3taya Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by 3taya Online Gaming Corporation ("3taya," "we," "us," or "our") and applies to all personal information collected from individuals ("you," "your," or "Data Subject") who access, register for, or use the 3taya website, mobile applications, and associated online gaming and sports betting services (collectively, the "Platform").

We are committed to protecting your privacy and handling your personal information with transparency, integrity, and responsibility. This Policy describes the types of personal data we collect, the purposes for which we use it, the parties with whom we may share it, and the rights you have with respect to your personal information. We strongly encourage you to read this Policy in full so you are fully informed about our data practices.

By registering for a 3taya account, accessing the Platform, or providing us with your personal information in any manner, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with any part of this Policy, you should not use the 3taya Platform.

This Policy is to be read alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your relationship with 3taya. In the event of any conflict between this Policy and the Terms & Conditions regarding privacy matters, this Policy shall prevail.

2. Information We Collect

3taya collects personal information about you from a variety of sources and through a variety of means in the course of providing the Platform and our services. The categories of personal information we collect are detailed below.

2.1 Information You Provide Directly

When you register for a 3taya account, interact with our customer support team, or use features of the Platform, you may provide us with the following personal information:

• Identity Information: Your full legal name, date of birth, gender, and nationality.
• Contact Information: Your residential address (including barangay, city, province, and postal code), email address, and Philippine mobile phone number.
• Government Identification: Copies of government-issued identification documents such as a Philippine passport, driver's license, UMID card, SSS card, or PhilHealth ID, provided for identity verification purposes.
• Financial Information: Payment method details including GCash or Maya account numbers, bank account details, credit or debit card numbers (stored in tokenized form only), and transaction history relating to deposits and withdrawals on the Platform.
• Account Credentials: Your chosen username and encrypted password. We do not store your password in plaintext.
• Communications: Records of your communications with our customer support team, including live chat transcripts, emails, and any feedback or complaints submitted through the Platform.
• Responsible Gaming Information: Any voluntary information you provide in connection with responsible gaming tools, including self-exclusion requests, deposit limit settings, and cooling-off period requests.

2.2 Information Collected Automatically

When you access and use the 3taya Platform, we automatically collect certain technical and behavioral information through cookies, log files, and similar tracking technologies:

• Device Information: Your device type, operating system, browser type and version, device identifiers, and mobile network information.
• Log Data: Your IP address, access times and dates, pages and features accessed, game sessions, bet history, and referring URLs.
• Location Data: General geographic location derived from your IP address, and in some cases precise geolocation data obtained from your device (with your permission) for regulatory compliance purposes, including verification that you are accessing the Platform from within the Philippines as required by PAGCOR licensing conditions.
• Usage Data: Information about how you use the Platform, including games played, betting patterns, session duration, and promotional offers viewed or redeemed.

2.3 Information from Third Parties

3taya may receive personal information about you from third parties in certain circumstances, including:

• Identity verification and Know Your Customer (KYC) service providers who assist in verifying the accuracy of the information you provide during registration.
• Payment processors and financial institutions that facilitate your deposits and withdrawals.
• Fraud prevention agencies and credit reference agencies used for risk assessment purposes.
• PAGCOR and other Philippine regulatory authorities where disclosure is required or permitted by law.
• The Anti-Money Laundering Council (AMLC) of the Philippines in connection with our AML compliance obligations.

3. How We Use Your Information

3taya uses the personal information we collect for the following purposes:

Purpose	Description
Account Management	Creating, verifying, maintaining, and managing your 3taya account, including processing your registration, authenticating your identity at login, and managing account settings.
Service Delivery	Providing access to the games, sportsbook, and other features of the 3taya Platform; processing deposits and withdrawals; settling wagers; and delivering promotional rewards.
Identity Verification (KYC)	Verifying your identity, age (21+), and eligibility to use the Platform as required by PAGCOR licensing conditions and applicable Philippine law.
Regulatory Compliance	Meeting our obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act, the Data Privacy Act, and all other applicable Philippine laws and regulations.
Fraud Prevention	Detecting, investigating, and preventing fraudulent transactions, multiple account creation, bonus abuse, money laundering, and other prohibited activities.
Customer Support	Responding to your inquiries, complaints, and feedback; resolving disputes; and improving our customer service delivery.
Responsible Gaming	Administering responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods; monitoring for signs of problem gambling; and delivering responsible gaming communications.
Platform Improvement	Analyzing usage patterns, game preferences, and technical performance to improve the Platform's features, stability, and user experience.
Marketing Communications	Sending you promotional offers, bonuses, and updates about 3taya, subject to your communication preferences and applicable opt-out rights.
Legal Proceedings	Establishing, exercising, or defending legal claims in connection with disputes arising from your use of the Platform.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 3taya processes your personal information on one or more of the following lawful bases:

• Consent: Where you have provided your freely given, specific, informed, and unambiguous consent to the processing of your personal data, such as when you register for a 3taya account and agree to this Privacy Policy, or when you opt in to marketing communications.
• Contractual Necessity: Where processing is necessary for the performance of our contract with you (as set out in the Terms & Conditions), including providing access to the Platform, processing transactions, and managing your account.
• Legal Obligation: Where processing is required for 3taya to comply with applicable Philippine law, including PAGCOR licensing requirements, AML obligations under Republic Act No. 9160, KYC requirements, and data retention obligations.
• Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party), provided those interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include fraud prevention, platform security, improving our services, and defending legal claims.

5. Disclosure to Third Parties

3taya does not sell, rent, or trade your personal information to third parties for their own marketing or commercial purposes. We may, however, share your personal information with the following categories of recipients in the circumstances described below:

5.1 Service Providers and Processors

We share personal information with trusted third-party service providers who assist us in operating the Platform and delivering our services. These include:

• Payment processors and e-wallet providers (such as GCash, Maya, BPI, BDO, Metrobank, and UnionBank) for processing deposits and withdrawals.
• Identity verification and KYC service providers for verifying player identity and age.
• Game content providers (such as JILI, Pragmatic Play, PG Soft, and Evolution Gaming) who supply the games available on the Platform.
• Cloud computing and data hosting providers who maintain the technical infrastructure of the Platform.
• Customer support and communication platform providers.
• Fraud detection and cybersecurity service providers.
• Analytics providers who help us understand how the Platform is used.

All third-party service providers are required to process your personal information only for the purposes for which it was shared, in accordance with our instructions, and subject to appropriate data protection agreements that meet the standards required by the Data Privacy Act.

5.2 Regulatory and Law Enforcement Authorities

3taya may be required to disclose your personal information to Philippine regulatory and law enforcement authorities, including but not limited to:

• PAGCOR, in connection with its regulatory oversight and licensing functions.
• The Anti-Money Laundering Council (AMLC), for reporting covered transactions and suspicious transactions as required by the Anti-Money Laundering Act.
• The National Privacy Commission (NPC), in connection with its regulatory and enforcement functions under the Data Privacy Act.
• Philippine courts and law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other lawful legal process.
• Other government agencies, where required by applicable Philippine law or regulation.

Where legally permitted, 3taya will notify you of any such disclosure request before complying. However, we may be legally prohibited from providing such notice in certain circumstances, including in connection with AML reporting obligations.

5.3 Business Transfers

In the event that 3taya undergoes a merger, acquisition, corporate restructuring, or sale of all or a substantial portion of its assets, your personal information may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and any material changes to how your personal information is processed as a result of such a transaction.

6. Cookies and Tracking Technologies

3taya uses cookies, web beacons, pixels, and similar tracking technologies on the Platform. Cookies are small text files stored on your device that help us recognize you when you return to the Platform, remember your preferences, maintain your session, and analyze how the Platform is used.

6.1 Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the Platform to function properly, including maintaining your login session, remembering your account preferences, and enabling core gaming and transactional functionality. These cookies cannot be disabled without significantly impairing the Platform's usability.
• Performance and Analytics Cookies: These cookies collect information about how users interact with the Platform, which pages are visited most frequently, and whether users encounter error messages. This information is used to improve the Platform's performance and user experience. All data collected through these cookies is aggregated and anonymized.
• Functionality Cookies: These cookies allow the Platform to remember choices you make (such as your preferred language, game lobby view, or responsible gaming settings) to provide a more personalized experience.
• Targeting and Marketing Cookies: These cookies track your visits to the Platform and, in some cases, to third-party websites, to deliver promotional content and offers that are relevant to your interests. You may opt out of these cookies through the cookie preference center on the Platform.

6.2 Managing Cookies

You can manage your cookie preferences through the cookie settings center available in the Platform's footer, or through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling certain categories of cookies may affect the functionality of the Platform. For more detailed information on managing cookies in specific browsers, please consult your browser's help documentation.

7. Data Security

3taya implements a comprehensive set of technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial information and government ID copies stored in our systems.
• Strict access controls, role-based permissions, and multi-factor authentication for 3taya staff who handle personal data.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent cybersecurity specialists.
• Intrusion detection and prevention systems monitoring the Platform infrastructure in real time.
• Secure, geographically redundant data centers with physical security controls.
• Regular staff training on data security and privacy best practices.

While we maintain robust security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your personal information, and we encourage you to take your own precautions, including using a strong, unique password for your 3taya account and never sharing your login credentials with anyone.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 3taya will notify you and the National Privacy Commission within the timeframes required by the Data Privacy Act and its implementing rules.

8. Data Retention

3taya retains your personal information for as long as is necessary to fulfill the purposes for which it was collected, or as required or permitted by applicable Philippine law and regulation. The following retention periods apply as general guidelines:

• Account Information: For the duration of your active account relationship with 3taya, plus a period of five (5) years following the closure of your account, to comply with PAGCOR licensing requirements and applicable statutory limitation periods.
• Transaction Records: A minimum of five (5) years from the date of the transaction, in compliance with the Anti-Money Laundering Act and AMLC regulations.
• Identity Verification Documents: For the duration of your account relationship plus five (5) years following account closure, as required by PAGCOR KYC requirements.
• Customer Support Communications: Two (2) years from the date of the communication, unless the communication relates to an unresolved dispute or legal claim, in which case it will be retained until the matter is fully resolved.
• Marketing Preferences: Until you withdraw your consent to marketing communications or close your account, whichever occurs first.
• Cookies and Analytical Data: As specified in our cookie settings, typically ranging from session-based (deleted when you close your browser) to up to two (2) years for persistent analytics cookies.

Upon expiry of the applicable retention period, 3taya will securely delete or anonymize your personal information in a manner that prevents its reconstruction or recovery.

9. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to the personal information that 3taya holds about you:

• Right to Be Informed: The right to be informed about how your personal information is being collected and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal information 3taya holds about you, together with information about how it is being used.
• Right to Rectification: The right to request that we correct any personal information about you that is inaccurate, incomplete, or outdated. You may update certain account information directly through your 3taya account settings.
• Right to Erasure: The right to request deletion of your personal information in certain circumstances, including where the information is no longer necessary for the purposes for which it was collected and there is no overriding legal obligation to retain it.
• Right to Object: The right to object to the processing of your personal information for direct marketing purposes and, in certain circumstances, to other types of processing based on legitimate interests.
• Right to Data Portability: The right to receive a copy of your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Damages: The right to be compensated for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal information.
• Right to File a Complaint: The right to file a complaint with the National Privacy Commission if you believe that 3taya has violated your data privacy rights.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 12 of this Policy. We will respond to all valid requests within thirty (30) days of receipt. Please note that certain rights are subject to limitations and exceptions under the Data Privacy Act, and we may be required to retain certain information notwithstanding a deletion request due to regulatory or legal obligations.

10. Children's Privacy

The 3taya Platform is strictly intended for individuals who are 21 years of age or older, consistent with PAGCOR regulations governing the minimum age for online gambling in the Philippines. 3taya does not knowingly collect, process, or retain personal information from individuals under the age of 21.

If we become aware that we have inadvertently collected personal information from a person under the age of 21, we will take immediate steps to delete that information from our systems, close the associated account, and reverse any transactions processed through that account. Parents or guardians who believe that a minor may have registered for a 3taya account should contact us immediately at the contact details provided in Section 12.

11. Changes to This Privacy Policy

3taya reserves the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify you by posting a prominent notice on the Platform and, where required by the Data Privacy Act, by sending you a direct notification to your registered email address.

The "Last Updated" date at the top of this Policy indicates when the most recent version was published. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information. Your continued use of the Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy.

12. Contact and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the manner in which 3taya processes your personal information, please contact our Data Protection Officer:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the 3taya Platform
• Response Time: All data privacy requests are acknowledged within 5 business days and resolved within 30 days

If you are not satisfied with our response to your privacy concern, or if you believe that 3taya has violated your rights under the Data Privacy Act, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the Philippine government authority responsible for enforcing the Data Privacy Act and adjudicating complaints from data subjects.