Puntos Privacy Notice

DRAFT — for lawyer review. Not yet in effect.

Version: 0.1 (draft) · Effective date: [EFFECTIVE DATE]

This notice explains how the Puntos team ("Puntos", "we") collects, uses, shares, and protects personal information when you use the Puntos website and apps (the "Service"), as required by the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and issuances of the National Privacy Commission (NPC).

Personal information controller: the Puntos team Data Protection Officer: the Puntos team, [PRIVACY EMAIL]


1. What we collect

CategoryExamplesSource
Accountname, email, sign-in provider ID (e.g. Google), profile photoyou, your sign-in provider
Phone (when verification is enabled)mobile number (stored hashed for uniqueness checks)you
Profiledisplay name, handle, sports, positions, skill level, city, bio, Facebook profile linkyou
Club and event activityclubs joined and roles, registrations, waitlist position, cancellations, transfers (pasalo)you, organizers
Payment recordsamount, payment method type, reference number, optional proof image, approval statusyou, organizers
Attendance and reliabilitycheck-ins, no-shows, late cancellations, disputes and outcomesorganizers, you
Organizer payment detailsaccount name, account number (encrypted), QR code imageorganizers
Communicationsnotification preferences, push subscription tokens, support messagesyou, your device
TechnicalIP address (stored hashed in audit logs), device and browser type, request logs, error reportsyour device
Usage analyticspages viewed and actions taken, with privacy-respecting settingsyour device

We do not collect your wallet or bank login credentials, and we do not process card payments.

2. Why we use it (purposes and lawful basis)

PurposeLawful basis (RA 10173 Sec. 12)
Create and secure your account; prevent duplicate and fake accountsContract; legitimate interest (fraud prevention)
Run rosters, waitlists, offers, transfers, and event rules you agreed toContract
Let organizers verify payments and track balances and refundsContract; legitimate interest of organizers and players in accurate records
Show attendance and reliability records under your privacy settingsContract; legitimate interest; your settings
Handle disputesContract; legitimate interest
Send notifications (in-app, push, email)Contract; consent for optional channels
Keep the Service secure, debug errors, prevent abuseLegitimate interest; legal obligation
Improve the Service with aggregate analyticsLegitimate interest (you may object)
Comply with law, lawful orders, and NPC requirementsLegal obligation

We do not sell personal information and we do not use it for third-party advertising.

3. Who can see your information

ProviderPurposeLocation
SupabaseDatabase, sign-in, file storageSingapore
Fly.ioWebsite, API and background jobsSingapore
CloudflareDomain, network security, bot checks on sign-in, email forwardingGlobal edge
ResendEmail deliveryUnited States
GoogleSign-in (if you choose it)Global
MetaFacebook sign-in (if you choose it)Global
SentryError monitoringUnited States
New RelicPerformance monitoringUnited States
PostHogPrivacy-respecting product analyticsUnited States / EU

4. Transfers outside the Philippines

Some providers process data outside the Philippines (see table). We use providers with contractual data-protection commitments and security safeguards, and we remain accountable for your data under RA 10173.

5. How long we keep it

DataRetention
Account and profileWhile your account is active; deleted or anonymized within 30 days of account deletion
Payment proof imagesDeleted 180 days after the event
Ledger entries, refunds, audit logsKept for record integrity; your identity is anonymized when you delete your account
Attendance and reliability recordsWhile your account is active; anonymized on deletion
Unpaid balances at deletionYour name as the club knew it, the game and the amount, visible only to that club's owner and admins; erased when paid or waived, or after [DEBT RETENTION PERIOD]
Server and error logsUp to 90 days
Push subscriptionsUntil you unsubscribe or the device token expires

We may keep data longer if required by law or to resolve an active dispute.

6. How we protect it

Encryption in transit (HTTPS) and at rest; organizer account numbers encrypted in the database; payment proofs in private storage with short-lived links; access limited by role and by club; append-only audit logs; personal data redacted from application logs; regular security scanning. No method is perfectly secure, but we work to meet recognized standards (OWASP ASVS Level 2).

7. Your rights

Under RA 10173 you have the right to: be informed; access your data; object to processing (including analytics); erasure or blocking; rectification; data portability; damages for violations; and to file a complaint with the National Privacy Commission (privacy.gov.ph).

You can edit your profile and privacy settings and delete your account in the Service. For other requests, email [PRIVACY EMAIL]. We may need to verify your identity. We respond within 15 days, or tell you if we need more time.

Some records cannot be fully erased without harming other people's accurate records (for example, a ledger entry an organizer relies on). In those cases we anonymize your identity instead.

8. Cookies and similar technologies

We use essential cookies and local storage to keep you signed in and to remember settings. We use privacy-respecting analytics to understand usage; you can opt out in your settings. We do not use advertising cookies.

9. Breach notification

If a personal data breach is likely to put you at real risk of serious harm, we will notify the National Privacy Commission and affected users within 72 hours of knowledge, as required by NPC rules, and tell you what we are doing about it.

10. Children

The Service is for people 18 and older, or minors using it with the consent and supervision of a parent or guardian. If you believe a minor's data was given to us without that consent, contact [PRIVACY EMAIL] and we will delete it.

11. Changes to this notice

We will post updates here with a new version and effective date, and notify you in the Service or by email of material changes.

12. Contact

Data Protection Officer: the Puntos team · [PRIVACY EMAIL]