Hawplay Privacy Policy — How We Protect Your Data

This Privacy Policy applies to all personal information collected, processed, stored, or shared by Hawplay in connection with the operation of the hawplay.com platform and all related products and services. It applies to registered members, prospective members who browse the platform, and anyone who contacts Hawplay through any support channel.

Hawplay is committed to protecting the personal data of every member in accordance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012, and its Implementing Rules and Regulations. We are registered with the National Privacy Commission (NPC) as required under Philippine law.

By registering a Hawplay account or using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to any part of this Policy, please do not use the Hawplay platform.

For the purposes of the Philippine Data Privacy Act, the data controller for all personal information processed through the Hawplay platform is the Philippine-incorporated legal entity operating hawplay.com under its PAGCOR license.

You may contact the Hawplay Data Protection Officer (DPO) at any time regarding privacy matters:

• Email: privacy@hawplay.com
• General support email: support@hawplay.com
• Subject line for privacy queries: "Data Privacy Request"

Hawplay's DPO is responsible for overseeing compliance with the Data Privacy Act, responding to data subject requests, and maintaining Hawplay's registration with the National Privacy Commission.

The personal data Hawplay collects depends on how you interact with the platform. The main categories are:

Hawplay does not knowingly collect sensitive personal information beyond what is required for identity and age verification under our PAGCOR license and anti-money laundering obligations.

Hawplay collects personal data through the following channels:

• Directly from you — when you register, complete identity verification, make a deposit or withdrawal, contact support, or use platform features.
• Automatically — through cookies, session tracking, and server logs when you browse or use the Hawplay platform. See Section 9 for details.
• From third-party verification services — Hawplay uses regulated identity verification providers to confirm your identity documents against authoritative Philippine databases as required by our PAGCOR license and AML obligations.
• From payment processors — when you deposit or withdraw via GCash, Maya, or bank transfer, your payment provider shares the transaction reference and account details necessary to process the movement of funds.

Hawplay uses member personal data for the following purposes:

• Account creation and management: To register your Hawplay account, verify your identity and age, maintain accurate account records, and process account changes.
• Service delivery: To operate sports betting, live casino, Pusoy, and all other Hawplay products that you use.
• Payment processing: To process deposits and withdrawals in PHP via GCash, Maya, bank transfer, and other supported channels, and to maintain transaction records as required by Philippine financial regulations.
• Regulatory compliance: To fulfil obligations under Hawplay's PAGCOR license, including identity verification, age verification, responsible gaming monitoring, and anti-money laundering (AML) checks as required under Republic Act No. 9160 and its amendments.
• Security and fraud prevention: To detect and prevent unauthorised account access, bonus abuse, identity fraud, money laundering, and other prohibited activities.
• Customer support: To respond to your queries, process complaints, and provide assistance via live chat or email.
• Responsible gaming: To administer the deposit limits, cool-off periods, and self-exclusion options you set, and to identify account activity patterns that may indicate gaming-related difficulty.
• Platform improvement: To understand how members use the Hawplay platform and identify areas for technical and product improvement, using aggregated and anonymised data where possible.
• Marketing communications: To send you relevant promotional offers and platform updates if you have opted in to marketing communications. You may opt out at any time.

Under the Philippine Data Privacy Act, Hawplay processes your personal data on one or more of the following legal bases:

• Consent: Where you have provided explicit consent, such as for marketing communications or the use of non-essential cookies. You may withdraw consent at any time.
• Contractual necessity: Processing required to fulfil the account agreement between you and Hawplay — including account operation, payment processing, and service delivery.
• Legal obligation: Processing required to comply with Hawplay's obligations under Philippine law, including PAGCOR regulations, AML legislation, the Data Privacy Act, and NPC registration requirements.
• Legitimate interests: Processing necessary for Hawplay's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, and internal analytics using anonymised data.

Hawplay does not sell your personal data to any third party. We share personal data only in the following limited circumstances:

• Identity and age verification providers: Regulated Philippine verification services used to confirm identity documents as required by our PAGCOR license.
• Payment processors: GCash, Maya, BDO, BPI, UnionBank, and other licensed Philippine payment channels necessary to process your deposits and withdrawals.
• PAGCOR: Hawplay submits required regulatory reports to PAGCOR in accordance with our license conditions. These reports may include aggregated transaction and member activity data.
• Philippine law enforcement and courts: Where Hawplay is required by a valid legal order, court process, or lawful government request to disclose member information.
• AML reporting: Where transaction monitoring identifies a matter requiring reporting under Philippine anti-money laundering law, Hawplay will fulfil its reporting obligations to the Anti-Money Laundering Council (AMLC).
• Service providers acting as data processors: Technology providers, hosting services, and customer support tools that process data on Hawplay's behalf under binding data processing agreements. These providers may not use your data for their own purposes.

Hawplay retains personal data only for as long as necessary for the purposes described in this Policy, and for the minimum periods required by Philippine law. Key retention periods include:

• Account and identity data: For the duration of your active Hawplay account, plus a minimum of five years following account closure, as required by PAGCOR license conditions and AML regulations.
• Transaction and financial data: A minimum of five years from the date of each transaction, consistent with Philippine AML record-keeping requirements.
• Support and communications data: Up to three years from the date of the interaction, unless a longer period is required for an open complaint or regulatory matter.
• Marketing preferences: Until you withdraw consent or request erasure, whichever is earlier.
• Cookies and technical data: As specified in Section 9. Most session data is not retained beyond the individual session.

When the applicable retention period expires and no legal obligation requires further retention, Hawplay securely deletes or anonymises the data concerned.

The Hawplay platform uses cookies and similar tracking technologies to operate certain platform functions, understand how members use the site, and improve the overall experience. The main categories of cookies Hawplay uses are:

• Strictly necessary cookies: Required for the platform to function — including session management, login state, and security token storage. These cannot be disabled without breaking core functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming limit reminders.
• Analytics cookies: Used to understand how members navigate the Hawplay platform in aggregate — page views, session duration, feature usage — to help us improve the product. This data is anonymised before analysis.
• Security cookies: Help detect and prevent fraudulent login attempts and unusual account activity.

Hawplay does not use third-party advertising or tracking cookies that follow you across unrelated websites. You can manage cookie preferences through your browser settings at any time, though disabling strictly necessary cookies will affect platform functionality.

Hawplay applies a layered approach to data security covering technical, organisational, and procedural controls:

• Encryption in transit: All data exchanged between your device and Hawplay servers is encrypted using TLS. The Hawplay platform is only accessible over HTTPS.
• Encryption at rest: Sensitive member data stored on Hawplay infrastructure is encrypted at rest.
• Access controls: Access to personal data within Hawplay is restricted on a strict need-to-know basis. Staff access is logged and audited.
• Two-factor authentication: Available for all Hawplay member accounts and required for sensitive operations including large withdrawals.
• Regular security assessment: Hawplay conducts regular security reviews of its platform architecture and data handling procedures.
• Incident response: Hawplay maintains a documented data breach response procedure consistent with NPC notification requirements under the Data Privacy Act.

No data transmission over the internet is completely secure, but Hawplay takes reasonable and proportionate measures to protect member data against unauthorised access, disclosure, or loss.

As a data subject under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by Hawplay:

• Right to be informed: The right to know what personal data Hawplay holds about you and how it is being used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data Hawplay holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to Hawplay's legal retention obligations under PAGCOR regulations and AML law.
• Right to object: The right to object to processing of your personal data for specific purposes, including direct marketing.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, contact Hawplay's Data Protection Officer at privacy@hawplay.com with the subject line "Data Privacy Request." Hawplay will acknowledge all requests within 72 hours and respond fully within 15 business days, consistent with NPC guidelines.

The Hawplay platform is strictly for eligible adults aged 21 and above. Hawplay does not knowingly collect or process personal data of individuals under 21 years of age. All account registrations are subject to identity and age verification.

If Hawplay becomes aware that an account has been registered by or on behalf of an individual under the eligible age, the account will be immediately suspended, all funds returned to the source payment method where possible, and the personal data of the underage individual securely deleted. If you believe an underage person has registered on Hawplay, please notify us immediately at support@hawplay.com.

Hawplay may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform features. The date shown at the top of this page reflects the most recent revision.

Where a change materially affects how Hawplay processes your personal data, we will notify registered members by email before the change takes effect, and will post a prominent notice on the Hawplay platform. Non-material clarifications or corrections will take effect upon publication without advance notice.

Continued use of the Hawplay platform following any update to this Policy constitutes acceptance of the revised Privacy Policy. If you do not agree with any update, please contact us to discuss or close your account before the effective date of the change.

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by Hawplay, please contact:

• Data Protection Officer email: privacy@hawplay.com
• General support email: support@hawplay.com
• Live chat: Available 24/7 through your logged-in Hawplay account
• Subject line: Please use "Data Privacy Request" for all privacy-related correspondence

If you are not satisfied with Hawplay's response to a privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines, which maintains a complaints process for data subjects under the Data Privacy Act.