phpun Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how phpun ("phpun," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you," "your," or "User") who access or use the phpun online gaming platform, including the phpun website and any associated mobile interfaces (collectively, the "Platform").

phpun is committed to protecting the privacy and security of your personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its Implementing Rules and Regulations. phpun is registered with the National Privacy Commission (NPC) of the Philippines as required by law.

By registering an account on phpun, accessing the Platform, or otherwise providing your personal information to phpun, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read together with phpun's Terms & Conditions and Responsible Gaming Policy.

If you do not agree with any part of this Policy, you must not use the phpun Platform. You may withdraw your consent at any time, subject to the limitations described in Section 10 of this Policy.

Data We Collect

phpun collects the following categories of personal data from users of the Platform:

How We Collect Data

phpun collects your personal data through the following means:

• Direct Collection: Information you provide when registering a phpun account, completing KYC verification, making deposits or withdrawals, contacting phpun support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the phpun Platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 7 for details on cookies.
• Third-Party Sources: phpun may receive data about you from third-party identity verification providers, payment processors (such as GCash and PayMaya), fraud detection services, and publicly available sources, where permitted by law and necessary for compliance purposes.
• KYC Verification Providers: When you submit identity documents for KYC verification, phpun uses accredited third-party verification services to authenticate your documents. These providers process your data under strict confidentiality agreements with phpun.

How We Use Your Data

phpun uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your phpun account, including authentication and account security.
• Service Delivery: To provide you with access to phpun's gaming services, process your bets, and deliver game results.
• Payment Processing: To process deposits and withdrawals through your chosen Philippine payment method, and to maintain accurate financial records.
• Identity Verification: To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine law, and to conduct ongoing KYC and AML checks.
• Responsible Gaming: To monitor your gaming activity for signs of problem gambling, to enforce deposit limits and self-exclusion requests, and to provide responsible gaming interventions where appropriate.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, money laundering, and other illegal activities.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Legal Compliance: To comply with applicable Philippine laws, PAGCOR regulatory requirements, court orders, and lawful requests from government authorities.
• Platform Improvement: To analyze usage patterns and improve the phpun Platform's features, performance, and user experience.
• Communications: To send you account-related notifications, security alerts, and, where you have opted in, promotional communications about phpun offers and updates.

phpun will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary for the performance of the contract between you and phpun (i.e., the phpun Terms & Conditions), including account management, game delivery, and payment processing.
• Legal Obligation: Processing is required for phpun to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and tax reporting requirements.
• Legitimate Interests: Processing is necessary for phpun's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as sending promotional communications, phpun relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time by contacting phpun support or updating your account preferences.

Data Sharing & Disclosure

phpun does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phpun may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya (Maya), and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, and others) receive the financial data necessary to process your transactions.
• Identity Verification Providers: Accredited KYC and AML service providers receive identity documents and related data for verification purposes.
• Game Software Providers: phpun's game content providers may receive anonymized or pseudonymized gaming data necessary for game delivery and technical support.
• Regulatory Authorities: phpun may disclose your data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government authorities as required by law or regulatory directive.
• Law Enforcement: phpun may disclose your data to law enforcement agencies in response to lawful requests, court orders, or subpoenas.
• Professional Advisors: php un's legal, accounting, and auditing advisors may access your data on a confidential basis as necessary for their professional services.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on phpun's behalf under strict data processing agreements.

All third parties with whom phpun shares personal data are required to maintain the confidentiality and security of your data and to process it only for the specified purpose. phpun does not authorize any third party to use your data for their own independent purposes.

Cookies & Tracking

phpun uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the phpun website. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming limit configurations to provide a personalized experience.
• Analytics Cookies: Collect anonymized data about how users interact with the phpun Platform, including pages visited and features used, to help phpun improve the user experience.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the phpun Platform.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the phpun Platform. phpun does not use cookies to serve third-party advertising.

Data Retention

phpun retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your phpun account and for a minimum of 5 years following account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Transaction Records: Financial transaction records are retained for a minimum of 5 years from the date of the transaction, as required by the AMLA and BIR regulations.
• KYC Documents: Identity verification documents are retained for a minimum of 5 years following account closure or the last transaction, whichever is later.
• Gaming History: Detailed game records are retained for a minimum of 3 years for dispute resolution and regulatory audit purposes.
• Support Communications: Customer support records are retained for 2 years from the date of the last interaction.
• Marketing Data: Where you have opted in to marketing communications, your marketing preferences are retained until you withdraw consent or close your account.

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

Data Security

phpun implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the phpun Platform is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest, including financial records and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to phpun personnel and authorized third parties who have a legitimate need to access it. All access is logged and audited.
• Two-Factor Authentication (2FA): phpun offers 2FA for all user accounts and requires it for administrative access to systems containing personal data.
• Penetration Testing: phpun conducts regular security assessments and penetration testing of its Platform and infrastructure to identify and remediate vulnerabilities.
• Incident Response: phpun maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, phpun will notify the National Privacy Commission (NPC) within 72 hours and affected users without undue delay, as required by the DPA.
• Staff Training: All phpun personnel with access to personal data receive regular data privacy and security training.

While phpun takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your phpun account credentials and for notifying phpun immediately of any suspected unauthorized access.

Your Rights

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

• Right to Be Informed: You have the right to be informed about how phpun collects and processes your personal data, as set out in this Policy.
• Right of Access: You have the right to request a copy of the personal data phpun holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data phpun holds about you.
• Right to Erasure: You have 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 phpun's legal retention obligations.
• Right to Object: You have the right to object to phpun's processing of your personal data where that processing is based on legitimate interests or for direct marketing purposes.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Withdraw Consent: Where phpun processes your data based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phpun has violated your data privacy rights.

To exercise any of these rights, please contact phpun's Data Protection Officer at [email protected] or via live chat. phpun will respond to all verified data subject requests within 30 calendar days. phpun may request proof of identity before processing your request.

Children's Privacy

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

If phpun discovers or has reason to believe that a user is under 21 years of age, phpun will immediately suspend the account, void any associated transactions, and securely delete all personal data collected from that user, except where retention is required by law.

If you are a parent or guardian and believe that your child under 21 has provided personal data to phpun, please contact phpun's Data Protection Officer immediately at [email protected] so that appropriate action can be taken.

Third-Party Services

The phpun Platform integrates with certain third-party services necessary for its operation, including payment processors, game software providers, and identity verification services. These third parties operate under their own privacy policies and data protection practices.

phpun carefully selects third-party service providers and requires them to enter into data processing agreements that obligate them to protect your personal data to a standard consistent with this Policy and applicable Philippine law. phpun is not responsible for the privacy practices of third-party services that operate independently of the phpun Platform.

phpun does not embed third-party advertising networks, social media tracking pixels, or external analytics platforms that would share your personal data with unrelated third parties for advertising purposes.

Cross-Border Data Transfers

phpun primarily stores and processes your personal data within the Philippines. In certain circumstances, your data may be transferred to and processed in countries outside the Philippines, for example where phpun uses cloud infrastructure or game software providers with servers in other jurisdictions.

Where such cross-border transfers occur, phpun ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to provide a level of data protection equivalent to that required under the Data Privacy Act of 2012. phpun will not transfer your personal data to a country that does not provide an adequate level of data protection without your explicit consent or without implementing appropriate safeguards.

Policy Amendments

phpun reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, phpun will notify registered users via email or in-platform notification at least 7 days before the changes take effect, where practicable.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the phpun Platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy. phpun encourages you to review this Policy periodically to stay informed about how your data is being protected.

Contact & DPO

phpun has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Policy or phpun's data processing practices, please contact:

• Data Protection Officer: phpun Data Privacy Team
• Email: [email protected]
• Live Chat: Available 24/7 on the phpun Platform

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. phpun will cooperate fully with any NPC investigation.