maniplay Privacy Policy

1. Data Controller

1.1 For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and other applicable data protection legislation, maniplay is the data controller responsible for your personal data collected through the maniplay.club platform.

1.2 maniplay has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact the DPO using the contact details provided in Section 14 of this policy.

1.3 This Privacy Policy applies to all personal data collected by maniplay in connection with the provision of its online gaming and sports betting services to players in the Philippines and other permitted jurisdictions.

2. Personal Data We Collect

2.1 maniplay collects the following categories of personal data from players:

2.1.1 Identity & Contact Data

• Full legal name;
• Date of birth;
• Nationality and country of residence;
• Email address;
• Mobile phone number;
• Residential address.

2.1.2 Identity Verification Data (KYC)

• Government-issued photo ID (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID);
• Proof of address documents;
• Proof of payment method ownership.

2.1.3 Financial Data

• Payment method details (e.g., GCash account reference, bank account details for BPI, BDO, or Metrobank);
• Transaction history (deposits, withdrawals, and wagers);
• Account wallet balance.

2.1.4 Technical & Usage Data

• IP address and device identifiers;
• Browser type and version;
• Operating system;
• Pages visited and features used on the maniplay platform;
• Login timestamps and session duration;
• Geolocation data (country/region level).

2.1.5 Communications Data

• Records of communications between you and maniplay customer support;
• Feedback and survey responses;
• Marketing preferences.

3. How We Collect Your Data

3.1 maniplay collects personal data through the following means:

• Direct interactions: Data you provide when registering for a maniplay account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you use the maniplay platform, including through cookies, web beacons, and server logs.
• Third-party sources: Data received from identity verification service providers, payment processors (such as GCash and PayMaya), fraud prevention agencies, and publicly available sources, where permitted by applicable law.

4. How We Use Your Personal Data

4.1 maniplay uses your personal data for the following purposes:

5. Legal Basis for Processing

5.1 maniplay processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to perform our contract with you (i.e., to provide the maniplay gaming services you have registered for);
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements and PAGCOR regulatory obligations;
• Legitimate interests: Processing necessary for maniplay's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, such as for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. Data Sharing & Disclosure

6.1 maniplay does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

6.2 maniplay may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your deposits and withdrawals;
• Identity verification providers: Third-party KYC and AML service providers engaged by maniplay to verify player identities and comply with regulatory requirements;
• IT and platform service providers: Cloud hosting, data storage, and platform infrastructure providers engaged by maniplay to operate the platform;
• Regulatory authorities: PAGCOR and other competent Philippine government authorities, where disclosure is required by law or regulation;
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid legal order or where maniplay has reasonable grounds to believe that disclosure is necessary to prevent fraud, money laundering, or other criminal activity;
• Professional advisors: Legal, accounting, and auditing firms engaged by maniplay, subject to professional confidentiality obligations.

6.3 All third -party service providers engaged by maniplay are required to process your personal data only in accordance with maniplay's instructions and applicable data protection laws. maniplay does not permit third-party service providers to use your personal data for their own purposes.

7. Data Retention

7.1 maniplay retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

7.2 In general, maniplay applies the following retention periods:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in accordance with Philippine anti-money laundering regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications: Retained for three (3) years from the date of the last communication;
• Marketing preference data: Retained until you withdraw your consent or request deletion, whichever is earlier;
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymized or deleted.

7.3 Where maniplay is required by law to retain your personal data for a longer period, the statutory retention period will apply. Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized.

8. Cookies & Tracking Technologies

8.1 maniplay uses cookies and similar tracking technologies (such as web beacons and pixel tags) on the maniplay.club platform. Cookies are small text files placed on your device that help us recognize you, remember your preferences, and improve your experience on the platform.

8.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the operation of the maniplay platform, including maintaining your login session and enabling secure transactions. These cookies cannot be disabled.
• Performance and analytics cookies: Used to collect anonymized information about how players use the maniplay platform, helping us identify areas for improvement.
• Functionality cookies: Used to remember your preferences and settings, such as your preferred language and display options.
• Marketing cookies: Used to deliver relevant promotional content to you based on your interests and platform activity. These cookies are only placed with your consent.

8.3 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the maniplay platform.

9. Your Data Protection Rights

9.1 As a data subject under Philippine law, you have the following rights with respect to your personal data held by maniplay:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data that maniplay holds about you;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data that maniplay holds about you;
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to maniplay's legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on maniplay's legitimate interests;
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that maniplay has not handled your personal data in accordance with applicable law.

9.2 maniplay will respond to all data subject requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, and you will be notified accordingly.

10. Data Security

10.1 maniplay implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the maniplay platform;
• Encryption of sensitive data at rest, including financial and identity data;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of the maniplay platform;
• Two-factor authentication (2FA) options for player accounts;
• Continuous monitoring for suspicious activity and potential data breaches.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, maniplay will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay where required by law.

10.3 While maniplay takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. maniplay cannot guarantee absolute security and shall not be liable for unauthorized access resulting from circumstances beyond its reasonable control.

11. Children's Privacy

11.1 The maniplay platform is strictly intended for individuals who are 21 years of age or older. maniplay does not knowingly collect personal data from individuals under the age of 21.

11.2 If maniplay becomes aware that it has inadvertently collected personal data from an individual under the age of 21, it will take immediate steps to delete such data and close the associated account. If you believe that maniplay may have collected data from a minor, please contact our Data Protection Officer immediately using the details in Section 14.

12. International Data Transfers

12.1 maniplay primarily processes and stores your personal data within the Philippines. In certain circumstances, your personal data may be transferred to and processed by third-party service providers located outside the Philippines, such as cloud infrastructure providers.

12.2 Where such international transfers occur, maniplay ensures that appropriate safeguards are in place to protect your personal data, in accordance with the requirements of the Data Privacy Act of 2012 and the regulations of the National Privacy Commission. These safeguards may include contractual clauses requiring the recipient to apply equivalent data protection standards.

12.3 By using the maniplay platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of maniplay's services, subject to the safeguards described in this section.

13. Changes to This Privacy Policy

13.1 maniplay reserves the right to update or amend this Privacy Policy at any time. Any changes will be posted on this page with an updated "Last Updated" date. Where the changes are material, maniplay will endeavor to provide reasonable notice to players via email or a prominent notice on the platform.

13.2 Your continued use of the maniplay platform following the posting of any amendments to this Privacy Policy constitutes your acceptance of the revised policy. We encourage you to review this Privacy Policy periodically to stay informed about how maniplay protects your personal data.

14. Contact Us

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

• Email: [email protected]
• Response time: Within 15 business days of receipt
• Support hours: Daily, 8 AM – 12 MN PHT

14.2 If you are not satisfied with maniplay's response to your privacy inquiry, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.