Privacy Policy

1 About This Policy

spnph ("the Platform," "we," "us," or "our") is committed to protecting the personal data of all individuals who access and use the spnph online gaming platform. This Privacy Policy has been prepared in accordance with the Data Privacy Act of 2012 of the Philippines (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

As the personal information controller in relation to data collected through the spnph platform, we are responsible for determining the purposes and means by which your personal data is processed. This policy sets out in transparent and clear terms how we fulfill that responsibility.

This Privacy Policy should be read alongside the spnph Terms & Conditions, which constitute the primary agreement governing your use of the platform. In the event of any inconsistency between this Privacy Policy and the Terms & Conditions on a privacy-related matter, the Privacy Policy shall prevail.

2 Personal Data We Collect

spnph collects personal data in the following categories. We only collect data that is adequate, relevant, and limited to what is necessary for the specified purposes.

2.1 Registration and Identity Data

When you create a spnph player account, we collect your full legal name, date of birth, email address, mobile phone number, and residential address. This information is required to open your account, verify your identity, and comply with our Know Your Customer (KYC) obligations under applicable gaming regulations.

2.2 Identity Verification (KYC) Documents

To verify your age and identity — and to comply with anti-money laundering (AML) requirements — spnph may request copies of government-issued identification documents. Accepted documents include the Philippine passport, driver's license, PhilSys National ID, UMID card, SSS ID, and Voter's ID. We may also request proof of residential address such as a utility bill or bank statement dated within the past three months.

2.3 Financial and Transaction Data

spnph collects data related to deposits, withdrawals, and in-platform transactions, including transaction amounts in Philippine Peso, payment method identifiers (such as your GCash-registered mobile number or bank account name), transaction timestamps, and transaction reference numbers. We do not store full bank account numbers or card numbers — these are handled directly by our payment service providers.

2.4 Gaming Activity Data

We record your betting and gaming activity on the spnph platform, including games played, bet amounts, outcomes, session durations, and wagering history. This data is used for account administration, dispute resolution, responsible gaming monitoring, and regulatory reporting purposes.

2.5 Technical and Device Data

When you access the spnph platform, we automatically collect certain technical data, including your IP address, device type and operating system, browser type and version, screen resolution, and general geographic location derived from your IP address. This data is used to secure your account, detect fraud, and optimize platform performance across the devices used by our Filipino player base.

2.6 Communications Data

If you contact the spnph support team via email or live chat, we retain records of those communications, including the content of your messages and the date and time of contact. This enables us to track the resolution of your queries and maintain a consistent service history.

3 How We Collect Your Data

spnph collects personal data through the following means:

• Directly from you — when you register a player account, complete KYC verification, make a deposit or withdrawal, contact support, or update your account profile.
• Automatically — through cookies, server logs, and tracking technologies when you access and navigate the spnph platform on any device.
• From payment service providers — GCash, Maya, QR Ph, GrabPay, BPI, BDO, and Metrobank may share transaction confirmation data with spnph as part of the payment settlement process.
• From identity verification services — where spnph uses a third-party KYC verification provider, that provider may share document verification results and identity match scores with us.
• From fraud prevention and security services — spnph may receive data signals from fraud detection partners to help identify and prevent unauthorized account access and suspicious betting activity.

4 How We Use Your Personal Data

spnph uses collected personal data for the following specific purposes. We do not use your data for any purpose that is incompatible with the reasons it was originally collected.

• Account Management: Creating, maintaining, and administering your spnph player account, including processing login sessions, managing your PHP wallet balance, and applying account settings such as deposit limits and self-exclusion preferences.
• Identity and Age Verification: Verifying that you meet the minimum age requirement of 21 years and confirming the accuracy of your registration information in compliance with applicable Philippine gaming regulations.
• Payment Processing: Facilitating deposits and withdrawals in Philippine Peso through GCash, Maya, BPI, BDO, Metrobank, QR Ph, and GrabPay. Matching payment account details to your verified spnph player account to prevent unauthorized transactions.
• Fraud Prevention and Security: Detecting and preventing unauthorized account access, multiple account registration, bonus abuse, money laundering, and other fraudulent or prohibited activities as defined in the spnph Terms & Conditions.
• Responsible Gaming: Monitoring gaming activity patterns to identify potential signs of problem gambling and administering responsible gaming tools including deposit limits, loss limits, and self-exclusion at the player's request.
• Legal and Regulatory Compliance: Meeting spnph's obligations under the Data Privacy Act of 2012, applicable anti-money laundering legislation, and the reporting requirements of relevant Philippine gaming and financial regulators.
• Customer Support: Responding to player queries, resolving disputes, and maintaining a record of support interactions to deliver consistent service.
• Platform Improvement: Analyzing aggregated and anonymized usage data to understand platform performance, identify technical issues, and improve the spnph user experience across devices.
• Communications: Sending you transactional notifications related to your account (such as deposit confirmations and withdrawal updates) and, where you have opted in, promotional communications about spnph offers and games.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, spnph must have a lawful basis for processing your personal data. The following legal bases apply to our processing activities:

• Contractual Necessity: Processing that is necessary to perform our obligations under the spnph Terms & Conditions — including account creation, payment processing, and game provision — is carried out on the basis of contractual necessity.
• Legal Obligation: Processing required for spnph to comply with its legal and regulatory obligations — including KYC verification, AML reporting, and age verification — is carried out on the basis of legal obligation.
• Legitimate Interest: Processing for fraud prevention, security monitoring, platform optimization, and responsible gaming monitoring is carried out on the basis of spnph's legitimate interests, balanced against the rights and interests of our players.
• Consent: Processing for marketing communications and the use of non-essential cookies is carried out on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

6.1 Service Providers and Partners

spnph shares personal data with carefully selected third-party service providers who assist in operating the platform. These include payment processors (GCash, Maya, GrabPay, QR Ph, BPI, BDO, Metrobank), identity verification providers, cloud infrastructure providers, customer support platform providers, and fraud detection and security vendors. All such providers are bound by data processing agreements that restrict their use of your data to the specific services they provide on spnph's behalf.

6.2 Game Content Providers

The spnph platform incorporates games from licensed third-party game studios and content providers. These providers may receive anonymized session data (such as game outcomes and bet amounts) as part of the game operation process, but they do not receive your personally identifiable information unless required for the operation of a specific game feature.

6.3 Regulatory and Law Enforcement Authorities

spnph may disclose personal data to the relevant Philippine regulatory bodies, law enforcement agencies, or courts where required to do so by law, by a court order, or where necessary to prevent, detect, or prosecute fraud, money laundering, or other criminal activity. Such disclosures are made strictly in accordance with applicable legal requirements and only to the extent necessary.

6.4 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of the spnph business, player personal data may be transferred to the acquiring entity as part of the transaction, subject to confidentiality obligations and continued compliance with this Privacy Policy.

7 Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device by a website you visit. They are widely used to make websites work efficiently, to remember your preferences, and to provide information to the site operators. The spnph platform uses cookies and similar technologies (such as local storage and session tokens) to operate key platform features and analyze usage.

7.2 Types of Cookies We Use

• Essential Cookies: Required for the spnph platform to function. These include session authentication tokens, CSRF protection tokens, and load-balancing cookies. These cookies cannot be disabled without significantly impairing platform functionality.
• Performance Cookies: Used to collect anonymized data about how players navigate and use the spnph platform, enabling us to identify slow-loading pages, errors, and areas for improvement. No personally identifiable information is collected via performance cookies.
• Preference Cookies: Used to remember your platform preferences, such as your chosen language, display settings, and responsible gaming limits, so that these are applied automatically on your next visit.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts. These cookies help protect your spnph account and maintain platform integrity.

7.3 Managing Cookies

You can manage or delete cookies at any time through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or receive a notification before a cookie is set. Please note that disabling essential cookies will prevent you from logging in and using the spnph platform. Disabling preference cookies means that your settings will not be saved between sessions.

8 Data Retention

spnph retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures. Where data must be retained beyond the standard period due to an active legal proceeding or regulatory investigation, it will be retained until that matter is resolved.

9 Data Security

spnph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and the spnph platform is protected using TLS 1.2 or higher encryption, preventing interception of data in transit.
• Encryption at Rest: Sensitive personal data stored on spnph servers — including identity documents and financial records — is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within spnph's internal systems is strictly limited on a need-to-know basis. Staff with access to player data undergo background verification and are bound by confidentiality obligations.
• Two-Factor Authentication: Player accounts on the spnph platform support two-factor authentication (2FA) as an additional layer of account security. Players are strongly encouraged to enable 2FA from their account security settings.
• Intrusion Detection and Monitoring: spnph operates continuous monitoring systems to detect and respond to unauthorized access attempts, unusual activity patterns, and potential data breaches in real time.
• Regular Security Assessments: The spnph platform undergoes regular security assessments and penetration testing conducted by qualified cybersecurity professionals to identify and remediate vulnerabilities before they can be exploited.

10 Your Data Rights

As a data subject under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by spnph:

• Right to Be Informed: You have the right to be informed about the manner in which your personal data is being collected and processed. This Privacy Policy fulfills that obligation.
• Right to Access: You have the right to obtain a copy of the personal data we hold about you, along with information about how it is being processed. Requests for data access will be fulfilled within 15 business days.
• Right to Correction: You have the right to request correction of any inaccurate, incomplete, or outdated personal data we hold. You may update basic account details directly through your spnph account profile. For corrections to KYC documents, please contact support.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to spnph's legal obligations to retain certain data under applicable law.
• Right to Object: You have the right to object to the processing of your personal data on the basis of legitimate interest or for direct marketing purposes. Where you object to marketing processing, we will stop processing your data for that purpose immediately.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to File a Complaint: If you believe that your data privacy rights have been violated, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. Contact details for the NPC are publicly available on the official NPC website.

To exercise any of these rights, please contact the spnph Data Protection Officer via the support team. We may need to verify your identity before processing your request to ensure that personal data is not disclosed to unauthorized parties.

11 Children and Minors

The spnph platform is strictly restricted to individuals who are at least twenty-one (21) years of age, in accordance with applicable Philippine gaming regulations. spnph does not knowingly collect personal data from individuals under the age of 21.

During the registration process, spnph collects date of birth information and may require identity document verification to confirm that a player meets the minimum age requirement. If spnph discovers or has reason to believe that a player account has been registered by an individual under the age of 21, that account will be immediately suspended, all pending transactions will be cancelled, and the matter may be referred to the relevant Philippine authorities.

If you are a parent or guardian and you believe that a minor in your care has registered a spnph account or provided personal data to spnph without your knowledge, please contact our support team immediately at [email protected] so that we can take appropriate action.

12 Cross-Border Data Transfers

spnph's primary data processing infrastructure is located within the Philippines or in jurisdictions that the National Privacy Commission recognizes as providing an adequate level of data protection. In cases where personal data is processed by third-party service providers located outside the Philippines — for example, cloud infrastructure or fraud detection providers operating in internationally recognized data centers — spnph ensures that appropriate safeguards are in place.

These safeguards include contractual clauses that bind the receiving party to data protection standards equivalent to those required under the Data Privacy Act of 2012, together with technical measures such as encryption to protect data during and after transfer. spnph does not transfer personal data to jurisdictions that lack adequate data protection frameworks without first implementing appropriate contractual and technical safeguards.

13 Updates to This Privacy Policy

spnph reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidelines, our data processing practices, or the features and services available on the spnph platform.

When material changes are made to this Privacy Policy, spnph will notify registered players by posting a prominent notice on the spnph platform and, where practicable, by sending a notification to the player's registered email address. The effective date of the updated policy will be displayed at the top of this page.

Your continued use of the spnph platform after the effective date of any revised Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Privacy Policy, you must stop using the spnph platform and may request account closure by contacting our support team.

14 Contact Us & Data Protection Officer

spnph has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and the terms of this Privacy Policy. If you have any questions, concerns, or requests relating to the collection, use, or protection of your personal data by spnph, you are welcome to contact us through the following channels:

• Support Email: [email protected]
• Live Chat: Available 24/7 directly through the spnph platform — average response time under 3 minutes
• Headquarters: Manila, Philippines (Philippine Standard Time, UTC+8)

When submitting a data rights request, please provide your registered spnph username and a clear description of your request so that our team can process it promptly. All data rights requests are acknowledged within 3 business days and resolved within 15 business days, in accordance with NPC guidelines.

If you are not satisfied with spnph's response to your data privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines.