phcom Privacy Policy

This Privacy Policy ("Policy") describes the data practices of phcom ("phcom," "we," "us," "our") with respect to personal information collected from users ("you," "Player," "User") who access or use phcom.org, the phcom Login portal, mobile interfaces, and any associated services (collectively, the "Platform").

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 guidelines issued by the National Privacy Commission (NPC). By creating a phcom account or continuing to use the Platform, you acknowledge that you have read this Policy and consent to the data practices described herein.

Data Controller

phcom is the personal information controller responsible for the personal data collected through the Platform, as that term is defined under the Data Privacy Act of 2012. phcom determines the purposes for which personal data is processed and the means by which such processing is carried out.

phcom has designated a Data Protection Officer (DPO) as required under Philippine law. Inquiries, complaints, or requests concerning your personal data under this Policy may be addressed to our support team, who will route the matter to the DPO where appropriate. Contact details are provided in Section 15.

Personal Data We Collect

phcom collects only the personal data that is necessary to provide the Platform's services, comply with regulatory requirements, and maintain account security. The categories of personal data we may collect are set out in the table below.

How We Collect Your Data

phcom collects personal data through the following means:

3.1 Direct Collection

You provide personal data directly to phcom when you: register an account through the phcom Login portal; complete the KYC identity verification process by uploading identification documents; submit a deposit or withdrawal request; contact phcom through live chat, email, or other support channels; fill in any form on the Platform; or opt in to promotions and communications.

3.2 Automated Collection

When you access the Platform, phcom automatically collects certain technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This data is collected whether or not you are logged in to your phcom account and is used to maintain platform security, diagnose technical issues, and improve the user experience.

3.3 Third-Party Sources

phcom may receive personal data about you from third parties in the following contexts: payment service providers (such as GCash, Maya, BPI, BDO) who confirm transaction details; identity verification and KYC service providers who validate the authenticity of documents you submit; fraud prevention and anti-money laundering screening services; and PAGCOR or other regulatory authorities where data sharing is required by law.

Purpose of Processing & Legal Basis

phcom processes your personal data for the following purposes, each of which rests on an identified legal basis under the Data Privacy Act of 2012:

• Account creation and management: To establish and maintain your phcom account, authenticate your identity at the phcom Login stage, and manage your account settings. Legal basis: Performance of a contract.
• KYC and age verification: To verify that you meet the minimum age of 21 years and that your identity matches the information provided during registration, as required by PAGCOR and Philippine anti-money laundering law. Legal basis: Legal obligation.
• Payment processing: To process deposits, withdrawals, and refunds via supported payment methods including GCash, Maya, Philippine banks, and cryptocurrency. Legal basis: Performance of a contract.
• Game provision and dispute resolution: To deliver casino games, sports betting, bingo, and sabong services; to record game outcomes for audit and dispute resolution purposes. Legal basis: Performance of a contract.
• Regulatory compliance and reporting: To fulfil obligations under PAGCOR's operational requirements, Philippine anti-money laundering laws (AMLA), and tax regulations, including reporting of suspicious transactions to the Anti-Money Laundering Council (AMLC). Legal basis: Legal obligation.
• Fraud prevention and platform security: To detect, investigate, and prevent fraudulent activity, account compromise, cheating, and other prohibited conduct. Legal basis: Legitimate interests of phcom and its players.
• Responsible gaming: To monitor gameplay patterns that may indicate problem gambling behavior, to enforce deposit limits and self-exclusion orders, and to deliver responsible gaming communications. Legal basis: Legal obligation and legitimate interests.
• Platform improvement and analytics: To analyze usage patterns, diagnose technical problems, test new features, and improve the overall experience of phcom for Filipino players. Legal basis: Legitimate interests.
• Marketing and promotions: To send promotional offers, bonus notifications, and platform updates to players who have consented to receive such communications. Legal basis: Consent (see Section 12).

Data Retention

phcom retains personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods:

• Account and identity records: Retained for the duration of your account plus a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction in compliance with AMLA and tax record-keeping requirements.
• Gameplay logs: Retained for a minimum of three (3) years from the date of each game session, or longer if required for the resolution of an active dispute or regulatory investigation.
• Customer support communications: Retained for a minimum of two (2) years from the date of the most recent interaction in a given matter.
• Marketing consent records: Retained for the duration of your marketing consent plus one (1) year following withdrawal of that consent, to demonstrate compliance with consent obligations.

When personal data is no longer required for the purposes for which it was collected and the applicable retention period has expired, phcom will securely delete or anonymize the data.

Sharing Your Personal Data

phcom does not sell, rent, or trade your personal data to third parties for advertising or commercial profiling purposes. We share personal data only with the categories of recipients described below, and only to the extent necessary for the specified purpose:

6.1 Payment Service Providers

Personal and financial data is shared with payment processors including GCash (G-Xchange Inc.), Maya (Voyager Innovations), BPI, BDO, Metrobank, 7-Eleven Philippines, and cryptocurrency processors, for the sole purpose of executing deposit and withdrawal transactions. These providers are bound by their own privacy policies and applicable Philippine financial regulations.

6.2 Game Content Providers

phcom's game lobby is powered by software providers including, but not limited to, PG Soft, Pragmatic Play, Jili, Play'n GO, and Evolution. These providers may receive a limited subset of gameplay data (such as session tokens and wager amounts) necessary to operate the game software and certify game outcomes. Providers are contractually prohibited from using this data for any purpose other than game delivery.

6.3 KYC and Compliance Service Providers

Identity verification and AML screening are conducted with the assistance of specialist third-party service providers. These providers process identity documents and verification data under strict data processing agreements and applicable law.

6.4 Regulatory Authorities

phcom is obligated to share certain player and transaction data with PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine regulatory authorities where required by law or regulatory direction. phcom will comply with valid legal orders without prior notification to the affected player where the law requires or permits such non-disclosure.

6.5 Professional Advisers

phcom may share relevant personal data with legal counsel, auditors, and professional advisers on a confidential basis where necessary for legal proceedings, audits, or corporate compliance purposes.

Cross-Border Data Transfers

Some of phcom's third-party service providers — particularly game content providers and certain technology infrastructure partners — are located outside the Philippines. When personal data is transferred outside the Philippines, phcom implements appropriate safeguards to ensure that the receiving party provides an adequate level of protection for your data, consistent with the requirements of the Data Privacy Act of 2012 and NPC guidelines on cross-border data flows.

Such safeguards may include: contractual clauses requiring the data recipient to process personal data to standards equivalent to those required under Philippine law; verification that the recipient jurisdiction has data protection laws that the NPC has recognized as providing adequate protection; or reliance on the recipient's certification to recognized international privacy frameworks.

Cookies & Tracking Technologies

phcom uses cookies and similar tracking technologies to operate the Platform and deliver a consistent, secure experience across sessions. The categories of cookies used are described below:

• Strictly Necessary Cookies: Required for core platform functions including session authentication (maintaining your phcom Login state), security token validation, and load balancing. These cookies cannot be disabled without impairing the functionality of the Platform.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and responsible gaming settings you have applied to your account.
• Analytics Cookies: Used to collect anonymized and aggregated information about how players use the Platform — which pages are visited most, where errors occur, and which features are underused. This data is used to improve phcom for Filipino players. Analytics data does not identify individual players.
• Security Cookies: Used to detect and prevent fraudulent activity, identify suspicious login patterns, and enforce account security policies.

Most web browsers allow you to manage cookie preferences through the browser settings menu. Disabling strictly necessary cookies may prevent you from logging in to your phcom account or using certain features of the Platform. phcom does not currently use third-party advertising or retargeting cookies.

Security Measures

phcom implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, accidental loss, and destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmissions between your device and phcom's servers, including during the phcom Login process, deposits, and withdrawals;
• Encryption at rest for sensitive personal and financial data stored in phcom's databases;
• Role-based access controls that restrict employee access to personal data to those with a legitimate operational need;
• Multi-factor authentication for phcom's internal administrative systems;
• Regular third-party security audits and penetration testing of the Platform;
• Incident response procedures for the detection, containment, and notification of personal data breaches in accordance with NPC requirements.

While phcom applies industry-standard safeguards, no data transmission over the internet can be guaranteed to be completely secure. You are responsible for maintaining the security of your phcom Login credentials and for notifying phcom immediately if you believe your account has been compromised.

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 phcom. To exercise any of these rights, please contact phcom's support team as described in Section 15.

• Right to be Informed: The right to be informed of the fact and extent of phcom's processing of your personal data. This Policy fulfils that obligation; you may also request a plain-language summary from our support team.
• Right of Access: The right to obtain a copy of the personal data phcom holds about you, together with information about how it is being processed. Requests are typically fulfilled within 30 days.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update certain information (such as contact details) directly through your phcom account settings, or by submitting a correction request to support.
• Right to Erasure or Blocking: The right to request that personal data that is no longer necessary, or that was collected on the basis of consent subsequently withdrawn, be deleted or blocked. Note that phcom may be required to retain certain data for regulatory compliance purposes even following an erasure request (see Section 5).
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format for transmission to another personal information controller, where technically feasible and lawful.
• Right to Object: The right to object to phcom's processing of your personal data where that processing is based on phcom's legitimate interests, or to object to processing for direct marketing purposes at any time.
• Right to Damages: The right to seek compensation for any actual damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data, pursuant to Section 16 of the Data Privacy Act of 2012.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe phcom has violated your privacy rights. The NPC may be reached through its official channels.

phcom will respond to data subject requests within 30 calendar days of receipt. Complex or high-volume requests may require an extension of up to an additional 30 days, in which case phcom will notify you of the extension and the reasons for it.

Minors

The phcom Platform is strictly intended for adults aged 21 years and older, consistent with the minimum gambling age established under PAGCOR regulations and applicable Philippine law. phcom does not knowingly collect personal data from individuals under 21 years of age.

If phcom becomes aware that personal data has been collected from a person under 21 — whether through a fraudulent registration or any other means — it will immediately suspend the relevant account, cancel all pending transactions, and delete the associated personal data, subject to any mandatory retention obligations required by law.

Parents and guardians who believe a minor has registered on phcom or accessed the Platform should contact phcom's support team immediately. Parental control software is recommended to prevent access by minors to online gambling platforms.

Marketing Communications

phcom may send you promotional emails, SMS messages, or in-platform notifications about bonuses, new games, tournaments, and other phcom offers. All direct marketing communications are sent only to players who have affirmatively opted in to receive them.

You may withdraw your consent to receive marketing communications at any time by: updating your notification preferences in your phcom account settings; clicking the unsubscribe link in any marketing email; or contacting phcom's support team with a request to opt out.

Withdrawal of marketing consent does not affect your ability to use the Platform or receive non-promotional service communications related to your account (such as transaction confirmations, security alerts, or responsible gaming notifications).

Third-Party Links and Services

The phcom Platform may contain links to game providers' interfaces and other integrated third-party services. While phcom vets its third-party partners, phcom is not responsible for the privacy practices or content of any third-party services accessed through or in connection with the Platform.

When you interact with a third-party game interface (such as a live dealer table operated by a third-party provider), that provider's own privacy policy may apply to the data processing that occurs within their system. phcom recommends reviewing the privacy policies of any third-party services you use in connection with phcom.

Changes to This Privacy Policy

phcom reviews this Privacy Policy regularly and may update it to reflect changes in applicable law, regulatory guidance from the NPC or PAGCOR, changes in phcom's data processing practices, or improvements in privacy best practices. The date of the most recent revision is always displayed at the top of this page.

When material changes are made to this Policy — particularly changes that affect your rights or the basis on which phcom processes your data — phcom will notify registered players via the email address or mobile number on record at least 14 days before the updated Policy takes effect. For non-material changes (such as formatting corrections or updated contact details), the revised Policy will be published without advance notice.

Your continued use of the phcom Platform after the effective date of a revised Policy constitutes your acceptance of the changes. If you do not accept a material change, you may request account closure before the effective date.

Contact & Data Subject Requests

For privacy-related inquiries, data subject access requests, or complaints regarding phcom's handling of your personal data, please contact our team through the following channels:

• Live Chat: Available 24/7 via phcom.org — select "Data Privacy" from the support topic menu
• Email: [email protected] — include "Privacy Request" in the subject line

When submitting a data subject request, please include your full registered name, the mobile number linked to your phcom account, and a clear description of your request. phcom may ask for additional information to verify your identity before processing access, rectification, or erasure requests.

If you are not satisfied with phcom's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). phcom encourages you to contact us first so that we can attempt to resolve the matter directly.