phpar Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") describes how phpar ("phpar," "we," "us," or "our"), the operator of the online gaming platform at phpar.app, collects, uses, stores, shares, and protects the personal data of users ("you," "Player," or "Data Subject") who access or use the phpar platform, including all games, features, promotions, and support services.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission. It applies to all personal data collected through phpar.app, our mobile applications, and any other phpar-branded digital touchpoints.

This Policy should be read together with phpar's Terms & Conditions, which are available at phpar.app/terms-conditions.

2. Personal Data We Collect

phpar collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued ID details (e.g., PhilSys ID number, passport number, driver's license number, UMID number).
• Contact Data: Philippine mobile number, email address, and residential address (including city, province, and postal code).
• Account Data: Username, encrypted password, account preferences, communication preferences, and responsible gaming settings.
• Financial Data: GCash or PayMaya account details, bank account details (for bank transfer transactions), transaction history, deposit and withdrawal records. phpar does not store full payment card numbers.
• KYC Verification Data: Copies of government-issued identification documents and proof of address submitted during the Know Your Customer (KYC) verification process.
• Gaming Data: Game history, wagering activity, session duration, game preferences, bonus usage, and win/loss records.
• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Usage Data: Pages visited on phpar.app, features used, links clicked, time spent on the platform, and navigation patterns.
• Communications Data: Records of your communications with phpar's customer support team, including live chat transcripts and email correspondence.

phpar collects personal data directly from you (e.g., during registration, KYC, or support interactions), automatically through your use of the platform (e.g., via cookies and server logs), and in limited cases from third-party identity verification and fraud prevention service providers.

3. How We Use Your Personal Data

phpar uses your personal data only for legitimate, specified purposes. The primary purposes for which phpar processes your personal data are:

• Account Management: To create, maintain, verify, and manage your phpar player account, including processing your registration and KYC verification.
• Service Delivery: To provide you with access to phpar's games, features, promotions, and customer support services.
• Financial Transactions: To process deposits, withdrawals, and bonus credits, and to maintain accurate financial records.
• Legal & Regulatory Compliance: To comply with phpar's obligations under the Data Privacy Act, anti-money laundering laws, PAGCOR regulations, and other applicable Philippine laws. This includes identity verification, transaction monitoring, and reporting to regulatory authorities where required.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal or prohibited conduct on the phpar platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, to enforce responsible gaming limits and self-exclusion requests, and to provide responsible gaming support.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the phpar platform, games, and user experience.
• 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 via your account settings or by contacting support.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, phpar processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and phpar (i.e., the Terms & Conditions), including account management, game provision, and financial transaction processing.
• Legal Obligation: Processing is necessary for phpar to comply with applicable Philippine laws and regulations, including KYC/AML obligations and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for phpar's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and interests.
• Consent: For marketing communications and certain non-essential cookies, phpar relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Cookies & Tracking Technologies

phpar uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies used by phpar include:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymized data about how players use phpar, which pages are most visited, and where errors occur. This data helps phpar improve the platform.
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming limits.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the phpar platform.

6. Sharing Your Personal Data

phpar does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phpar may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Identity Verification & KYC Providers: Third-party service providers that assist phpar in verifying player identities and complying with KYC/AML obligations.
• Payment Processors: GCash, PayMaya / Maya, and Philippine banking partners that process your deposits and withdrawals. These providers are subject to their own privacy policies and data protection obligations.
• Game Software Providers: Licensed game developers whose games are hosted on the phpar platform may receive limited technical data necessary to deliver game content.
• Fraud Prevention & Security Providers: Specialist providers that assist phpar in detecting and preventing fraud, money laundering, and other prohibited activities.
• Regulatory & Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities, where phpar is legally required to disclose information.
• Professional Advisors: Lawyers, auditors, and other professional advisors engaged by phpar, subject to professional confidentiality obligations.

All third-party service providers engaged by phpar are contractually required to process personal data only on phpar's instructions and to implement appropriate technical and organizational security measures.

7. Data Retention

phpar retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active Account Data: Retained for the duration of your phpar account and for a period of at least five (5) years after account closure, as required by Philippine AML regulations.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction.
• Support Communications: Retained for up to three (3) years from the date of the communication.
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period thereafter for compliance documentation purposes.

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

8. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and phpar's servers.
• Encryption of sensitive data at rest, including financial data and KYC documents.
• Role-based access controls ensuring that phpar staff can only access personal data necessary for their specific job functions.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication for phpar staff accessing internal systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

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

9. Your Rights as a Data Subject

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

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phpar holds about you, along with information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most of your account information directly through your phpar account settings.
• 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 phpar'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 phpar's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint:The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phpar has violated your data privacy rights.

To exercise any of these rights, please contact phpar's Data Protection Officer (DPO) using the contact details in Section 12. phpar will respond to all valid data subject requests within fifteen (15) calendar days of receipt, as required by the DPA.

10. Children's Privacy

phpar is strictly an adult platform. In accordance with Philippine gaming regulations enforced by PAGCOR, phpar requires all players to be at least 21 years of age. phpar does not knowingly collect personal data from individuals under the age of 21.

If phpar discovers or has reason to believe that a player is under 21 years of age, the account will be immediately suspended, all pending transactions will be frozen, and any deposits will be returned to the source payment method after verification. If you believe a minor has registered on phpar, please contact our support team immediately.

11. Changes to This Privacy Policy

phpar reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, phpar will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect, where practicable.

The most current version of this Privacy Policy will always be available at phpar.app/privacy-policy. The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. Your continued use of phpar following the effective date of any amendment constitutes your acceptance of the revised Policy.

12. Contact & Data Protection Officer

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

• Live Chat: Available 24/7 via the phpar platform
• Email (DPO): [email protected]
• General Support: [email protected]

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines at [email protected] (plain text — not a link) if you are not satisfied with phpar's response to your data privacy concern.