phophen Privacy Policy

1. Introduction

phophen is committed to protecting the privacy and security of every player who uses our platform. We understand that Filipino players are entrusting us with sensitive personal and financial information, and we take that responsibility seriously. This Policy is designed to be transparent — we want you to know exactly what data we hold about you, why we hold it, and what your rights are.

By registering an account with phophen or by continuing to use the phophen platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the phophen platform and contact our support team to close your account.

2. Data Controller

phophen is the data controller responsible for the personal information collected through the phophen platform. As data controller, phophen determines the purposes and means of processing your personal data. phophen operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to Philippine data protection law.

For all data privacy inquiries, requests, and complaints, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

phophen collects personal data in the following categories:

Category	Examples	When Collected
Identity Data	Full name, date of birth, nationality, government ID number	Registration & KYC verification
Contact Data	Email address, mobile number, residential address	Registration & account updates
Financial Data	GCash number, Maya account, bank account details, transaction history	Deposits & withdrawals
Technical Data	IP address, device type, browser type, operating system, session logs	Automatically on platform access
Usage Data	Games played, bets placed, session duration, feature interactions	Automatically during gameplay
Communications Data	Support chat transcripts, email correspondence, feedback submissions	When you contact phophen support
Marketing Preferences	Opt-in/opt-out status for email, SMS, and push notifications	Registration & account settings

phophen does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. We do not collect data relating to racial or ethnic origin, political opinions, religious beliefs, or health information unless specifically required by applicable law or regulation.

4. How We Use Your Personal Data

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

• Account Management: To create, maintain, and administer your phophen account, including verifying your identity and age (21+) as required by PAGCOR regulations.
• Service Delivery: To provide access to phophen games, process deposits and withdrawals, and deliver customer support.
• Regulatory Compliance: To fulfill our obligations under our PAGCOR license, including anti-money laundering (AML) checks, Know Your Customer (KYC) verification, and reporting requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other prohibited conduct on the phophen platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer self-exclusion, deposit limits, and other responsible gaming tools.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your consent or where we have a legitimate interest to do so.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the overall phophen player experience.
• Legal Claims: To establish, exercise, or defend legal claims in connection with the phophen platform.

5. Legal Basis for Processing

phophen processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform the contract between you and phophen — specifically, to operate your account and deliver the services you have requested.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML obligations, and tax reporting requirements.
• Legitimate Interests: Processing is necessary for phophen's legitimate interests, including fraud prevention, platform security, and improving our services, provided those interests are not overridden by your rights and freedoms.
• Consent: Where phophen relies on your consent as the legal basis for processing — for example, for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Data Sharing and Disclosure

phophen does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya (Maya), and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity Verification Providers: Third-party KYC service providers who assist phophen in verifying player identity and age in compliance with PAGCOR requirements.
• Game Software Providers: Licensed game developers and platform providers whose games are available on phophen. These providers may receive anonymized or pseudonymized usage data for game performance purposes.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulation.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and technical support providers who process data on phophen's behalf under strict data processing agreements.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors where necessary for legal compliance or the defense of legal claims.

All third-party service providers who process personal data on behalf of phophen are required to implement appropriate technical and organizational security measures and to process data only in accordance with phophen's instructions.

7. Cookies and Tracking Technologies

phophen 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 phophen website. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the phophen platform to function. 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, display options, and responsible gaming limits you have set.
• Analytics Cookies: Help phophen understand how players use the platform — which games are most popular, where players encounter difficulties, and how navigation flows can be improved. Data collected is aggregated and does not identify individual players.
• Marketing Cookies: Used only where you have given explicit consent, to deliver relevant promotional content within the phophen platform.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phophen platform. phophen does not use cookies to track your activity across unrelated third-party websites.

8. Data Retention

phophen retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulation. Specifically:

• Account and Identity Data: Retained for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AML regulations.
• 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 of 2001 (as amended).
• Communications Data: Support correspondence is retained for up to three (3) years from the date of the last interaction.
• Technical and Usage Data: Retained for up to twenty-four (24) months for platform analytics and security purposes, after which it is anonymized or deleted.
• Marketing Preferences: Retained until you withdraw consent or close your account, whichever is earlier.

When personal data is no longer required for the purposes for which it was collected, phophen will securely delete or anonymize it in accordance with our internal data retention procedures.

9. Data Security

phophen implements a range of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phophen platform.
• Encryption of sensitive data at rest, including financial information and government ID details.
• Role-based access controls ensuring that phophen staff can only access personal data necessary for their specific job functions.
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent third parties.
• Multi-factor authentication requirements for phophen administrative systems.
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC notification requirements.

While phophen takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phophen account credentials and for notifying us immediately if you suspect unauthorized access to your account.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by phophen:

• Right to Be Informed: The right to know whether phophen holds personal data about you and to receive clear information about how it is processed — which this Policy provides.
• Right of Access: The right to request a copy of the personal data phophen holds about you, along with information about how it is used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data phophen holds about you.
• 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 phophen'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 legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phophen has not handled your personal data in accordance with applicable law.

To exercise any of these rights, please contact phophen's Data Protection Officer using the details in Section 14. phophen will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

11. Children's Privacy and Age Restriction

The phophen platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations. phophen does not knowingly collect personal data from individuals under the age of 21. If phophen becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended and the data will be deleted.

If you are a parent or guardian and believe that a minor has registered an account with phophen, please contact our support team immediately so that we can take appropriate action.

12. Third-Party Links

The phophen platform may contain links to third-party websites or services for informational purposes. phophen is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Policy applies solely to personal data collected by phophen through the phophen platform.

13. Changes to This Privacy Policy

phophen 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. The date of the most recent revision is displayed at the top of this page. Where changes are material, phophen will notify registered players via email or an in-platform notification prior to the changes taking effect.

Your continued use of the phophen platform following the publication of any amendment to this Policy constitutes your acknowledgment of the revised terms. We encourage you to review this Policy periodically to stay informed about how phophen protects your personal data.

14. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or phophen's data processing practices, please contact our Data Protection Officer:

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

Our support team is available 24 hours a day, 7 days a week. The DPO will respond to formal data privacy requests within thirty (30) days of receipt.

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.