phhoy Privacy
Policy

1 Overview & Scope

1.1 This Privacy Policy applies to all personal data collected and processed by phhoy in connection with: (a) the phhoy website at phhoy.club; (b) the phhoy gaming platform and all associated products and services; (c) communications between you and phhoy via live chat, email, or any other channel; and (d) the phhoy player account registration and management process.

1.2 phhoy is committed to handling personal data responsibly, transparently, and in accordance with applicable data protection legislation. For players based in the Philippines, this includes compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

1.3 This Privacy Policy does not apply to third-party websites or services that may be linked from the phhoy platform. phhoy is not responsible for the privacy practices of any third party.

2 Personal Data We Collect

2.1 phhoy collects personal data through several channels, including account registration, KYC verification, payment processing, platform usage, and communications. The categories of personal data we collect are described below.

2.2 phhoy does not knowingly collect sensitive personal information (such as health data, political opinions, or religious beliefs) unless directly relevant to a responsible gaming assessment or legal compliance obligation.

3 How We Use Your Personal Data

3.1 phhoy uses the personal data we collect for the following purposes:

• Account Management: To create, operate, and maintain your phhoy player account, including identity verification and security.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Regulatory Compliance: To comply with anti-money laundering (AML) obligations, KYC requirements, PAGCOR reporting obligations, and other applicable legal requirements.
• Gaming Services: To provide access to phhoy's slots, live casino, bingo, sports betting, and other game categories, and to record betting history for dispute resolution purposes.
• Responsible Gaming: To enforce deposit limits, session reminders, self-exclusion requests, and the 21+ age restriction; to identify problem gambling indicators and take appropriate action.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and violations of the phhoy Terms and Conditions.
• Customer Support: To respond to your support queries, complaints, and account management requests.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications.
• Platform Improvement: To analyse platform usage data in aggregate to improve phhoy's games, user experience, and technical performance.

4 Legal Basis for Processing

4.1 phhoy processes personal data on the following legal bases, consistent with the Data Privacy Act of 2012 and applicable data protection principles:

• Contractual Necessity: Processing required to fulfil our obligations under the phhoy Terms and Conditions — including account management, payment processing, and the provision of gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC requirements, and regulatory reporting to PAGCOR.
• Legitimate Interests: Processing necessary for phhoy's legitimate business interests, including fraud prevention, platform security, and responsible gaming enforcement — where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained. You may withdraw consent at any time.

5 Data Sharing & Disclosure

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

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processing services, to facilitate deposits and withdrawals.
• Identity Verification Providers: Third-party KYC service providers who verify the authenticity of identity documents submitted during account verification.
• Game Providers: JILI, PG Soft, Pragmatic Play, CQ9, and other licensed game providers receive session data necessary to deliver game functionality. These providers do not receive your financial or identity verification data.
• Regulatory Authorities: PAGCOR and other applicable regulatory or law enforcement bodies, where disclosure is required by law, court order, or regulatory directive.
• Fraud Prevention Services: Third-party fraud detection and anti-money laundering screening services used to protect the platform and its players.
• Professional Advisors: Lawyers, auditors, and other professional advisors engaged by phhoy, under obligations of confidentiality.

5.2 All third parties with whom phhoy shares personal data are required to maintain appropriate technical and organisational security measures and are contractually prohibited from using your data for purposes beyond those specified.

6 Cookies & Tracking Technologies

6.1 phhoy uses cookies and similar tracking technologies on the phhoy.club platform. Cookies are small text files placed on your device that help us operate the platform, remember your preferences, and analyse usage patterns.

6.2 The types of cookies used by phhoy include:

• Strictly Necessary Cookies: Required for the platform to function, including maintaining your login session and security state. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming configurations.
• Analytics Cookies: Used to understand aggregate platform usage — pages visited, session duration, error rates — to improve the phhoy experience. Data is processed in anonymised or pseudonymised form.
• Marketing Cookies: Used to deliver relevant promotional content to opted-in players. These are set only with your consent.

6.3 You may manage your cookie preferences through your browser settings. Disabling functional or analytics cookies may affect your experience on the phhoy platform but will not prevent you from accessing core gaming features.

7 Data Retention

7.1 phhoy retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention principles:

• Active Accounts: Personal data is retained for the full duration of your active phhoy account relationship.
• Closed Accounts: Following account closure, phhoy retains identity, financial, and gaming data for a minimum of five (5) years, as required by applicable AML legislation and regulatory obligations.
• Responsible Gaming Records: Self-exclusion records and problem gambling flags are retained for a minimum of seven (7) years to prevent circumvention of exclusion measures.
• Support Communications: Live chat transcripts and email correspondence are retained for three (3) years from the date of the last interaction.
• Technical Logs: IP address and session data logs are retained for twelve (12) months under normal circumstances.

7.2 After the applicable retention period has expired, phhoy will securely delete or anonymise the personal data concerned.

8 Security Measures

8.1 phhoy implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and phhoy's servers;
• Encryption of sensitive stored data, including financial account details and identity document images;
• Access controls limiting personal data access to authorised phhoy staff on a need-to-know basis;
• Two-factor authentication options for player accounts;
• Regular security audits and vulnerability assessments of phhoy's platform infrastructure;
• Staff training on data protection obligations and security best practices.

8.2 While phhoy takes all reasonable precautions, no data transmission or storage system can be guaranteed as completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phhoy will notify affected players and the relevant authorities as required by applicable law.

9 Your Privacy Rights

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and shared — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of the personal data phhoy holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data in your phhoy account.
• Right to Erasure: The right to request deletion of your personal data where there is no lawful basis for continued retention — subject to phhoy's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: The right to receive a copy of personal data you have provided to phhoy in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing emails), the right to withdraw consent at any time without affecting the lawfulness of prior processing.

9.1 phhoy will respond to privacy rights requests within 30 calendar days. Some requests may take longer where they involve complex data extraction or legal review. We may ask you to verify your identity before processing a rights request.

10 Children & Minors

10.1 The phhoy platform is strictly intended for individuals aged 21 years and above, consistent with PAGCOR's minimum age requirement for online gambling in the Philippines. phhoy does not knowingly collect personal data from individuals under the age of 21.

10.2 If phhoy becomes aware that an account has been registered by or on behalf of a person under 21, the account will be immediately suspended, all balances held will be reviewed in accordance with the phhoy Terms and Conditions, and any personal data of the minor will be promptly deleted.

10.3 If you believe a person under 21 has registered a phhoy account, please contact phhoy support immediately at [email protected].

11 International Data Transfers

11.1 Where phhoy transfers personal data to third-party service providers located outside the Philippines — such as game providers, cloud infrastructure providers, or fraud screening services — we ensure that appropriate safeguards are in place to protect your personal data in accordance with applicable data protection law.

11.2 These safeguards may include contractual data transfer agreements that impose equivalent data protection standards on the recipient, or reliance on the recipient being located in a jurisdiction recognised as providing adequate data protection.

12 Third-Party Links

12.1 The phhoy platform may contain links to third-party content or services, including game provider promotional pages. This Privacy Policy does not apply to any third-party websites or services. phhoy is not responsible for the privacy practices, data collection, or content of any third party.

12.2 We encourage you to review the privacy policies of any third-party services you access via the phhoy platform.

13 Policy Updates

13.1 phhoy 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, phhoy will notify registered players via the email address associated with their phhoy account and by publishing the updated Policy at phhoy.club/privacy-policy.

13.2 The date of the most recent revision is shown at the top of this Privacy Policy. Your continued use of the phhoy platform after the effective date of any update constitutes acceptance of the revised Policy.

14 Contact & Complaints

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or phhoy's handling of your personal data, please contact the phhoy Data Privacy team:

14.2 If you are unsatisfied with phhoy's response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC), the supervisory authority for data protection matters under the Data Privacy Act of 2012.

14.3 This Privacy Policy was last reviewed and updated in June 2026.