Privacy Policy – phfub

1 Introduction

phfub ("phfub," "we," "us," or "our") is committed to protecting the privacy and personal data of all registered players and visitors to the phfub platform. This Privacy Policy describes how phfub collects, uses, stores, shares, and protects personal information in connection with the operation of our online casino and sports betting services in the Philippines.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. phfub acts as the personal information controller in respect of all personal data collected through the Platform.

By registering an account on phfub, accessing the Platform, or using any of our services, you consent to the collection, processing, and use of your personal data as described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must immediately cease using the phfub Platform.

This Privacy Policy should be read in conjunction with phfub's Terms and Conditions, which govern your use of the Platform and are incorporated herein by reference.

2 Personal Data We Collect

phfub collects the following categories of personal data from registered players and Platform visitors:

phfub does not collect sensitive personal information as defined under the DPA (such as health data, political opinions, or religious beliefs) unless specifically required by law or with your explicit consent.

3 How We Collect Your Data

phfub collects personal data through the following means:

• Direct collection: Information you provide when registering your phfub account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the phfub Platform, including through cookies, web beacons, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay.
• Publicly available sources: Information from public records or databases where permitted by applicable law for the purpose of verifying your identity or preventing fraud.

4 How We Use Your Personal Data

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

• Account management: To create, maintain, and manage your phfub player account, including processing your registration and verifying your identity.
• Service delivery: To provide you with access to phfub's games, sports betting markets, promotions, and all other Platform features and services.
• Payment processing: To process deposits, withdrawals, and other financial transactions on your phfub account, and to maintain accurate financial records.
• Legal and regulatory compliance: To comply with our obligations under applicable Philippine law, including anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and data protection law.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the phfub Platform and its players.
• Responsible gaming: To monitor gaming activity and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance through phfub's support channels.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the phfub Platform.

phfub will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

5 Legal Basis for Processing

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

• Contractual necessity: Processing is necessary to perform our obligations under the Terms and Conditions you agreed to when registering your phfub account, including providing gaming services and processing payments.
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and regulatory reporting duties.
• Legitimate interests: Processing is necessary for phfub's legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookies, phfub relies on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing and Disclosure

phfub does not sell, rent, or trade your personal data to third-party marketers. We 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, InstaPay, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and identity verification service providers engaged by phfub to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention partners: Anti-fraud and security service providers who assist phfub in detecting and preventing fraudulent activity on the Platform.
• IT and infrastructure providers: Cloud hosting, data storage, and technology service providers who process data on phfub's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, regulatory bodies, and law enforcement authorities in the Philippines where disclosure is required by law, court order, or regulatory directive.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by phfub in connection with the operation of our business, subject to confidentiality obligations.

All third parties with whom phfub shares personal data are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with phfub's instructions and applicable data protection law.

In the event of a merger, acquisition, or sale of all or part of phfub's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Privacy Policy.

7 Data Retention

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

The following general retention periods apply to the main categories of personal data held by phfub:

• Account and identity data: Retained for the duration of your active phfub account, and for a minimum of five (5) years following account closure, in accordance with AML and KYC regulatory requirements applicable in the Philippines.
• Financial transaction data: Retained for a minimum of five (5) years from the date of each transaction, in compliance with applicable financial record-keeping regulations.
• Communications data: Support communications and chat transcripts are retained for up to three (3) years from the date of the communication for dispute resolution and quality assurance purposes.
• Technical and usage data: Retained for up to twenty-four (24) months from collection for analytics and security purposes, after which it is anonymized or deleted.
• Marketing consent records: Retained for the duration of your consent and for up to three (3) years following withdrawal of consent, as evidence of your consent history.

When personal data is no longer required for any of the purposes described above, phfub will securely delete or anonymize it in accordance with our data disposal procedures.

8 Data Security

phfub implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phfub's servers.
• Encryption at rest for sensitive personal and financial data stored on phfub's servers.
• Multi-factor authentication options for player accounts to prevent unauthorized access.
• Access controls limiting access to personal data to authorized phfub personnel on a strict need-to-know basis.
• Regular security audits and penetration testing conducted by independent security professionals.
• Intrusion detection systems and real-time monitoring to identify and respond to security threats.

Despite these measures, no method of electronic transmission or data storage is completely secure. phfub cannot guarantee the absolute security of your personal data. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phfub will notify you and the National Privacy Commission of the Philippines in accordance with the requirements of the Data Privacy Act of 2012.

You are responsible for maintaining the security of your phfub login credentials. Do not share your password with anyone, and contact our support team immediately if you suspect unauthorized access to your account.

9 Cookies and Tracking Technologies

phfub uses cookies and similar tracking technologies on the Platform to enhance your user experience, analyze Platform usage, and support our security and fraud prevention measures. The following categories of cookies are used by phfub:

• Strictly necessary cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Performance and analytics cookies: These cookies collect anonymized information about how players use the phfub Platform, such as which pages are visited most frequently and how long sessions last. This data helps us improve Platform performance and user experience.
• Functional cookies: These cookies remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience on phfub.
• Marketing cookies: With your consent, phfub may use cookies to deliver relevant promotional content and to measure the effectiveness of our marketing campaigns. You may withdraw consent for marketing cookies at any time through your browser settings or our cookie preference center.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phfub Platform. For more information on managing cookies, refer to your browser's help documentation.

10 Your Data Protection Rights

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

• Right to be informed: You have the right to be informed about how phfub collects and uses your personal data, as set out in this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data phfub holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request that phfub correct any inaccurate or incomplete personal data held about you. You may update certain account information directly through your phfub account settings.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phfub's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes. You may exercise this right at any time by updating your communication preferences in your account settings.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that phfub has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the rights listed above, please contact phfub's Data Protection Officer by sending a written request to [email protected]. phfub will respond to all data subject requests within thirty (30) days of receipt, in accordance with the requirements of the DPA.

11 Children's Privacy

The phfub Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine regulations governing online gaming and casino-style gambling. phfub does not knowingly collect personal data from individuals under the age of 21.

If phfub becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on phfub or provided personal data to us, please contact our support team immediately at [email protected] so that we can investigate and take appropriate action.

phfub employs age verification procedures during the registration process and reserves the right to request documentary proof of age at any time. Accounts that cannot be verified as belonging to a player aged 21 or above will be suspended pending verification or permanently closed.

12 Changes to This Privacy Policy

phfub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the features and services offered on the Platform. The date of the most recent revision is indicated at the top of this page.

When material changes are made to this Privacy Policy, phfub will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how phfub protects your personal data.

Your continued use of the phfub Platform following the publication of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any changes to this Privacy Policy, you must cease using the Platform and may request the closure of your account by contacting our support team.

13 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or phfub's data processing practices, please contact our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.

You may reach phfub's Data Protection Officer at: [email protected]

Please note that this email address is displayed as plain text for informational purposes only and is not a clickable link. phfub will acknowledge all written privacy inquiries within five (5) business days and provide a substantive response within thirty (30) days of receipt.

For complaints that cannot be resolved directly with phfub, you may contact the National Privacy Commission of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.