okpaly Privacy Policy

1. Who We Are

1.1 okpaly ("okpaly," "we," "us," "our") operates the online gaming platform accessible at okpaly.net. okpaly is the data controller responsible for the personal data you provide when using our Platform.

1.2 okpaly operates in compliance with Philippine gaming regulations and the Philippine Data Privacy Act of 2012 (RA 10173). Our platform is designed specifically for Filipino players and is subject to the jurisdiction of Philippine law.

1.3 If you have any questions about how okpaly handles your personal data, you may contact our Data Protection Officer via live chat on the Platform or by email at [email protected].

2. Personal Data We Collect

2.1 okpaly collects personal data from you in the following ways: directly from you when you register an account or use the Platform; automatically through your use of the Platform; and from third-party service providers such as payment processors and identity verification services.

2.2 The categories of personal data we collect include:

Category	Examples	Source
Identity Data	Full name, date of birth, government-issued ID number, selfie/photo for KYC	Provided by you at registration or KYC
Contact Data	Email address, mobile number, home address	Provided by you at registration
Financial Data	GCash number, Maya account, bank account details (for withdrawals), transaction history	Provided by you; received from payment processors
Technical Data	IP address, device type, browser type, operating system, session duration	Collected automatically via cookies and server logs
Usage Data	Games played, bets placed, login history, pages visited, feature interactions	Collected automatically via Platform analytics
Communications Data	Live chat transcripts, support ticket content, email correspondence	Generated when you contact our support team
Marketing Data	Communication preferences, promotion opt-in/opt-out status	Provided by you; inferred from usage

2.3 okpaly does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required for responsible gaming purposes (e.g., self-exclusion requests) and only with your explicit consent.

3. How We Use Your Personal Data

3.1 okpaly uses your personal data for the following purposes:

• To create and manage your okpaly account and verify your identity;
• To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Philippine law;
• To provide customer support and respond to your enquiries;
• To personalise your gaming experience and recommend relevant games;
• To send you transactional notifications such as deposit confirmations and withdrawal updates;
• To send you promotional communications where you have opted in to receive them;
• To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct;
• To monitor and enforce responsible gaming obligations, including age verification and self-exclusion;
• To analyse Platform usage and improve our services, games, and user experience;
• To comply with applicable Philippine laws, regulations, and PAGCOR requirements.

3.2 okpaly will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

4. Legal Basis for Processing

4.1 Under the Philippine Data Privacy Act of 2012, okpaly processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms and Conditions you agreed to at registration, including account management and payment processing.
• Legal obligation: Processing required to comply with Philippine law, including AML regulations, PAGCOR licensing requirements, and tax obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and improving our services, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and optional personalisation features, where you have given explicit consent. You may withdraw consent at any time.

5. Sharing Your Personal Data

5.1 okpaly does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following limited circumstances:

• Payment processors: GCash, PayMaya (Maya), and Philippine bank partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive the minimum data necessary to process your transactions.
• Identity verification providers: Third-party KYC service providers who verify your identity documents and age as required by Philippine gaming regulations.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law.
• Technology service providers: Cloud hosting, analytics, and customer support platform providers who process data on our behalf under strict data processing agreements.
• Law enforcement: Where required by a valid court order, subpoena, or other legal process under Philippine law.

5.2 All third parties with whom okpaly shares personal data are required to handle that data in accordance with applicable privacy laws and are prohibited from using it for any purpose other than the specific service they provide to okpaly.

6. Cookies and Tracking Technologies

6.1 okpaly uses cookies, web beacons, pixel tags, and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you and remember your preferences.

6.2 We use the following types of cookies:

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game display options, and notification preferences.
• Analytics cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymised where possible.
• Marketing cookies: Used to deliver relevant promotions and offers within the Platform. These are only set if you have opted in to marketing communications.

6.3 You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the okpaly Platform.

7. Data Retention

7.1 okpaly retains your personal data for as long as your account is active and for a period thereafter as required by applicable Philippine law and regulatory obligations.

7.2 Specifically, transaction records and KYC documentation are retained for a minimum of five (5) years following the closure of your account, in accordance with Philippine AML regulations and PAGCOR requirements.

7.3 Where you have requested deletion of your personal data and there is no legal obligation to retain it, okpaly will securely delete or anonymise your data within thirty (30) days of the request being verified.

7.4 Anonymised and aggregated data that cannot be used to identify you may be retained indefinitely for statistical and analytical purposes.

8. Data Security

8.1 okpaly implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encrypted storage of sensitive personal and financial data at rest;
• Strict role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of our Platform infrastructure;
• Two-factor authentication (2FA) available for all player accounts;
• Automated fraud detection and suspicious activity monitoring systems.

8.2 While okpaly takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights, okpaly will notify you and the National Privacy Commission (NPC) in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Data Rights

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

• Right to be informed: The right to know what personal data okpaly holds about you and how it is being used.
• Right of access: The right to request a copy of the personal data okpaly 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 where there is no legal basis for continued processing.
• Right to object: The right to object to processing of your personal data for direct marketing or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

9.2 To exercise any of the above rights, please contact our Data Protection Officer via live chat on the Platform or by email at [email protected]. We will respond to all verified requests within fifteen (15) business days.

10. Children and Minors

10.1 okpaly employs age verification procedures at registration and during KYC to ensure compliance with the 21+ age requirement under Philippine gaming law. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

11. International Data Transfers

11.1 okpaly primarily stores and processes your personal data within the Philippines. Where data is transferred to service providers located outside the Philippines, okpaly ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012.

11.2 Such safeguards include contractual data processing agreements that require overseas recipients to apply data protection standards equivalent to those required under Philippine law.

12. Updates to This Privacy Policy

12.1 okpaly reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The most current version will always be published at okpaly.net/privacy-policy with the effective date clearly indicated at the top of the page.

12.2 Where changes are material, okpaly will notify registered players via email or an in-platform notification prior to the changes taking effect. Continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

13. Contact Us and Complaints

13.1 If you have any questions, concerns, or complaints about this Privacy Policy or the way okpaly handles your personal data, please contact our Data Protection Officer:

13.2 If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the government body responsible for enforcing the Data Privacy Act of 2012 and can be reached through its official government channels.

13.3 okpaly takes all privacy complaints seriously and will investigate every concern raised in good faith. We are committed to resolving data privacy issues promptly and transparently for all Filipino players on our platform.