rionplay Privacy Policy

1. Introduction & Scope

rionplay ("rionplay," "we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you," "Player," or "Data Subject") who access and use the rionplay online gaming platform, website, mobile applications, and related services (collectively, the "Platform").

This Privacy Policy describes how rionplay collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform. It applies to all personal data collected through the rionplay website at rionplay.club, any rionplay mobile application, customer support interactions, and any other touchpoint where rionplay collects personal data from you.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission ("NPC"). By registering for or using the rionplay 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.

2. Personal Data We Collect

rionplay collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected and processed. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including barangay, city, province, and postal code)
• Email address and mobile phone number
• Username and encrypted password
• Nationality and country of residence

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (Philippine passport, driver's license, SSS/UMID card, or PhilSys National ID)
• Proof of address documents (utility bills, bank statements, or barangay certificates)
• Selfie or liveness verification images where required
• Source of funds declarations where required by applicable regulations

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts, dates, and payment methods used
• GCash or PayMaya account reference numbers (not full credentials)
• Bank account details where bank transfer is used (BPI, BDO, Metrobank)
• Bonus and promotional credit history
• Account balance history

2.4 Gaming Activity Data

• Game session logs including games played, wager amounts, and outcomes
• Betting history across all rionplay products (slots, live casino, sports betting, bingo, sabong)
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, cooling-off periods)

2.5 Technical & Device Data

• IP address and approximate geolocation data
• Device type, operating system, and browser information
• Session timestamps and duration
• Cookie identifiers and similar tracking data (see Section 7)

2.6 Communications Data

• Records of your communications with rionplay customer support via live chat, email, or other channels
• Feedback, complaints, and survey responses you submit to rionplay
• Marketing preferences and communication opt-in/opt-out records

3. How We Use Your Personal Data

rionplay uses the personal data we collect for the following purposes:

rionplay will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, rionplay processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and rionplay (i.e., the Terms & Conditions), including account management, payment processing, and providing gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations under Republic Act No. 9160, PAGCOR licensing requirements, and reporting obligations to the Anti-Money Laundering Council (AMLC) and National Privacy Commission (NPC).
• Legitimate Interests: Processing is necessary for rionplay's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improving our services, provided such interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities such as direct marketing communications and non-essential cookies, rionplay relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

rionplay does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

5.1 Service Providers

rionplay engages trusted third-party service providers who process personal data on our behalf under strict data processing agreements. These include payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and cybersecurity vendors. All service providers are contractually required to process personal data only on rionplay's instructions and to maintain appropriate security measures.

5.2 Regulatory & Law Enforcement Authorities

rionplay is required by Philippine law to disclose personal data to regulatory and law enforcement authorities in certain circumstances, including:

• Reporting of suspicious transactions to the Anti-Money Laundering Council (AMLC) under Republic Act No. 9160
• Compliance with PAGCOR licensing requirements and audit requests
• Responding to valid court orders, subpoenas, or lawful requests from Philippine law enforcement agencies
• Reporting data breaches to the National Privacy Commission (NPC) as required under the DPA

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of rionplay's business, your personal data may be transferred to the acquiring entity as part of that transaction. rionplay will notify you of any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those in this Privacy Policy.

5.4 With Your Consent

rionplay may share your personal data with other third parties where you have provided your explicit consent to such sharing.

6. Data Retention Periods

rionplay retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under Philippine law.
• KYC verification documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Financial and transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by AMLC regulations.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of each session for dispute resolution and responsible gaming monitoring purposes.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.
• Technical and device data: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, rionplay will securely delete or anonymize your personal data in accordance with our data disposal procedures, unless retention is required by a specific legal obligation or ongoing legal proceedings.

7. Cookies & Tracking Technologies

rionplay uses cookies and similar tracking technologies (such as web beacons and pixel tags) on the Platform to enhance your user experience, maintain session security, and analyze Platform usage. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session authentication, security tokens, and load balancing. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations to provide a personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the Platform, including pages visited, session duration, and navigation paths, to help rionplay improve the Platform.
• Marketing Cookies: Used with your consent to deliver relevant promotional content and measure the effectiveness of rionplay's marketing campaigns. These are only activated where you have provided consent.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the rionplay Platform. For detailed information about the specific cookies we use, please refer to our Cookie Notice available on the Platform.

8. Your Data Subject Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by rionplay:

To exercise any of the above rights, please contact rionplay's Data Protection Officer using the contact details in Section 13. rionplay will respond to all verified data subject requests within thirty (30) days of receipt, or within such extended period as permitted by the DPA where the request is complex or numerous.

Please note that certain rights are subject to limitations under the DPA. For example, the right to erasure does not apply where rionplay is required to retain data to comply with a legal obligation, such as AML record-keeping requirements.

9. Data Security Measures

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

• Encryption: All data transmitted between your device and the rionplay Platform is encrypted using Transport Layer Security (TLS) protocols. Sensitive data at rest, including financial records and KYC documents, is encrypted using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to rionplay personnel and authorized service providers who have a legitimate need to access it for their job functions. All access is logged and monitored.
• Two-Factor Authentication: rionplay offers two-factor authentication (2FA) for player accounts and requires it for all internal administrative access to systems containing personal data.
• Regular Security Audits: rionplay conducts regular internal and third-party security assessments, penetration testing, and vulnerability scans to identify and remediate security risks.
• Data Breach Response: rionplay maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, rionplay will notify the NPC within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay where required.

While rionplay takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your rionplay account credentials and for notifying us immediately if you suspect any unauthorized access to your account.

10. Children's Privacy

The rionplay Platform is strictly intended for adults aged 21 years and above. rionplay does not knowingly collect personal data from individuals under the age of 21. The minimum age requirement of 21 years is a mandatory legal requirement under Philippine gaming regulations.

If rionplay becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the personal data collected, and take appropriate steps to prevent further access. If you believe that a minor has registered on the rionplay Platform, please contact our support team immediately.

11. Third-Party Links

The rionplay Platform may contain links to third-party websites or services for informational purposes. rionplay is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to personal data collected by rionplay through the rionplay Platform. We encourage you to review the privacy policies of any third-party websites you visit.

12. Changes to This Privacy Policy

rionplay reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Privacy Policy, rionplay will notify registered players via email or through a prominent notice on the Platform at least fourteen (14) days before the changes take effect, where practicable. Your continued use of the rionplay Platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how rionplay protects your personal data.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by rionplay, please contact us through the following channels:

rionplay will acknowledge all data privacy requests within five (5) business days and provide a substantive response within thirty (30) days. For complex requests, we may extend this period by a further thirty (30) days with prior notice.

If you are not satisfied with rionplay's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.