spentime Privacy Policy

01 Introduction

spentime Casino ("spentime," "we," "us," "our") is committed to protecting the privacy and personal data of all players and visitors who use the spentime platform at spentime.org. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in connection with the spentime platform and related services.

This Privacy Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering an account on spentime or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, each of which is incorporated by reference.

02 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, spentime Casino is the personal information controller responsible for the personal data collected through the spentime platform. All data processing activities carried out by spentime are conducted in accordance with the principles of transparency, legitimate purpose, and proportionality as required by Philippine data privacy law.

If you have any questions about how spentime processes your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer using the contact details provided in Section 15 of this Privacy Policy.

03 Personal Data We Collect

spentime collects the following categories of personal data from players and platform visitors:

3.1 Identity and Contact Data

• Full legal name
• Date of birth
• Residential address (including barangay, city/municipality, province)
• Email address
• Mobile phone number
• Government-issued identification number (e.g., Philippine passport number, driver's license number, SSS/UMID number)
• Copies of identity documents submitted for KYC verification

3.2 Financial Data

• GCash or PayMaya account details (mobile number associated with the e-wallet)
• Bank account details for BPI, BDO, Metrobank, or InstaPay transactions
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment references
• Account balance information

3.3 Gaming Activity Data

• Game history, including games played, wager amounts, outcomes, and session durations
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

3.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Login timestamps and session activity logs
• Pages visited and features used on the spentime platform
• Cookie identifiers and similar tracking data (see Section 10)

3.5 Communications Data

• Records of communications between you and spentime support, including live chat transcripts, email correspondence, and support ticket history
• Survey responses and feedback submitted through the spentime platform

04 How We Collect Your Data

spentime collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the spentime platform, through cookies, server logs, and similar technologies.
• Third-party sources: Identity verification data from KYC service providers; payment confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay; fraud prevention data from third-party risk management services.

05 How We Use Your Personal Data

spentime uses your personal data for the following purposes:

spentime 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.

06 Legal Basis for Processing

spentime processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the spentime Terms & Conditions, including account management, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improvement of spentime services, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Sharing Your Personal Data

spentime 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party services engaged to verify your identity and documents in compliance with regulatory requirements.
• Fraud prevention and risk management services: Third-party providers that assist spentime in detecting and preventing fraudulent activity on the platform.
• Game software providers: Licensed game developers whose titles are available on the spentime platform, to the extent necessary to deliver gaming services.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory instruction.
• Professional advisers: Legal counsel, auditors, and accountants engaged by spentime, subject to professional confidentiality obligations.

08 Data Retention

spentime retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following 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 compliance with anti-money laundering regulations.
• Financial transaction data: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC and tax reporting requirements.
• Gaming activity data: Retained for a minimum of three (3) years following account closure.
• Communications data: Retained for a minimum of two (2) years from the date of the communication.
• Technical and usage data: Retained for a maximum of thirteen (13) months from collection, unless required for longer retention by law.

Upon expiry of the applicable retention period, spentime will securely delete or anonymize your personal data in accordance with its data disposal procedures.

09 Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the spentime platform.
• Encryption of sensitive data at rest, including financial account details and government ID information.
• Role-based access controls limiting access to personal data to authorized spentime personnel on a need-to-know basis.
• Regular security assessments and penetration testing of the spentime platform.
• Two-factor authentication options for player accounts.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

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

10 Cookies & Tracking Technologies

spentime uses cookies and similar tracking technologies on the spentime platform to enhance your experience, maintain your session, and analyze platform usage. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the operation of the spentime platform, including session management and security features. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the spentime platform, to help us improve our services. These cookies are only set with your consent.
• Marketing cookies: Used to deliver relevant promotional content to you based on your gaming activity and preferences. These cookies are only set with your explicit 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 spentime platform. Withdrawing consent for analytics or marketing cookies will not affect your ability to use core spentime services.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by spentime:

• Right to be informed: The right to be notified of how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data spentime 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 it is no longer necessary for the purposes for which it was collected, subject to spentime's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that spentime has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact spentime's Data Protection Officer at [email protected]. spentime will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. We may request proof of identity before processing your request.

12 Minors and Age Restriction

The spentime platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. spentime does not knowingly collect personal data from individuals under the age of 21. If spentime becomes aware that personal data has been collected from an individual under 21, such data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that your child has provided personal data to spentime, please contact us immediately at [email protected] so that we can take appropriate action.

13 International Data Transfers

spentime primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines — for example, to international game software providers or cloud infrastructure providers — spentime ensures that such transfers are carried out in compliance with the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers. This includes ensuring that recipient organizations provide an adequate level of data protection through contractual safeguards or other approved mechanisms.

14 Changes to This Privacy Policy

spentime reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email at least seven (7) days before the updated policy takes effect. The current version of this Privacy Policy is always available on this page, with the effective date clearly indicated at the top. Your continued use of the spentime platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy.

15 Contact Us & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or spentime's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: Privacy / Data Subject Request
• Response time: Within 15 business days for data subject requests; within 5 business days for general privacy enquiries

If you are not satisfied with spentime's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.