phphone Privacy Policy

1. Introduction

phphone ("we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our online gaming platform at phphone.app. This Privacy Policy describes the types of personal information 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 data.

This Policy applies to all users of the phphone Platform, including registered players, visitors to our website, and any person who contacts our support team. By accessing or using phphone, 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.

This Privacy Policy should be read together with our Terms & Conditions, which govern your use of the phphone Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Personal Data We Collect

phphone collects personal data through several channels, including account registration, gameplay activity, financial transactions, and communications with our support team. The categories of personal data we collect include:

2.1 Identity and Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth (for age verification — players must be 21 years or older)
• Residential address (including barangay, city/municipality, province)
• Email address and mobile number
• Government-issued ID number (e.g., Philippine passport, SSS, UMID, driver's license)

2.2 Financial Data

• GCash or Maya account details used for deposits and withdrawals
• Bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank)
• Debit card details (card number masked; full PAN is not stored)
• Transaction history, deposit and withdrawal records

2.3 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and game activity logs
• Login timestamps and access logs

2.4 Communications Data

• Records of live chat, email, and support ticket interactions
• Feedback, complaints, and dispute correspondence

3. How We Use Your Personal Data

phphone uses the personal data we collect for the following purposes:

Purpose	Data Used
Account registration and identity verification (KYC)	Identity, contact, government ID data
Processing deposits and withdrawals	Financial data, identity data
Fraud prevention and anti-money laundering compliance	Identity, financial, technical data
Providing customer support	Identity, contact, communications data
Responsible gaming monitoring and intervention	Usage data, financial data
Regulatory reporting to PAGCOR and other authorities	Identity, financial, usage data
Improving platform performance and user experience	Technical and usage data (anonymized where possible)
Sending service notifications and account alerts	Contact data
Marketing communications (with your consent)	Contact data, usage preferences

phphone will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by applicable law.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its implementing rules, phphone processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and optional features, where you have given explicit, informed consent. You may withdraw consent at any time by contacting our support team.

5. Data Sharing and Disclosure

phphone 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 only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to facilitate deposits and withdrawals in Philippine Peso.
• KYC and identity verification providers: Third-party services that assist in verifying your identity and government-issued documents in compliance with PAGCOR requirements.
• Game content providers: Licensed game studios and live dealer operators whose games are available on the phphone Platform, to the extent required for game delivery and fairness auditing.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or regulatory directive.
• IT and security service providers: Cloud hosting, cybersecurity, and analytics vendors operating under strict data processing agreements that prohibit independent use of your data.
• Professional advisers: Lawyers, auditors, and accountants bound by professional confidentiality obligations, where necessary for legal or compliance purposes.

All third parties with whom phphone shares personal data are required to implement appropriate technical and organizational security measures and to process your data only in accordance with our instructions and applicable Philippine law.

6. Cookies and Tracking Technologies

phphone uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use our services.

6.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your language preferences, display settings, and login state to improve your experience.
• Analytics cookies: Collect anonymized data about how players navigate the Platform, helping us identify and fix usability issues.
• Security cookies: Detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the phphone Platform. phphone does not use third-party advertising or behavioral tracking cookies.

7. Data Retention

phphone retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods include:

• 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 PAGCOR and AMLA requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Support and communications records: Retained for three (3) years from the date of the last interaction, or longer if required for ongoing dispute resolution.
• Technical and usage logs: Retained for up to twelve (12) months, after which they are anonymized or deleted.

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

8. Data Security

phphone implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phphone Platform
• Encryption of sensitive data at rest, including financial information and government ID details
• Multi-factor authentication options for player accounts
• Regular penetration testing and vulnerability assessments conducted by independent security firms
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• 24/7 security monitoring and intrusion detection systems
• Incident response procedures compliant with NPC breach notification requirements

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

9. Your Data Privacy Rights

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

• Right to be informed: The right to know what personal data phphone collects about you and how it is used — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data phphone 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, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format for transfer to another service provider.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13. phphone will respond to all verified requests within thirty (30) days. We may require proof of identity before processing your request.

10. Children's Privacy

The phphone Platform is strictly intended for adults aged 21 years and older, as required by PAGCOR regulations governing online gaming in the Philippines. phphone does not knowingly collect personal data from individuals under the age of 21.

If phphone becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data, and report the incident to the relevant regulatory authorities where required. If you believe a minor has registered on the phphone Platform, please contact our support team immediately.

11. Cross-Border Data Transfers

phphone primarily stores and processes personal data within the Philippines. In limited circumstances, personal data may be transferred to or accessed from servers located outside the Philippines — for example, when using internationally hosted cloud infrastructure or game content providers.

Any cross-border transfer of personal data is conducted in compliance with Section 21 of the Data Privacy Act of 2012 and NPC implementing rules. phphone ensures that recipient countries or organizations provide an adequate level of data protection, and that appropriate contractual safeguards (such as data processing agreements incorporating NPC-approved standard contractual clauses) are in place before any transfer occurs.

12. Updates to This Privacy Policy

phphone may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before taking effect.

The "Last updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically. Your continued use of the phphone Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact phphone's Data Protection Officer (DPO):

Data Protection Officer — phphone
Email: [email protected]
General Support: [email protected]

Our DPO is registered with the National Privacy Commission of the Philippines in accordance with NPC Circular No. 17-01. We aim to respond to all privacy-related inquiries within fifteen (15) business days.

This Privacy Policy was last updated on January 1, 2026. Previous versions are available upon written request to our Data Protection Officer.