inplay Privacy Policy

1 Introduction

inplay is committed to protecting the privacy and personal data of every player who uses our Platform. We understand that when you share your personal information with us, you are placing your trust in inplay, and we take that responsibility seriously. This Policy has been prepared in accordance with applicable Philippine data privacy laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

This Policy describes the types of personal data we collect from you, the purposes for which we process that data, the parties with whom we may share it, the security measures we employ to protect it, and the rights you have as a data subject under Philippine law. We encourage you to read this Policy carefully and to contact us if you have any questions or concerns about how inplay handles your personal information.

2 Personal Data We Collect

inplay collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include, but are not limited to, the following:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information unless specifically required by law or regulatory obligation and with your explicit consent.

3 How We Collect Your Data

inplay collects personal data through a variety of means, depending on how you interact with our Platform. The primary collection methods include:

• Direct Submission: Data you provide when you register for an inplay account, complete identity verification, make a deposit or withdrawal, contact our support team, or participate in promotions.
• Automated Collection: Technical data collected automatically when you access the inplay Platform, including IP addresses, device identifiers, browser information, and session activity logs, via cookies and similar tracking technologies.
• Third-Party Sources: Data received from payment processors (such as GCash, Maya, BPI, BDO, and Metrobank), identity verification service providers, fraud prevention partners, and regulatory databases, where permitted by law.
• Public Sources: Publicly available information used to verify your identity or to comply with anti-money laundering obligations, such as government registry data or sanctions lists.

4 How We Use Your Personal Data

inplay processes your personal data only for specific, legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The primary purposes for which inplay uses your personal data are as follows:

• Account Management: To create, maintain, and manage your inplay account, including verifying your identity and age (21+ requirement) in compliance with Philippine gaming regulations.
• Service Delivery: To process your deposits and withdrawals, provide access to games, and deliver the full range of inplay Platform features.
• Legal & Regulatory Compliance: To comply with applicable Philippine laws, including the Data Privacy Act of 2012, Anti-Money Laundering Act, and any requirements imposed by relevant gaming regulatory authorities.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other illegal or prohibited activities on the inplay Platform.
• Responsible Gaming: To monitor gaming activity and identify patterns that may indicate problem gambling, and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Marketing & Promotions: To send you relevant promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the inplay Platform.

5 Legal Basis for Processing

inplay processes your personal data on the following legal bases, as recognized under the Data Privacy Act of 2012 and applicable Philippine regulations:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to when registering for an inplay account, including account management, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including anti-money laundering obligations, age verification requirements, and regulatory reporting duties.
• Legitimate Interests: Processing is necessary for inplay's legitimate business interests, including fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as direct marketing communications and the use of non-essential cookies, inplay relies on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

inplay does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may, however, share your personal data with the following categories of recipients where necessary and lawful:

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged by inplay to verify your identity and comply with regulatory requirements.
• Game Content Providers: Licensed game suppliers and software providers who power the games available on the inplay Platform, to the extent necessary for game delivery and fairness auditing.
• Fraud Prevention & Security Partners: Specialist providers engaged to detect and prevent fraudulent activity, unauthorized access, and other security threats on the inplay Platform.
• Regulatory & Law Enforcement Authorities: Government agencies, regulatory bodies, and law enforcement authorities in the Philippines, where disclosure is required by law, court order, or regulatory directive.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by inplay, subject to strict confidentiality obligations.

7 Cookies & Tracking Technologies

The inplay Platform uses cookies and similar tracking technologies to enhance your browsing experience, maintain your session, and collect analytical data about how the Platform is used. Cookies are small text files stored on your device when you visit the inplay website.

inplay uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the inplay Platform, including maintaining your login session and enabling core functionality. These cookies cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymized data about how visitors use the inplay Platform, helping us identify areas for improvement. These cookies do not identify you personally.
• Functionality Cookies: Used to remember your preferences and settings on the inplay Platform, such as your preferred language or display settings.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of inplay marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the inplay Platform. For more information on managing cookies, refer to your browser's help documentation.

8 Data Security

inplay implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the inplay Platform is encrypted using industry-standard SSL/TLS protocols.
• Secure Data Storage: Personal data is stored on secure servers with restricted access controls, firewalls, and intrusion detection systems.
• Access Controls: Access to personal data within inplay is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Regular Security Audits: inplay conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in our systems.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their inplay accounts for an additional layer of security.

9 Data Retention

inplay 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 regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active inplay account, plus a period of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Gaming History: Bet and gaming session records are retained for five (5) years to support dispute resolution, regulatory audits, and responsible gaming monitoring.
• Support Communications: Customer support records are retained for three (3) years from the date of the last interaction.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymized within thirty (30) days.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized so that it can no longer be associated with you as an individual.

10 Your Data 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 inplay. To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14.