phparm Privacy Policy

1. Introduction

1.1 phparm ("we", "us", "our") is committed to protecting the privacy and personal data of all players who register and use the phparm online gaming platform. This Privacy Policy sets out the basis on which phparm collects, processes, stores, and shares personal data in connection with the operation of the phparm platform.

1.2 This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission of the Philippines. phparm is also subject to applicable data handling requirements imposed by PAGCOR as a condition of its gaming operations.

1.3 This Privacy Policy should be read together with phparm's Terms & Conditions, which are available at phparm.net/terms-conditions. Terms not defined in this Privacy Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

2.1 phparm is the data controller responsible for the personal data collected through the phparm platform. As data controller, phparm determines the purposes and means of processing your personal data.

2.2 phparm has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws and this Privacy Policy. You may contact the phparm DPO using the contact details provided in Section 15 of this Privacy Policy.

3. Personal Data We Collect

3.1 phparm collects the following categories of personal data from players:

3.1 Identity and Contact Data

• Full legal name as it appears on a government-issued identification document;
• Date of birth;
• Residential address (including barangay, city or municipality, province, and postal code);
• Email address;
• Mobile phone number.

3.2 Identity Verification Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID);
• Selfie or facial image submitted for identity verification purposes;
• Proof of address documents where required.

3.3 Financial Data

• Payment method details (e.g., GCash mobile number, PayMaya account reference, bank account details for BPI, BDO, or Metrobank withdrawals);
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references;
• Account balance information.

3.4 Gaming Activity Data

• Game session records, including games played, bet amounts, outcomes, and session duration;
• Bonus and promotion participation records;
• Responsible gaming settings and limit history.

3.5 Technical and Usage Data

• IP address and approximate geolocation derived from IP address;
• Device type, operating system, and browser information;
• Platform access logs, including login timestamps and session duration;
• Cookie and tracking data as described in Section 8.

3.6 Communications Data

• Records of communications between you and phparm's customer support team, including chat transcripts and email correspondence;
• Survey responses and feedback submitted to phparm.

4. How We Collect Your Data

4.1 phparm collects personal data through the following means:

• Direct collection: Data you provide when registering your phparm account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Data collected automatically when you access and use the phparm platform, including through cookies, log files, and similar tracking technologies;
• Third-party sources: Data received from payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention services, and regulatory bodies where permitted by applicable law.

5. How We Use Your Personal Data

5.1 phparm uses the personal data it collects for the following purposes:

Purpose	Data Used
Account registration and management	Identity and contact data
Age and identity verification (KYC)	Identity and verification data
Processing deposits and withdrawals	Financial data, identity data
Providing access to games and platform features	Account data, gaming activity data
Anti-money laundering (AML) compliance	Financial data, identity data, transaction history
Fraud detection and prevention	Technical data, financial data, gaming activity data
Responsible gaming monitoring and enforcement	Gaming activity data, responsible gaming settings
Customer support and dispute resolution	Communications data, account data
Regulatory reporting to PAGCOR and other authorities	Identity data, financial data, gaming activity data
Platform improvement and analytics	Technical and usage data (aggregated where possible)
Marketing communications (where consented)	Contact data, gaming activity data

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the phparm Terms & Conditions, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering laws, PAGCOR regulatory requirements, and tax obligations;
• Legitimate interests: Processing necessary for phparm's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights;
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Sharing Your Personal Data

7.1 phparm does not sell, rent, or trade your personal data to third parties for their own commercial purposes. phparm may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals;
• Identity verification providers: Third-party KYC and identity verification service providers engaged by phparm to assist with age and identity verification;
• Fraud prevention services: Third-party fraud detection and prevention service providers engaged to protect the phparm platform and its players;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation;
• Technology and hosting providers: Cloud hosting, data storage, and platform infrastructure providers engaged by phparm to operate the platform;
• Professional advisers: Legal, accounting, and compliance advisers engaged by phparm, subject to professional confidentiality obligations.

7.2 All third parties with whom phparm shares personal data are required to handle such data in accordance with applicable data privacy laws and phparm's data processing requirements. phparm does not authorize third parties to use your personal data for their own independent purposes.

7.3 phparm does not transfer personal data outside the Philippines except where required by applicable law or where adequate data protection safeguards are in place in the recipient jurisdiction.

8. Cookies and Tracking Technologies

8.1 phparm uses cookies and similar tracking technologies on the phparm website and mobile application. Cookies are small text files stored on your device that help phparm recognize you, remember your preferences, and improve your experience on the platform.

8.2 phparm uses the following categories of cookies:

• Strictly necessary cookies: Required for the phparm platform to function correctly, including session management and security features. These cookies cannot be disabled;
• Functional cookies: Used to remember your preferences and settings on the phparm platform, such as language preferences and responsible gaming limit settings;
• Analytics cookies: Used to collect aggregated information about how players use the phparm platform, helping us improve platform performance and user experience;
• Security cookies: Used to detect and prevent fraudulent activity and unauthorized access to phparm accounts.

8.3 You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phparm platform. phparm does not use third-party advertising cookies or share cookie data with advertising networks.

9. Data Retention

9.1 phparm retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

9.2 In accordance with applicable Philippine anti-money laundering regulations and PAGCOR requirements, phparm retains player account records, transaction records, and identity verification documents for a minimum of five (5) years following account closure or the date of the last transaction, whichever is later.

9.3 Where phparm processes personal data on the basis of your consent (such as for marketing communications), phparm will retain such data until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

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

10. Data Security

10.1 phparm implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption of personal data in transit using industry-standard TLS/SSL protocols;
• Encryption of sensitive data at rest, including financial data and identity verification documents;
• Role-based access controls limiting access to personal data to authorized phparm personnel on a need-to-know basis;
• Regular security assessments and penetration testing of phparm's platform infrastructure;
• Staff training on data privacy and security obligations.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phparm will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations.

10.3 While phparm takes all reasonable steps to protect your personal data, no data transmission over the internet or electronic storage system is completely secure. You are responsible for maintaining the security of your phparm account credentials as described in the Terms & Conditions.

11. Your Data Privacy Rights

11.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phparm:

• Right to be informed: The right to be informed of how your personal data is collected, processed, and used by phparm, as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data phparm holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held by phparm;
• Right to erasure: The right to request deletion of your personal data, subject to phparm's legal and regulatory retention obligations;
• Right to object: The right to object to the processing of your personal data where phparm relies on legitimate interests as the legal basis for processing;
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phparm has not handled your personal data in accordance with applicable law.

11.2 To exercise any of the above rights, please contact phparm's Data Protection Officer using the contact details in Section 15. phparm will respond to all data privacy rights requests within thirty (30) days of receipt, or within such extended period as may be permitted under applicable law.

11.3 phparm may need to verify your identity before processing a data privacy rights request to ensure that personal data is not disclosed to unauthorized persons.

12. Children's Privacy

12.1 The phparm platform is strictly intended for individuals aged 21 years and above. phparm does not knowingly collect personal data from individuals under the age of 21. If phparm becomes aware that personal data has been collected from an individual under 21 years of age, phparm will take immediate steps to delete such data and close the associated account.

12.2 If you believe that phparm may have inadvertently collected personal data from a person under 21 years of age, please contact phparm immediately using the contact details in Section 15.

13. Marketing Communications

13.1 With your consent, phparm may send you marketing communications about phparm promotions, new games, and platform updates via email or SMS. You may withdraw your consent to receive marketing communications at any time by updating your communication preferences in your phparm account settings or by contacting phparm support.

13.2 Withdrawal of consent to marketing communications will not affect your ability to use the phparm platform or receive service-related communications necessary for the operation of your account.

13.3 phparm does not share your contact details with third parties for their own marketing purposes.

14. Changes to This Privacy Policy

14.1 phparm reserves the right to update or amend this Privacy Policy at any time. Where changes are material, phparm will provide reasonable advance notice to registered players via email or a prominent notice on the phparm platform prior to the changes taking effect.

14.2 The date of the most recent revision to this Privacy Policy is displayed at the top of this page. Your continued use of the phparm platform following notification of any amendment constitutes your acknowledgment of the revised Privacy Policy.

14.3 phparm encourages you to review this Privacy Policy periodically to stay informed about how phparm protects your personal data.

15. Contact Us

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or phparm's handling of your personal data, please contact our Data Protection Officer:

phparm Data Protection Officer
Email: [email protected]

15.2 For general support enquiries, you may also contact the phparm customer support team at: [email protected]

15.3 phparm aims to acknowledge all privacy-related enquiries within 5 business days and to resolve requests within 30 days of receipt. Complex matters may require additional time, in which case phparm will keep you informed of progress.

15.4 You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with phparm's response to your privacy concern.