hawkph Privacy Policy

hawkph ("we", "us", "our", or "the Company") operates the online gaming platform accessible at hawkph.club (the "Platform"). This Privacy Policy describes how hawkph collects, uses, discloses, stores, and protects the personal information of individuals ("Players" or "you") who register for or otherwise interact with the Platform.

This Privacy Policy forms part of the hawkph Terms & Conditions. By creating a hawkph account or accessing the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, please discontinue use of the Platform.

hawkph is committed to protecting the privacy of its players and to processing personal data in a lawful, fair, and transparent manner, consistent with the obligations set out under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR").

For the purposes of the Philippine Data Privacy Act of 2012, hawkph is the Personal Information Controller in respect of all personal data collected through the Platform. hawkph determines the purposes and means of processing your personal data.

hawkph has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with the DPA and this Privacy Policy. The DPO can be contacted via the support channels specified in Section 14 of this Privacy Policy. Player data subject access requests, correction requests, deletion requests, and complaints should be directed to the DPO in the first instance.

hawkph collects the following categories of personal data from players in connection with account registration, platform use, and legal compliance obligations:

3.1 Sensitive Personal Information. Certain data collected during KYC verification — including government ID numbers — may constitute sensitive personal information under the DPA. hawkph handles all such data with heightened security measures and processes it solely to fulfil mandatory identity and age verification obligations under applicable Philippine gaming and anti-money laundering regulations.

3.2 Voluntary Data. Players are not required to provide data beyond what is necessary for registration, KYC, and payment processing. However, failure to provide required information may prevent hawkph from activating your account or processing withdrawal requests.

hawkph uses the personal data collected for the following purposes:

• Account Registration and Management: Creating and maintaining your hawkph account, authenticating your hawkph login sessions, and managing account settings and preferences;
• KYC and Age Verification: Verifying that all players are at least 21 years of age and confirming the accuracy of identity information as required under Philippine gaming regulations;
• Payment Processing: Facilitating PHP deposits via GCash, PayMaya, BPI, BDO, and Metrobank, and processing withdrawal requests to your verified payment methods;
• Anti-Money Laundering Compliance: Monitoring transactions for suspicious activity and fulfilling reporting obligations under the Anti-Money Laundering Act (Republic Act No. 9160, as amended) and relevant AMLC regulations;
• Fraud Prevention and Platform Security: Detecting, investigating, and preventing fraudulent activity, account abuse, bonus exploitation, and collusion;
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling indicators and administering deposit limits, loss limits, and self-exclusion tools activated by players;
• Customer Support: Responding to player inquiries, resolving disputes, and providing technical assistance;
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the hawkph platform, game offerings, and user experience;
• Legal and Regulatory Compliance: Meeting hawkph's obligations under applicable Philippine law, responding to lawful regulatory requests, and maintaining records as required by law.

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

• Consent: Where you have given explicit consent to specific processing activities, such as receiving promotional communications from hawkph;
• Contractual Necessity: Where processing is necessary to perform the contract between hawkph and you as a registered player — including account registration, game access, deposit processing, and withdrawal facilitation;
• Legal Obligation: Where processing is required for hawkph to comply with applicable Philippine laws, including the Anti-Money Laundering Act, gaming regulations, and the Data Privacy Act itself;
• Legitimate Interests: Where processing is necessary for hawkph's legitimate interests in fraud detection, platform security, responsible gaming compliance, and improving the player experience — provided such interests are not overridden by your fundamental rights and freedoms.

6.1 Third-Party Service Providers. hawkph shares personal data with trusted third-party service providers who process data on our behalf under binding data processing agreements. Categories of third-party processors include:

• Payment processors and e-wallet providers (GCash, PayMaya, and partner banks) for the purpose of processing financial transactions;
• KYC and identity verification service providers for the purpose of confirming player age and identity;
• Cloud infrastructure and hosting providers for secure platform operation and data storage;
• Customer support platform providers for managing support ticket systems and live chat functions;
• Fraud detection and anti-money laundering analytics providers.

6.2 Regulatory and Legal Disclosure. hawkph may disclose personal data to Philippine government agencies, regulatory bodies, law enforcement authorities, and courts where required by applicable law, valid court order, or lawful regulatory directive. This includes mandatory reporting obligations under the Anti-Money Laundering Act and applicable gaming regulation frameworks.

6.3 No Commercial Data Sales. hawkph does not sell, rent, or transfer personal data to third parties for their independent marketing or commercial purposes.

6.4 Business Transfers. In the event of a merger, acquisition, asset sale, or restructuring involving hawkph, player personal data may be transferred to the successor entity. hawkph will provide advance notice of any such transfer and the applicable privacy terms of the receiving entity before the transfer takes effect.

7.1 Types of Cookies Used. The hawkph Platform uses the following categories of cookies and similar tracking technologies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your hawkph account and security cookies that help detect fraudulent login attempts. These cannot be disabled;
• Functional Cookies: Remember your Platform preferences such as language settings and responsible gaming limit configurations;
• Analytical Cookies: Collect anonymised information about how players use the Platform to help hawkph identify performance issues and improve the user experience. Data collected via analytical cookies is aggregated and does not identify individual players.

7.2 Cookie Management. On your first visit to the hawkph Platform, you will be presented with a cookie consent notice. You may manage non-essential cookie preferences through your browser settings at any time. Disabling analytical cookies will not affect your ability to access games or account features on hawkph.

7.3 No Third-Party Advertising Cookies. hawkph does not permit third-party advertising networks to place tracking cookies on the Platform for the purpose of building cross-site advertising profiles from player behaviour on hawkph.

hawkph retains personal data for the periods set out below, after which data is securely deleted or irreversibly anonymised:

Where a longer retention period is required by applicable Philippine law or regulatory direction, hawkph will retain data for that longer period. Where data is retained beyond the periods above for legal purposes, access is restricted to authorised personnel with a documented need.

9.1 Technical Measures. hawkph implements and maintains the following technical security measures to protect player personal data:

• TLS 1.3 encryption for all data in transit between your device and the hawkph Platform;
• Encryption at rest for sensitive personal data stored in hawkph databases;
• One-way password hashing — hawkph cannot retrieve your original password;
• OTP two-step authentication for hawkph login sessions;
• Automatic session timeout on inactive accounts;
• Login attempt rate limiting and brute-force detection;
• Regular security audits and penetration testing of Platform infrastructure.

9.2 Organisational Measures. Access to player personal data is restricted to hawkph employees and contractors who require it to perform their job functions. All personnel with access to personal data are subject to confidentiality obligations and receive regular data protection training.

9.3 Data Breach Response. In the event of a personal data breach that poses a risk to player rights and freedoms, hawkph will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, as required under the DPA IRR. Affected players will be notified without undue delay where the breach is likely to result in high risk to their rights.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by hawkph. To exercise any of these rights, contact hawkph support as described in Section 14.

The hawkph Platform is strictly restricted to individuals who are at least 21 years of age. hawkph does not knowingly collect personal data from individuals under the age of 21. Age verification is performed as part of the mandatory KYC process for all new hawkph account registrations.

If hawkph becomes aware that personal data has been collected from an individual under 21 years of age, that data will be deleted immediately and the associated account will be permanently closed. All funds in such accounts will be forfeited pending investigation in accordance with applicable Philippine gaming regulations.

Parents and guardians who believe that a minor in their household has attempted to register on the hawkph Platform should contact hawkph support immediately. hawkph takes underage access concerns with the utmost seriousness and will investigate and act on all credible reports promptly.

12.1 Transfer Situations. In the course of providing the hawkph Platform, certain technical service providers — including cloud infrastructure and analytics providers — may process personal data in jurisdictions outside the Philippines. hawkph takes steps to ensure that any such cross-border transfers comply with the requirements of the Philippine Data Privacy Act.

12.2 Transfer Safeguards. Before transferring personal data to a third party located outside the Philippines, hawkph ensures that at least one of the following conditions is met:

• The receiving jurisdiction has been assessed to provide an adequate level of data protection;
• Standard contractual clauses or equivalent contractual safeguards are in place between hawkph and the receiving party;
• The transfer is necessary for the performance of a contract between hawkph and the Player (e.g., international payment processing).

12.3 Player Rights on Transfer. Your rights under the Philippine DPA continue to apply to your personal data regardless of where it is stored or processed. You may contact hawkph's DPO for information about specific cross-border transfers affecting your personal data.

hawkph may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, the hawkph Platform's features, or our data processing practices. When material changes are made, hawkph will notify registered players by sending a notice to their registered Philippine mobile number or by posting a prominent notice on the Platform.

The updated Privacy Policy will display the revised effective date at the top of this page. Continued use of the hawkph Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the changes.

Players who do not agree with any material change to this Privacy Policy may close their account and withdraw their available balance before the revised policy takes effect. For account closure requests, please contact hawkph support as described in Section 14.

14.1 Data Protection Officer. For all data privacy inquiries, data subject rights requests, and privacy complaints, players should contact the hawkph Data Protection Officer:

14.2 National Privacy Commission. If you are not satisfied with hawkph's response to a data privacy complaint, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). The NPC oversees compliance with the Data Privacy Act of 2012 and has jurisdiction over complaints from Philippine data subjects regarding violations of the DPA.

14.3 Scope of This Policy. This Privacy Policy applies solely to personal data processed by hawkph through the hawkph.club Platform. It does not apply to third-party websites, payment providers, or services that may be accessible through links on the Platform.

This Privacy Policy was last reviewed and updated as of 1 January 2026. hawkph reserves the right to update this policy in accordance with Section 13.