Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") describes how pirya collects, uses, stores, discloses, and otherwise processes the personal data of individuals who access or use pirya's online gaming platform, website at pirya.cam, and related mobile applications (collectively, the "Services").

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), the issuances of the National Privacy Commission (NPC), and the data protection requirements imposed on pirya as a PAGCOR-licensed gaming operator.

By registering a pirya account or using any part of our Services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of pirya's Services immediately and contact support to arrange account closure.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, the personal information controller responsible for your data is:

• Entity: pirya (operating under its PAGCOR license)
• Website: pirya.cam
• Jurisdiction: Republic of the Philippines
• Support Email: [email protected]

pirya has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. The DPO can be contacted via the email address above, clearly marked for the attention of the Data Protection Officer.

3. Personal Data We Collect

pirya collects the following categories of personal data, depending on how you interact with our Services:

pirya does not intentionally collect sensitive personal information as defined under the Data Privacy Act — such as health data, religious belief, or political affiliations — unless expressly required for a specific responsible gaming or regulatory purpose, and only with your explicit consent where applicable.

4. How We Collect Your Data

pirya collects personal data through the following channels:

4.1 Data You Provide Directly

When you register a pirya account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions, you provide personal data directly to pirya. This is the primary source of identity, contact, and financial data.

4.2 Data Collected Automatically

When you access pirya's website or application, certain technical data is collected automatically by our systems. This includes your IP address, device identifiers, browser characteristics, session timing, pages visited, game interactions, and error logs. This data is collected to maintain platform security, detect fraud, and optimize the player experience.

4.3 Data from Third-Party Payment Providers

When you transact via GCash, Maya, BPI, BDO, Metrobank, or other payment providers integrated with pirya, we may receive confirmation data from those providers — such as transaction reference numbers, mobile wallet identifiers, and payment status — for the purpose of crediting your pirya Balance or processing your withdrawal. pirya does not receive or store your full banking credentials or GCash/Maya PIN.

4.4 Data from Cookies and Analytics Tools

pirya uses cookies and similar tracking technologies on its website. Full details of the cookies we use and how to manage them are provided in Section 9 of this Policy.

5. Legal Basis for Processing

pirya processes your personal data on one or more of the following legal bases as recognized under the Data Privacy Act of 2012:

• Contract Performance: Processing necessary to fulfill pirya's contractual obligations to you as a registered player — including account management, game provision, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR licensing requirements, Anti-Money Laundering Act obligations, National Privacy Commission rules, and other applicable Philippine law.
• Legitimate Interests: Processing necessary for pirya's legitimate business interests, including fraud prevention, security monitoring, responsible gaming programme administration, and platform improvement — provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where pirya relies on your consent as the legal basis for a specific processing activity (such as sending promotional communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

pirya uses your personal data for the following purposes:

• Account Registration and Management: Creating, maintaining, and securing your pirya player account, including password reset, session management, and VIP tier tracking.
• Identity and Age Verification: Conducting KYC verification as required by PAGCOR to confirm your identity and eligibility to use pirya's Services, including verification that you are aged 21 or above.
• Payment Processing: Processing deposits and withdrawals in Philippine Peso via GCash, Maya, and integrated Philippine bank payment channels.
• Game Provision: Delivering the gaming content you access on pirya, maintaining game logs, and resolving disputes relating to game outcomes.
• Fraud Prevention and Security: Detecting, investigating, and preventing unauthorized access, fraudulent transactions, money laundering, bonus abuse, and other prohibited conduct.
• Regulatory Compliance: Fulfilling reporting obligations to PAGCOR and, where required by law, to the Anti-Money Laundering Council (AMLC) and other competent Philippine authorities.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling indicators and administering responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods.
• Customer Support: Responding to queries, complaints, and disputes submitted through pirya's support channels.
• Marketing and Promotions: Sending promotional communications about pirya bonuses, new games, and special offers — where you have consented to receive such communications.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve pirya's platform, game selection, and user experience.

7. Sharing Your Personal Data

pirya does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances:

7.1 Service Providers

pirya shares personal data with third-party service providers who process data on pirya's behalf under written data processing agreements that prohibit independent use or further disclosure. These include:

• KYC and identity verification service providers
• Payment processors and Philippine e-wallet providers (GCash, Maya)
• Game software studios and content providers
• Cloud hosting and infrastructure providers
• Fraud detection and cybersecurity service providers
• Customer support platform operators

7.2 Regulatory Disclosure

pirya is required by its PAGCOR license and applicable Philippine law to disclose certain player data to regulatory and law enforcement authorities upon lawful request. This includes disclosures to PAGCOR in the course of regulatory audits and reports to the AMLC under the Anti-Money Laundering Act. pirya will notify affected players of such disclosures where legally permitted to do so.

7.3 Business Transfers

In the event that pirya undergoes a merger, acquisition, or transfer of all or part of its business assets, personal data held by pirya may be transferred to the successor entity as part of that transaction, subject to the same data protection obligations set out in this Policy.

8. International Data Transfers

Some of pirya's service providers — including cloud infrastructure providers and certain game studios — may be located outside the Philippines. Where personal data is transferred outside the Philippines, pirya ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards include:

• Contractual data transfer clauses incorporating NPC-recognized data protection standards
• Transfers only to jurisdictions with adequate data protection frameworks as recognized by the NPC
• Technical and organizational security measures equivalent to those applied within the Philippines

A list of the third-party countries to which pirya transfers personal data in the course of its operations is available upon request from pirya's Data Protection Officer.

9. Cookies & Tracking Technologies

9.1 What Cookies Are

Cookies are small data files placed on your device when you visit pirya's website. They serve several functions: keeping you logged in during a session, remembering your display preferences, and collecting anonymised analytics data that helps pirya improve the platform.

9.2 Types of Cookies Used

• Strictly Necessary Cookies: Required for core platform functions including authentication, session security, and load balancing. These cookies cannot be disabled without impairing your ability to use pirya's Services.
• Functional Cookies: Remember your preferences such as language settings, lobby filters, and display options to provide a more personalized experience on pirya.
• Analytics Cookies: Collect anonymised information about how players use pirya's platform — which pages are visited most frequently, how long sessions last, and where users encounter errors. This data is used to improve pirya's platform and is not linked to individual player identities.
• Security Cookies: Support pirya's fraud detection and security monitoring systems by identifying unusual patterns in platform access behavior.

9.3 Managing Cookies

You can manage cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Note that disabling strictly necessary cookies will prevent you from logging in or using pirya's core Services. For detailed browser-specific cookie management instructions, refer to your browser's help documentation.

10. Data Retention

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

• Account Data: Retained for the duration of your active pirya account and for a minimum of five (5) years following account closure, as required by PAGCOR and AML regulations.
• KYC Documents: Retained for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the Revised Implementing Rules and Regulations of the Anti-Money Laundering Act.
• Financial Transaction Records: Retained for a minimum of five (5) years following each transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Gaming Logs: Retained for three (3) years to support dispute resolution and regulatory audit obligations.
• Support Communications: Retained for two (2) years following the resolution of the relevant query or complaint.
• Marketing Consent Records: Retained for three (3) years following the withdrawal of consent, to demonstrate compliance with consent requirements.

Upon expiry of applicable retention periods, pirya will securely delete or anonymise personal data so that it can no longer be associated with an identifiable individual.

11. Data Security

pirya implements a layered security architecture to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and pirya's servers
• AES-256 encryption for sensitive data at rest, including KYC documents and financial data
• Strict role-based access controls ensuring that employee access to personal data is limited to what is necessary for their specific job function
• Multi-factor authentication requirements for all pirya system administrators
• Regular penetration testing and vulnerability assessments by independent security professionals
• 24/7 automated intrusion detection and anomaly monitoring
• Incident response procedures designed to contain and remediate data breaches within the timeframes required by the NPC

In the event of a personal data breach that is likely to result in harm to affected data subjects, pirya will notify the National Privacy Commission and affected players within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03.

12. Your Data Subject Rights

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

To exercise any of these rights, please contact pirya's Data Protection Officer at [email protected] with "Data Subject Rights Request" in the subject line. pirya will respond to valid requests within fifteen (15) business days of receipt, or within the timeframe required by applicable NPC guidelines.

pirya may need to verify your identity before processing a rights request. Where a request is complex or numerous, pirya may extend the response period by a further fifteen (15) business days, and will notify you of the extension and the reason for it within the initial fifteen-day period.

13. Children's Privacy

pirya's Services are strictly for individuals aged 21 years and above in accordance with PAGCOR requirements. pirya does not knowingly collect or process personal data from any individual below the age of 21.

If pirya discovers, through age verification processes or other means, that personal data has been collected from an individual below the age of 21, pirya will immediately close the relevant account, forfeit any associated balance in accordance with its Terms and Conditions, and securely delete the personal data collected, except where retention is required by applicable law for fraud investigation or regulatory reporting purposes.

If you believe that a person under 21 has registered a pirya account, please report this to [email protected] immediately.

14. Responsible Gaming & Data Processing

As part of its PAGCOR-mandated responsible gaming programme, pirya processes gaming data — including session duration, frequency, bet sizes, and loss patterns — to identify indicators of potentially problematic gambling behavior. This processing is carried out on the legal basis of legitimate interests (protecting player welfare) and legal obligation (PAGCOR responsible gaming requirements).

Where pirya's monitoring systems flag a player's activity for review, a member of the responsible gaming team may conduct a welfare check and may apply responsible gaming interventions such as temporary deposit limits or a cooling-off period. Players are notified when such interventions are applied.

Responsible gaming data is not shared with third parties except where required by PAGCOR reporting obligations. It is retained for a minimum of three (3) years to support programme effectiveness analysis and regulatory audit.

Players may also request that pirya apply voluntary self-exclusion. Details of pirya's self-exclusion process and other responsible gaming tools are available on the Responsible Gaming page.

15. Amendments to This Policy

pirya reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, NPC guidelines, PAGCOR requirements, or pirya's data processing practices. When material changes are made, pirya will notify registered players via email to their registered address or through a prominent in-platform notification, with a minimum notice period of fourteen (14) days before the revised Policy takes effect — except where immediate amendment is required by law or regulatory instruction.

The effective date at the top of this Policy will always reflect the date of the most recent revision. We encourage players to review this Policy periodically. Continued use of pirya's Services after the effective date of a revised Policy constitutes your acceptance of the changes.

16. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by pirya, please contact:

• Data Protection Officer, pirya
• Email: [email protected] — mark correspondence "Attn: Data Protection Officer"
• Response Time: Within 15 business days for standard queries; 72 hours for breach-related notifications
• Support Hours: 24 hours a day, 7 days a week

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe pirya has violated the Data Privacy Act. The NPC can be reached through its official Philippine government channels.

This Privacy Policy is effective as of 1 January 2026 and supersedes all prior privacy policies issued by pirya.