phll Privacy Policy

1. Introduction and Scope

phll ("phll", "we", "us", or "our") is committed to protecting the privacy and personal data of all users of the phll online casino platform, accessible at phll.net and all associated subdomains and mobile interfaces (collectively, the "Platform"). This Privacy Policy ("Policy") describes how phll collects, uses, stores, discloses, and protects personal data in connection with your use of the Platform.

This Policy applies to all registered players, visitors, and any other individuals whose personal data phll processes in connection with the Platform. By accessing or using the phll Platform, you acknowledge that you have read, understood, and agree to the data practices described in this Policy. If you do not agree, please discontinue use of the Platform immediately.

This Policy should be read together with phll's Terms & Conditions and Responsible Gaming Policy, both of which are available on the Platform.

2. Data Controller Information

phll acts as the data controller in respect of the personal data collected through the Platform. As data controller, phll determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "PDPA") and its implementing rules and regulations.

For all privacy-related inquiries, you may contact phll's designated Data Protection Officer (DPO) at the contact details provided in Section 13 of this Policy.

3. Personal Data We Collect

3.1 Registration and Identity Data

When you create a phll account, we collect the following personal data: full legal name, date of birth, residential address (including city, province, and postal code), email address, Philippine mobile number, and government-issued identification details for Know Your Customer (KYC) verification purposes.

3.2 Financial Data

To process deposits and withdrawals, phll collects financial information including your preferred payment method details (e.g., GCash account number, PayMaya account, BPI, BDO, or Metrobank account details), transaction history, and deposit and withdrawal records. phll does not store full payment card numbers on its servers.

3.3 Gaming Activity Data

phll collects data relating to your gaming activity on the Platform, including game history, wagering records, session duration, win and loss records, and bonus usage. This data is used for account management, regulatory compliance, and responsible gaming monitoring purposes.

3.4 Technical and Device Data

When you access the phll Platform, we automatically collect certain technical data, including your IP address, browser type and version, operating system, device identifiers, referring URLs, and pages visited. This data is collected through cookies and similar tracking technologies as described in Section 8.

3.5 Communications Data

If you contact phll's support team, we will collect and retain records of your communications, including the content of emails, live chat transcripts, and any attachments you provide.

4. How We Collect Your Data

phll collects personal data through the following means:

• Directly from you — when you register for an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions;
• Automatically — through cookies, web beacons, and similar technologies when you access and interact with the Platform;
• From third parties — including identity verification service providers, payment processors, and fraud prevention agencies, where necessary to verify your identity or comply with regulatory requirements.

5. Purposes and Legal Basis for Processing

phll processes your personal data for the following purposes and on the following legal bases:

• Account registration and management — to create and maintain your phll account, verify your identity, and provide you with access to the Platform's features. Legal basis: performance of a contract.
• Payment processing — to process deposits, withdrawals, and other financial transactions. Legal basis: performance of a contract.
• Regulatory compliance — to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR reporting requirements, and the PDPA. Legal basis: legal obligation.
• Responsible gaming — to monitor gaming activity for signs of problem gambling and to enforce responsible gaming measures, including self-exclusion requests. Legal basis: legitimate interests and legal obligation.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct. Legal basis: legitimate interests.
• Customer support — to respond to your inquiries and resolve disputes. Legal basis: performance of a contract and legitimate interests.
• Marketing and promotions — to send you information about phll promotions, bonuses, and new features, where you have provided your consent. Legal basis: consent. You may withdraw your consent at any time by contacting [email protected].
• Platform improvement — to analyze usage patterns and improve the functionality and user experience of the phll Platform. Legal basis: legitimate interests.

6. Disclosure of Personal Data

phll does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phll may disclose your personal data to the following categories of recipients:

• Service providers — including payment processors, identity verification providers, cloud hosting providers, and customer support platform providers, who process data on phll's behalf under strict data processing agreements;
• Regulatory and law enforcement authorities — including PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and Philippine law enforcement agencies, where required by law or court order;
• Fraud prevention agencies — to verify your identity and prevent fraudulent activity;
• Business successors — in the event of a merger, acquisition, or sale of all or part of phll's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

All third-party service providers engaged by phll are contractually required to process personal data only in accordance with phll's instructions and applicable Philippine data protection law.

7. Data Retention

phll retains your personal data for as long as your phll account remains active and for a period of at least five (5) years following account closure, in accordance with Philippine AML regulations and PAGCOR record-keeping requirements. Financial transaction records may be retained for longer periods where required by applicable law.

Where personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, phll will securely delete or anonymize such data in accordance with its internal data retention procedures.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the phll Platform. They allow phll to recognize your device, remember your preferences, and improve your overall experience on the Platform.

8.2 Types of Cookies Used

• Strictly necessary cookies — essential for the operation of the phll Platform, including session management and security functions. These cannot be disabled.
• Functional cookies — used to remember your preferences, such as language settings and login status, to provide a more personalized experience on phll.
• Analytics cookies — used to collect aggregated, anonymized data about how users interact with the phll Platform, helping us identify areas for improvement.
• Marketing cookies — used to deliver relevant promotional content about phll. These are only placed with your consent.

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Please note that disabling strictly necessary cookies may affect the functionality of the phll Platform and prevent you from accessing certain features.

9. Data Security

phll 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:

• AES-256 encryption for data stored on phll servers;
• Transport Layer Security (TLS) encryption for all data transmitted between your device and the phll Platform;
• Multi-factor authentication options for phll account access;
• Regular security audits and penetration testing of the Platform's infrastructure;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Comprehensive staff training on data protection and information security practices.

While phll takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phll will notify the National Privacy Commission and affected individuals in accordance with the requirements of the PDPA.

10. Your Rights Under the PDPA

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 phll:

• Right to be informed — you have the right to be informed of how your personal data is being collected and processed, as described in this Policy;
• Right of access — you have the right to request a copy of the personal data phll holds about you;
• Right to rectification — you have the right to request correction of any inaccurate or incomplete personal data phll holds about you;
• Right to erasure — you have 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 phll's legal retention obligations;
• Right to object — you have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on phll's legitimate interests;
• 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;
• Right to lodge a complaint — you have the right to lodge a complaint with the National Privacy Commission if you believe phll has violated your data privacy rights.

To exercise any of the above rights, please contact phll's Data Protection Officer at the details provided in Section 13. phll will respond to all verified requests within fifteen (15) business days, in accordance with the PDPA's requirements.

11. Children's Privacy

The phll Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. phll does not knowingly collect personal data from individuals under the age of 21. If phll becomes aware that personal data has been collected from a person under 21, such data will be deleted immediately and the associated account will be suspended.

If you are a parent or guardian and believe that your child has provided personal data to phll, please contact us immediately at [email protected] so that we can take appropriate action.

12. Changes to This Privacy Policy

phll reserves the right to update or modify this Privacy Policy at any time. When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered phll players via email or a prominent notice on the Platform.

Your continued use of the phll Platform following the posting of any changes to this Policy constitutes your acceptance of those changes. We encourage you to review this Policy periodically to stay informed about how phll protects your personal data.

13. Contact and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or phll's data processing practices, please contact our Data Protection Officer using the details below. All communications should be in English.

• Data Protection Officer: [email protected]
• General Support: [email protected]

phll aims to resolve all privacy-related inquiries within fifteen (15) business days of receipt. If you are not satisfied with phll's response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.

Note: This Privacy Policy constitutes the complete and current statement of phll's privacy practices with respect to the Platform. It supersedes any prior privacy notices or statements. If any provision of this Policy is found to be invalid or unenforceable under applicable law, the remaining provisions shall continue in full force and effect.