and platform updates. You can opt out at any time via your account settings or by emailing support@cpunkplay.app.

Under the Data Privacy Act of 2012 (RA 10173), CPunkPlay must have a lawful basis for each type of personal data processing it undertakes. The following bases apply to CPunkPlay's data processing activities:

• Contractual necessity: Processing required to fulfil CPunkPlay's obligations under the account agreement with you — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with Philippine law, including gaming regulation, AML obligations, KYC requirements, and data protection law itself.
• Legitimate interests: Processing carried out for CPunkPlay's legitimate business interests where these are not overridden by your rights — including fraud detection, platform security, and anonymised analytics.
• Consent: For marketing communications and any optional data processing beyond what is necessary for service delivery. You may withdraw consent at any time without affecting the lawfulness of prior processing.

CPunkPlay does not sell your personal data to third parties. Period. Your information is shared only in the limited circumstances described below, and only with parties who are bound by strict data processing agreements or regulatory obligations.

• CPunkPlay internal staff: Only employees and contractors with a legitimate business need to access your data are permitted to do so. Access is controlled through role-based permissions and is logged and audited.
• Payment processors: GCash, Maya, BDO, BPI, UnionBank, and other Philippine payment providers receive only the transactional data necessary to process deposits and withdrawals. CPunkPlay does not share your gaming history or personal profile with payment processors.
• Identity verification providers: Third-party KYC services engaged by CPunkPlay to verify government-issued IDs and conduct liveness checks during account verification. These providers operate under strict data processing agreements.
• Regulatory authorities: Philippine gaming regulators and law enforcement authorities may receive data from CPunkPlay where CPunkPlay is legally required to provide it — for example, as part of an AML investigation or a regulatory audit.
• Technology and infrastructure providers: Cloud hosting and security service providers who process data on CPunkPlay's behalf under data processing agreements that impose equivalent data protection standards.

CPunkPlay uses cookies and similar tracking technologies to operate the platform, keep you logged in, prevent fraud, and improve the user experience. Here is what each type does:

• Essential cookies: Required for CPunkPlay to function at all. These maintain your login session, remember your account preferences, and enable secure payment flows. You cannot opt out of these without stopping your use of the platform.
• Functional cookies: Remember your settings and preferences across sessions — such as your preferred game lobby layout or language settings.
• Analytics cookies: Collect anonymised data on how players navigate CPunkPlay — which features are used most, where errors occur, how long sessions last. This data is aggregated and not linked to individual player identities.
• Security cookies: Help CPunkPlay detect and prevent fraudulent activity, including duplicate account detection and bot behaviour identification.

CPunkPlay does not use third-party advertising cookies or share tracking data with advertising networks. You can manage non-essential cookie preferences via the cookie settings link in the CPunkPlay platform footer. Note that disabling essential cookies will prevent the platform from functioning correctly.

CPunkPlay retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law. Specific retention periods are as follows:

• Account data (registration, profile): Retained for the duration of your active account and for five (5) years following account closure.
• Financial transaction records: Retained for seven (7) years in compliance with Philippine AML and financial record-keeping obligations.
• KYC/identity verification documents: Retained for five (5) years after your last transaction or account closure, whichever is later.
• Game activity logs: Retained for five (5) years for compliance, dispute resolution, and RNG audit purposes.
• Customer support communications: Retained for three (3) years from the date of the interaction.
• Marketing consent records: Retained for the duration of your consent and for one (1) year after withdrawal of consent.

When data reaches the end of its retention period, CPunkPlay deletes or anonymises it securely. Anonymised data — where all identifying information has been irreversibly removed — may be retained indefinitely for platform analytics and improvement purposes.

CPunkPlay implements a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• 256-bit SSL/TLS encryption on all data transmissions between your device and CPunkPlay servers
• At-rest encryption for all personal and financial data stored in CPunkPlay's databases
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis
• Multi-factor authentication for all CPunkPlay administrative systems and staff accounts
• Regular penetration testing and third-party security audits
• Intrusion detection systems monitoring for unusual access patterns 24/7
• Incident response procedures to ensure that any data breach is contained, investigated, and reported to the National Privacy Commission within the timeframes required by law

In the event of a personal data breach that poses a real risk of serious harm to your rights and freedoms as a data subject, CPunkPlay will notify you directly and will report the breach to the National Privacy Commission (NPC) within 72 hours of becoming aware of it, in accordance with RA 10173.

As a CPunkPlay player based in the Philippines, you have the following rights over your personal data under RA 10173. CPunkPlay will honour all valid data rights requests within 30 days of receipt. Some requests may require identity verification before we can process them.

CPunkPlay is strictly for players aged 21 and above. CPunkPlay does not knowingly collect personal data from anyone under the age of 21. Age verification is performed during account registration and may be repeated at any point during the account lifecycle.

If CPunkPlay becomes aware that personal data has been collected from a player who is under 21 years of age, that data will be deleted immediately and the account will be permanently closed. Any deposits held in an underage account will be refunded to the verified payment source before closure.

If you believe a minor has registered a CPunkPlay account, please contact us immediately at support@cpunkplay.app. CPunkPlay takes underage gaming and underage data collection extremely seriously.

CPunkPlay may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, CPunkPlay will notify all registered players via email and via an in-platform notification at least seven (7) days before the changes take effect.

The updated Privacy Policy will be published on this page with a revised "Last Updated" date at the top. Your continued use of CPunkPlay after the effective date of the updated policy constitutes acceptance of the revised terms. If you do not agree with the updated policy, you may close your account by contacting support@cpunkplay.app.

To exercise any of your data rights, ask a question about this Privacy Policy, or report a potential data security concern, please contact CPunkPlay's Data Protection Officer through any of the following channels:

• Email: support@cpunkplay.app (mark your subject line: "Privacy Request")
• Live Chat: Available through your CPunkPlay account dashboard during peak hours (9 AM – 11 PM PHT)

CPunkPlay will acknowledge your request within 3 business days and provide a full response within 30 calendar days. Complex requests may require up to 60 days with written notification of the extension provided to you.

If you are not satisfied with CPunkPlay's response to a privacy request or complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing RA 10173.