orionplay Privacy Policy – How We Collect, Use, and Protect Your Personal Data

1. Introduction

orionplay ("we", "us", "our") is a PAGCOR-licensed online gaming platform operating in the Philippines. We are committed to protecting the privacy and personal data of all individuals who use the orionplay website, create an account, or otherwise interact with our services ("you", "Player", "Data Subject").

This Privacy Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC") of the Philippines. It describes how orionplay collects, uses, stores, shares, and protects personal data, as well as the rights available to you as a data subject under Philippine law.

This Policy should be read alongside the orionplay Terms & Conditions and Responsible Gaming Policy. If you have questions not addressed here, please contact our Data Protection Officer using the details in Section 13.

2. Personal Data We Collect

orionplay collects the following categories of personal data from Players:

2.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — 21+ requirement)
• Email address and mobile number
• Username and encrypted password
• Residential address in the Philippines

2.2 KYC Verification Data

• Scanned or photographed copy of a valid Philippine government-issued ID (SSS, UMID, Passport, Driver's License, or PhilSys National ID)
• Proof of payment method ownership (where required)
• Selfie or liveness verification image (where required)

2.3 Financial & Transaction Data

• GCash or PayMaya mobile number or account reference
• Bank account details for BPI, BDO, Metrobank, or UnionBank withdrawals
• Transaction history including deposits, withdrawals, and wager records

2.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Pages visited, session duration, and clickstream data
• Game history and betting patterns

2.5 Communications Data

• Content of support chat conversations and email correspondence
• Survey responses and feedback provided voluntarily

3. How We Collect Your Data

orionplay collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions on orionplay.
• Automatically: Through cookies, web beacons, and server logs when you access and browse the orionplay website. See Section 9 for details on cookies.
• From third parties: From identity verification service providers and payment processors engaged by orionplay to facilitate KYC and transactions, solely for the purposes described in this Policy.

4. Purposes of Processing Your Personal Data

orionplay processes your personal data for the following specific, legitimate purposes:

• Account management: To create, verify, maintain, and administer your orionplay account.
• Age verification: To confirm that you meet the minimum age requirement of 21 years under PAGCOR regulations.
• KYC compliance: To comply with PAGCOR licensing requirements and the Anti-Money Laundering Act (AMLA) as administered by the Anti-Money Laundering Council (AMLC) of the Philippines.
• Transaction processing: To process deposits via GCash, PayMaya, and bank transfers, and to process withdrawal requests.
• Customer support: To respond to your inquiries, resolve disputes, and assist with account issues.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, multiple accounts, and abuse of the orionplay platform.
• Responsible gaming: To monitor gameplay patterns for signs of problem gambling and to administer self-exclusion and limit requests.
• Marketing communications: To send you promotional offers and platform updates where you have given consent. You may withdraw consent at any time.
• Legal and regulatory obligations: To comply with court orders, PAGCOR directives, NPC requirements, and applicable Philippine laws.

5. Legal Basis for Processing

orionplay processes personal data under the following lawful bases as recognised by the Data Privacy Act of 2012:

• Consent: Where you have expressly agreed to processing, such as for marketing communications and optional profile features.
• Contractual necessity: Processing required to perform the contract between you and orionplay, including account management, gaming services, and payment processing.
• Legal obligation: Processing required by PAGCOR regulations, the AMLA, and other applicable Philippine laws.
• Legitimate interests: Processing necessary for orionplay's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your rights.

6. Data Sharing and Disclosure

orionplay does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your data only in the following limited circumstances:

• Service providers: With third-party providers engaged by orionplay to provide identity verification, payment processing, fraud detection, customer support platforms, and IT infrastructure services. These providers are contractually bound to process your data only on orionplay's instructions and in compliance with Philippine data privacy law.
• Regulatory and legal authorities: With PAGCOR, the AMLC, the NPC, law enforcement agencies, and other competent Philippine authorities where disclosure is required by law or by a valid regulatory directive.
• Corporate transactions: In the context of a merger, acquisition, or sale of assets, personal data may be transferred to successor entities, subject to the same privacy protections described in this Policy.

Any cross-border transfer of personal data outside the Philippines will only occur where the receiving country provides an adequate level of data protection, or where appropriate safeguards such as contractual clauses are in place, as required by the DPA.

7. Data Retention

orionplay retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer. Specific retention periods include:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and Philippine AMLA obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Support communications: Retained for up to three (3) years from the date of the last communication.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter for compliance documentation.

When personal data is no longer required, orionplay will securely delete or anonymise it in accordance with our data disposal procedures.

8. Security Measures

orionplay implements appropriate technical and organisational 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 orionplay's servers
• Encrypted storage of passwords using industry-standard hashing algorithms
• Role-based access controls ensuring that only authorised personnel access personal data
• Regular security audits and penetration testing of orionplay's systems
• Two-factor authentication available for all Player accounts
• Continuous monitoring for suspicious login activity and data access anomalies

While orionplay employs robust security measures, no online platform can guarantee absolute security. We encourage Players to use strong, unique passwords and to enable two-factor authentication on their orionplay accounts to maximise personal account security.

9. Cookies and Tracking Technologies

orionplay uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise your browser session, maintain your login state, and understand how Players interact with the website.

9.1 Types of Cookies Used

• Strictly necessary cookies: Required for the Platform to function, including session management and security cookies. These cannot be disabled.
• Analytical cookies: Used to collect anonymised data about how Players use the Platform, helping us improve navigation and game loading performance.
• Preference cookies: Used to remember your display settings and language preferences on the orionplay Platform.

9.2 Managing Cookies

You may configure your browser to refuse or delete non-essential cookies at any time. Please note that disabling certain cookies may affect the functionality of the orionplay Platform, including your ability to stay logged in.

10. Your Data Subject Rights

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

• Right to be informed: The right to know how your personal data is being collected and processed.
• Right of access: The right to request a copy of the personal data orionplay holds about you.
• Right to correction: 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 our legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to object: The right to object to processing of your personal data, particularly for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days in accordance with NPC guidelines.

11. Minors and Age Restriction

orionplay does not knowingly collect personal data from individuals under the age of 21. Access to and use of the orionplay Platform is strictly prohibited for persons under 21 years of age, as required by PAGCOR regulations. If orionplay discovers that personal data has been collected from a person under 21, the relevant account will be immediately closed and all collected data will be securely deleted.

Parents and guardians who believe that a minor may have registered on orionplay are strongly encouraged to contact our support team immediately at [email protected] so the matter can be investigated and resolved promptly.

12. Changes to This Privacy Policy

orionplay reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine laws, or PAGCOR regulatory requirements. When material changes are made, orionplay will notify registered Players via the email address on file at least fourteen (14) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. Your continued use of the orionplay Platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

13. Contact Our Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or orionplay's data practices, please contact our designated Data Protection Officer through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 via the orionplay website — for urgent data security concerns, live chat is the fastest route
• Response time: Email inquiries are addressed within 4 business hours; formal data subject requests are processed within 30 days

You also have the right to escalate unresolved privacy concerns directly to the National Privacy Commission of the Philippines (privacy.gov.ph) at any time.