phfunclub Privacy Policy

1. Data Controller

phfunclub is the data controller responsible for the personal information collected through the phfunclub platform. phfunclub operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the data protection obligations imposed by the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

phfunclub has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact the DPO at the email address provided in Section 14 of this policy.

2. Personal Data We Collect

phfunclub collects the following categories of personal data from players and platform users:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., Philippine National ID, passport, driver's license, SSS/GSIS number).
• Contact Data: Residential address (including city — Manila, Cebu, Davao, Quezon City, Makati, or elsewhere in the Philippines), email address, and mobile number.
• Account Data: Username, encrypted password, account registration date, account status, and communication preferences.
• Financial Data: Payment method details (GCash account number, PayMaya account, BPI/BDO/Metrobank account details), transaction history, deposit and withdrawal records, and account balance information.
• Gaming Data: Betting history, game session data, wagering patterns, bonus usage, and responsible gaming tool settings.
• Technical Data: IP address, device type, browser type and version, operating system, time zone, and platform access logs.
• Usage Data: Information about how you navigate and interact with the phfunclub platform, including pages visited, features used, and session duration.
• Communications Data: Records of your communications with phfunclub customer support, including live chat transcripts and email correspondence.

3. How We Collect Your Data

phfunclub collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the phfunclub platform, through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering (AML) screening services; payment data from e-wallet providers such as GCash and PayMaya, and banking partners including BPI, BDO, and Metrobank.
• Regulatory sources: Data received from PAGCOR or other competent Philippine authorities in connection with regulatory compliance obligations.

4. How We Use Your Personal Data

phfunclub uses your personal data for the following purposes:

• To create, manage, and maintain your phfunclub account.
• To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and the Philippine Data Privacy Act.
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To provide customer support and respond to your enquiries and complaints.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To comply with our legal and regulatory obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• To administer bonuses, promotions, and loyalty programs.
• To monitor and enforce responsible gaming measures, including deposit limits, self-exclusion, and cooling-off periods.
• To improve the phfunclub platform through analytics and user experience research.
• To send you service-related communications, including account notifications, transaction confirmations, and security alerts.
• To send you marketing communications about phfunclub promotions and new features, where you have provided consent or where permitted by applicable law.

5. Legal Basis for Processing

phfunclub processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the phfunclub Terms & Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, tax reporting requirements, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

phfunclub does not sell or rent your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• PAGCOR and regulatory authorities: As required by our operating license and applicable Philippine law.
• KYC and identity verification providers: To verify your identity and age in compliance with regulatory requirements.
• Payment processors and e-wallet providers: Including GCash, PayMaya, BPI, BDO, and Metrobank, to process your financial transactions.
• Anti-fraud and AML screening services: To detect and prevent money laundering and fraudulent activity.
• IT and platform service providers: Including cloud hosting, data analytics, and customer support technology providers, who process data on our behalf under strict data processing agreements.
• Law enforcement and courts: Where required by a valid court order, subpoena, or other legal process under Philippine law.

All third-party service providers engaged by phfunclub are contractually required to maintain the confidentiality and security of your personal data and to process it only for the purposes specified by phfunclub.

7. Data Retention

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

• Account and identity data is retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Financial transaction records are retained for a minimum of five (5) years in compliance with AMLA and BIR requirements.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing consent records are retained for the duration of your account and for three (3) years following account closure.

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

8. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the phfunclub platform.
• Encryption of personal data at rest using industry-standard encryption protocols.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments and vulnerability testing of the phfunclub platform.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phfunclub will notify the National Privacy Commission and affected players in accordance with the timeframes prescribed by the Data Privacy Act and NPC regulations.

9. Cookies Policy

phfunclub uses cookies and similar tracking technologies to enhance your experience on the platform. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the platform to function, including session management and security cookies. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login status to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the phfunclub platform, helping us improve performance and user experience.
• Marketing cookies: Used to deliver relevant promotional content about phfunclub. These are only set with your consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phfunclub platform.

10. Your Rights as a Data Subject

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

• Right to be informed: The right to know how your personal data is being collected and processed, as described in this Privacy Policy.
• Right of access: The right to request a copy of the personal data phfunclub holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to phfunclub's legal and regulatory retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact phfunclub's Data Protection Officer using the contact details in Section 14. phfunclub will respond to all verified data subject requests within thirty (30) days, as required by the Data Privacy Act.

11. Children's Privacy

The phfunclub platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. phfunclub does not knowingly collect personal data from individuals under the age of 21. If phfunclub becomes aware that personal data has been collected from an underage individual, the associated account will be immediately suspended and the data will be deleted in accordance with our data disposal procedures.

If you are a parent or guardian and believe that your child has registered on phfunclub, please contact our customer support team immediately so that we can take appropriate action.

12. Cross-Border Data Transfers

phfunclub primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed by service providers located outside the Philippines — for example, cloud infrastructure providers or international KYC verification services.

Where such transfers occur, phfunclub ensures that appropriate safeguards are in place to protect your personal data, including contractual data processing agreements that impose data protection standards equivalent to those required under the Philippine Data Privacy Act. phfunclub will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or without implementing appropriate safeguards.

13. Amendments to This Privacy Policy

phfunclub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. Any material changes will be communicated to registered players via email or platform notification prior to taking effect. The updated policy will be posted on this page with a revised effective date.

Your continued use of the phfunclub platform following the posting of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how phfunclub protects your personal data.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or phfunclub's data protection practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Data Privacy Request – [Your Full Name]
• Response Time: Within 30 days of receipt of a verified request

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