www.hawkplay Privacy Policy

1.1  This Privacy Policy is published by www.hawkplay (hereinafter "www.hawkplay," "we," "us," or "our"), the operator of the online gaming platform accessible at wwwhawkplay.club. This Policy describes our practices with respect to the collection, use, storage, disclosure, and protection of personal information relating to users of the Platform (hereinafter "you," "the Player," or "Data Subject").

1.2  This Privacy Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission of the Philippines ("NPC"). www.hawkplay is registered as a Personal Information Controller under the applicable NPC registration requirements.

1.3  This Policy applies to all personal information collected through: (a) your registration and use of an Account on the Platform; (b) your use of any game, betting, or interactive feature available on the Platform; (c) your communications with www.hawkplay Customer Support; (d) your participation in any promotional campaign or loyalty program operated by www.hawkplay; and (e) your browsing activity on the Platform whether or not you are a registered Account holder.

1.4  This Policy should be read alongside the www.hawkplay Terms & Conditions available at /terms-conditions. In the event of any inconsistency between this Policy and the Terms & Conditions on data privacy matters, this Privacy Policy shall prevail.

2.1  www.hawkplay collects only the personal information that is necessary for the lawful purposes described in this Policy. The categories of personal information we collect include the following:

Registration and Identity Information

When you create an Account on www.hawkplay, we collect: your full legal name as it appears on a valid government-issued Philippine identification document; your date of birth; your Philippine mobile number; your email address; and a username of your choosing. This information is required to create and operate your Account and to verify your eligibility to use the Platform.

Identity Verification (KYC) Documents

To comply with PAGCOR regulations and anti-money laundering requirements under Republic Act No. 9160 as amended, we collect copies of valid Philippine government-issued identification documents (such as a passport, PhilSys national ID, SSS/GSIS card, PRC license, voter's ID, or driver's license) and, where required, proof of residential address. KYC documentation is required before the withdrawal of funds from your Account.

Financial and Transaction Information

We collect records of all financial transactions conducted through your Account, including deposit amounts, payment method identifiers (such as your registered GCash or PayMaya mobile number or bank account details), withdrawal requests, and transaction timestamps. We do not store full payment card numbers or full bank account numbers — payment processing is handled by our licensed payment service providers.

Gaming Activity Data

We collect information about your activity on the Platform, including game sessions, bets placed, wager amounts, game outcomes, bonus usage, and login and logout timestamps. This data is used for account management, regulatory compliance, responsible gaming monitoring, and personalization of your experience.

Device and Technical Information

We automatically collect technical information when you access the Platform, including: your IP address; device type, model, and operating system; browser type and version; unique device identifiers; and session duration data. This information is used for security, fraud detection, and platform performance optimization.

Communications Data

If you contact Customer Support via live chat or any other available channel, we collect and retain records of those communications for quality assurance, dispute resolution, training, and regulatory compliance purposes.

3.1  www.hawkplay collects your personal information through the following methods:

• Directly from you: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawal requests, contacting Customer Support, or participating in promotions;
• Automatically through your use of the Platform: Device identifiers, IP addresses, session data, and gaming activity collected automatically as you use the Platform through cookies and similar tracking technologies (described further in Section 8);
• From payment service providers: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors when you make deposits or receive withdrawals;
• From identity verification services: Where we use third-party KYC service providers to verify the authenticity of identification documents, those providers may return verification outcomes and flagging information to us;
• From fraud detection and security tools: Risk scoring, device fingerprinting, and behavioral analytics data collected by licensed security services we use to protect the Platform and its users.

4.1  www.hawkplay processes your personal information only for specified, explicit, and legitimate purposes. The following table identifies our processing purposes and the legal basis for each under the Data Privacy Act of 2012:

4.2  Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Marketing communications consent can be withdrawn by contacting Customer Support or updating your communication preferences in your Account settings.

5.1  www.hawkplay does not sell, rent, or disclose your personal information to third parties for their own independent marketing or commercial purposes. We share personal information only in the following circumstances:

Service Providers and Data Processors

We engage trusted third-party service providers who process personal information on our behalf as Personal Information Processors under written data processing agreements that impose confidentiality obligations and security requirements consistent with the DPA. These providers include payment processors (GCash, PayMaya, BPI, BDO, Metrobank integrations), KYC identity verification services, cloud infrastructure providers, customer support platform operators, and fraud detection service providers. All processors are contractually prohibited from using your personal information for any purpose beyond the services they provide to www.hawkplay.

Regulatory and Legal Disclosure

www.hawkplay may disclose personal information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or any other Philippine government authority when required to do so by applicable law, court order, valid legal process, or regulatory directive. We will, where legally permissible, notify you of such disclosure.

Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of the assets of www.hawkplay, your personal information may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change in the controller of your personal information.

6.1  www.hawkplay retains your personal information for the period necessary to fulfill the purposes for which it was collected, including for the duration of your Account relationship with us and for such additional period as may be required by applicable Philippine law and PAGCOR regulations.

6.2  The following general retention periods apply:

• Account and identity information: Retained for the duration of the Account relationship and for a minimum of five (5) years after Account closure, as required by anti-money laundering regulations;
• KYC verification documents: Retained for a minimum of five (5) years after Account closure in compliance with the Anti-Money Laundering Act requirements;
• Financial transaction records: Retained for a minimum of five (5) years in compliance with BIR and AMLC record-keeping requirements;
• Gaming activity logs: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes;
• Customer support communications: Retained for a minimum of two (2) years;
• Technical and device logs: Retained for up to twelve (12) months for security and fraud detection purposes.

6.3  Upon expiry of the applicable retention period, personal information will be securely deleted, anonymized, or pseudonymized in a manner that prevents re-identification, in accordance with secure disposal standards consistent with the DPA.

7.1  www.hawkplay implements technical, organizational, and physical security measures designed to protect your personal information against unauthorized access, unauthorized disclosure, alteration, misuse, or destruction. These measures are reviewed and updated regularly to address evolving security threats.

7.2  Technical security measures implemented by www.hawkplay include:

• 256-bit SSL (Secure Sockets Layer) encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data fields at rest in our database infrastructure;
• Firewalls, intrusion detection systems, and network segmentation;
• Multi-factor authentication for administrative access to systems holding personal data;
• Regular security penetration testing and vulnerability assessments by qualified third-party security professionals;
• Automated monitoring systems that detect and alert on anomalous access patterns.

7.3  Data Breach Response. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, www.hawkplay will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected Data Subjects without undue delay, in accordance with the Data Privacy Act of 2012 and NPC Circular No. 16-03.

8.1  www.hawkplay uses cookies and similar tracking technologies (including session tokens, local storage, and pixel tags) to operate and improve the Platform, personalize your experience, maintain your session while logged in, and collect analytics data. This section explains what cookies we use and your choices regarding them.

Types of Cookies Used

• Strictly Necessary Cookies: These cookies are required for the Platform to function correctly. They include session authentication tokens that keep you logged in to your www.hawkplay Account, security cookies that help detect fraud, and load-balancing cookies. These cookies cannot be disabled without preventing you from using the Platform.
• Functional Cookies: These cookies remember your preferences (such as your preferred language settings) and enable personalized features. Disabling functional cookies may affect your user experience but will not prevent you from accessing core Platform features.
• Analytics Cookies: We use analytics tools to collect aggregated, non-identifiable data about how players use the Platform — which game categories are most visited, how long sessions typically last, and where users encounter difficulties. This data is used to improve the Platform. Where analytics cookies involve third-party services, those services process only aggregated or pseudonymized data.
• Security and Fraud Detection Cookies: These cookies help www.hawkplay identify unusual or suspicious activity patterns and protect players' accounts from unauthorized access.

8.2  You can manage cookie preferences through your browser's settings. Most modern browsers allow you to refuse cookies, delete existing cookies, or receive notification before a cookie is placed. Please note that restricting cookies may affect the functionality of the www.hawkplay Platform, including the ability to maintain a logged-in session.

9.1  Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal information held by www.hawkplay. You may exercise these rights by contacting our Data Privacy Officer (DPO) as described in Section 14.

9.2  www.hawkplay will respond to data subject rights requests within thirty (30) calendar days of receipt. Where a request is complex or numerous, we may extend this period by a further sixty (60) days and will notify you accordingly. There is no fee for submitting a data subject rights request, except where requests are manifestly unfounded or excessive.

10.1  The www.hawkplay Platform is strictly intended for adults aged twenty-one (21) years and above, as required by PAGCOR regulations applicable to online casino-style gaming in the Philippines. www.hawkplay does not knowingly collect personal information from any person under the age of 21.

10.2  Registration on the Platform requires entry of a date of birth, and KYC verification requires submission of a government-issued identification document confirming legal age. Accounts found to belong to persons under 21 years of age will be immediately suspended, all associated funds will be handled in accordance with PAGCOR guidelines, and any personal information collected will be securely deleted from our systems.

11.1  Some of the third-party service providers that process personal information on our behalf may be located outside of the Philippines. Where personal information is transferred to processors or sub-processors in other countries, www.hawkplay ensures that such transfers are conducted in compliance with the Data Privacy Act of 2012 and NPC guidelines on cross-border data flows.

11.2  Safeguards applied to cross-border transfers include: requiring recipient processors to comply with data protection standards substantially equivalent to those required under the DPA; incorporating standard contractual clauses approved by the NPC into data processing agreements; and conducting due diligence assessments of the data protection practices of recipient entities before transfer.

11.3  By using the Platform and consenting to this Privacy Policy, you consent to the transfer of your personal information to countries outside the Philippines where necessary for service delivery, subject to the safeguards described in this Section.

12.1  As an operator under PAGCOR's regulatory framework, www.hawkplay is subject to specific data collection, retention, and reporting obligations imposed by PAGCOR as a condition of operation. These obligations are non-negotiable and take precedence over individual consent in circumstances where they apply. They include:

• Collection and verification of player identity information (KYC) before permitting withdrawals;
• Retention of player registration, transaction, and gaming activity records for periods specified by PAGCOR;
• Reporting of suspicious transactions and activities to the Anti-Money Laundering Council (AMLC) as required by RA 9160 as amended;
• Maintaining player activity records sufficient to support PAGCOR audit and investigation requirements;
• Implementation of responsible gaming monitoring tools that require collection of gaming behavior data.

12.2  Where www.hawkplay processes personal information pursuant to PAGCOR regulatory requirements or other applicable Philippine law, such processing is carried out on the legal basis of legal obligation under the DPA and does not require additional consent from the Data Subject.

13.1  www.hawkplay reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, NPC guidance, or PAGCOR requirements. The "Effective Date" at the top of this Policy reflects the date of the most recent revision.

13.2  When material changes are made to this Privacy Policy, www.hawkplay will notify registered Account holders via the mobile number or email address registered to their Account and/or by displaying a prominent notice on the Platform for a minimum of thirty (30) days prior to the changes taking effect.

13.3  Your continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. The most current version of this Privacy Policy will always be available at /privacy-policy.

14.1  www.hawkplay has designated a Data Privacy Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and for responding to data subject rights requests and privacy-related inquiries.

14.2  To exercise any of the data subject rights described in Section 9, to report a suspected privacy breach, or to raise any concern about how www.hawkplay handles your personal information, please contact the DPO through the following channel:

14.3  If you are not satisfied with our response to your data subject rights request or privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available through official Philippine government information channels.