Privacy Policy

01 Overview & Scope

This Privacy Policy applies to all personal information collected by phsphin through the phsphin online gaming platform, including our website, mobile-optimized interface, customer support channels, and any other services operated under the phsphin brand (collectively, the "Platform").

By registering an account on phsphin, accessing the Platform, or otherwise providing your personal information to us, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

phsphin acts as the Personal Information Controller with respect to the personal data of its players and Platform visitors, as defined under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations. phsphin is committed to full compliance with the National Privacy Commission's (NPC) guidelines and applicable data protection standards.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and phsphin.

02 Personal Data We Collect

phsphin collects the following categories of personal information from players and Platform visitors:

phsphin does not collect sensitive personal information beyond what is strictly necessary for identity verification, regulatory compliance, and the provision of gaming services. We do not collect biometric data, health information, or political affiliations.

03 How We Collect Your Data

phsphin collects personal data through the following means:

• Direct Collection: Information you provide when registering your phsphin account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the phsphin Platform, including through cookies, web beacons, pixel tags, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; age verification data from identity verification partners.
• Payment Processors: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers used on the phsphin Platform.

phsphin will always inform you at the point of collection what data is being collected and for what purpose, where this is not already covered by this Privacy Policy.

04 How We Use Your Personal Data

phsphin uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your phsphin player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to phsphin's games, process your deposits and withdrawals, credit bonuses, and deliver the core gaming experience.
• KYC & Compliance: To verify your identity and age in accordance with Philippine gaming regulations and anti-money laundering (AML) requirements, and to maintain records required by applicable law.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the phsphin Platform.
• Responsible Gaming: To monitor gaming patterns for signs of problem gambling, enforce responsible gaming limits and self-exclusion requests, and provide appropriate support to players who may be at risk.
• Customer Support: To respond to your inquiries, resolve disputes, process complaints, and provide technical assistance through our 24/7 support team.
• Marketing & Promotions: To send you information about phsphin promotions, bonuses, and new games — but only where you have provided your consent to receive such communications. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the phsphin Platform's features, performance, and user experience for Filipino players.
• Legal Obligations: To comply with applicable Philippine laws, regulatory requirements, court orders, and lawful requests from government authorities.

05 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, phsphin processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you — i.e., to provide the phsphin gaming services you have registered for, including account management, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including KYC/AML requirements, gaming regulations, and tax reporting obligations.
• Legitimate Interests: Processing necessary for phsphin's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and optional analytics. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Sharing Your Personal Data

phsphin does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances:

• Service Providers: With carefully selected third-party service providers who assist phsphin in operating the Platform, including KYC/identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud detection services, cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on phsphin's instructions and in accordance with applicable data protection law.
• Regulatory Authorities: With the Philippine Amusement and Gaming Corporation (PAGCOR), the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where required by law or regulatory directive.
• Law Enforcement: With law enforcement agencies or courts where phsphin is legally required to disclose information, or where disclosure is necessary to protect the rights, property, or safety of phsphin, its players, or the public.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of phsphin's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.
• With Your Consent: With any other third party where you have provided your explicit consent to such sharing.

07 Data Retention

phsphin retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements.

• Active Account Data: Retained for the duration of your phsphin account and for a period of five (5) years following account closure, in accordance with Philippine AML and gaming record-keeping requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of submission, or longer if required by applicable law or ongoing regulatory proceedings.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine AML regulations.
• Support Communications: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of your prior consent.
• Technical & Usage Logs: Retained for up to twelve (12) months for security and fraud detection purposes, after which they are anonymized or deleted.

When personal data is no longer required, phsphin will securely delete or anonymize it in accordance with our data disposal procedures.

08 Data Security

phsphin implements robust technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the phsphin Platform is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest, including passwords and financial information, is encrypted using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to phsphin staff and service providers who have a legitimate need to access it. All access is logged and subject to regular review.
• Secure Infrastructure: phsphin's Platform is hosted on secure, enterprise-grade cloud infrastructure with regular security patching, vulnerability scanning, and penetration testing.
• Two-Factor Authentication: phsphin offers two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Staff Training: All phsphin staff who handle personal data receive regular data protection and security awareness training.
• Incident Response: phsphin maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, phsphin will notify the National Privacy Commission and affected players in accordance with applicable requirements.

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

09 Cookies & Tracking Technologies

phsphin uses cookies and similar tracking technologies to operate and improve the Platform, personalize your experience, and analyze usage patterns. The following types of cookies are used on the phsphin Platform:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game preferences, and responsible gaming limits to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players use the phsphin Platform, helping us identify areas for improvement. Used only with your consent.
• Security & Fraud Detection Cookies: Help phsphin detect and prevent fraudulent activity, unauthorized account access, and bot traffic on the Platform.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the phsphin Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate.

10 Your Data Privacy Rights

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

• Right to Be Informed: The right to know what personal data phsphin collects about you, how it is used, and with whom it is shared — as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phsphin holds about you, along with information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You can update most account information directly through your phsphin account settings.
• 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 phsphin's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on phsphin's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phsphin has violated your data privacy rights.

To exercise any of these rights, please contact phsphin's Data Protection Officer using the contact details in Section 15 of this Policy. phsphin will respond to all verified requests within thirty (30) days, or within the timeframe required by applicable law.

11 Minors & Age Restriction

The phsphin Platform is strictly intended for persons who are 21 years of age or older, in accordance with Philippine gaming regulations. phsphin does not knowingly collect personal data from individuals under the age of 21.

phsphin employs age verification procedures during account registration and KYC processes to prevent access by minors. If phsphin becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately closed, all data will be deleted, and the matter may be referred to the appropriate Philippine authorities.

If you are a parent or guardian and believe that a minor has registered on the phsphin Platform, please contact our support team immediately so we can take appropriate action.

12 Third-Party Services & Links

The phsphin Platform integrates with third-party services including game providers, payment processors, and identity verification services. These third parties operate under their own privacy policies and data protection practices. phsphin is not responsible for the privacy practices of third-party service providers, though we carefully vet all partners for compliance with applicable data protection standards before engaging them.

phsphin does not include links to external third-party websites on the Platform. All content and services accessible through phsphin are operated by phsphin or its authorized service providers.

13 International Data Transfers

Some of phsphin's service providers — including cloud hosting, KYC verification, and fraud detection partners — may process your personal data outside the Philippines. Where such international transfers occur, phsphin ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Philippine Data Privacy Act, including through contractual data processing agreements incorporating standard data protection clauses.

phsphin will not transfer your personal data to countries or organizations that do not provide an adequate level of data protection without your explicit consent or a lawful basis for the transfer.

14 Changes to This Privacy Policy

phsphin may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, phsphin will notify registered players by email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how phsphin protects your personal data. Your continued use of the phsphin Platform after the effective date of any update constitutes your acceptance of the revised Policy.

15 Contact & Data Protection Officer

phsphin has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection law. If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy, please contact us:

• Data Protection Officer: phsphin DPO
• Email: support phsphin.org
• Live Chat: Available 24/7 through the phsphin Platform
• Support Hours: 8:00 AM – 12:00 MN Philippine Time (PHT)

If you are not satisfied with phsphin's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.