phpar Privacy Policy

1. Introduction

phpar ("phpar," "we," "us," "our") operates the online gaming platform accessible at phpar.club (the "Platform"), providing casino games, sports betting, bingo, live dealer games, and related services to eligible players in the Philippines. This Privacy Policy ("Policy") describes how phpar collects, uses, discloses, stores, and protects personal information provided by players ("you," "your") in connection with your use of the Platform.

This Policy is prepared in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its Implementing Rules and Regulations, as well as applicable PAGCOR guidelines on player data handling.

This Policy should be read alongside phpar's Terms & Conditions and Responsible Gaming Policy, both of which form part of the agreement between you and phpar.

2. Data Controller

phpar is the data controller responsible for the personal information collected through phpar.club. As data controller, phpar determines the purposes and means by which your personal data is processed.

For all data privacy matters, including requests to exercise your data subject rights under the Data Privacy Act of 2012, you may contact phpar through the channels listed in Section 14 of this Policy.

3. Personal Data We Collect

phpar collects the following categories of personal data from players:

phpar does not collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and compliance purposes.

4. How We Collect Your Data

phpar collects personal data through the following methods:

• Direct Collection: Information you provide during registration, identity verification (KYC), deposit and withdrawal requests, support interactions, and voluntary communications.
• Automated Collection: Technical data collected automatically when you access the Platform, including IP address, device identifiers, browser characteristics, and session data via cookies and server logs.
• Third-Party Sources: Identity verification data from accredited KYC and anti-money laundering screening providers, and payment confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank.

5. Purpose & Legal Basis for Processing

phpar processes your personal data for the following purposes, each grounded in a legal basis under the Data Privacy Act of 2012:

• Contract Performance: To create and manage your phpar account, process deposits and withdrawals, deliver gaming services, and provide customer support.
• Legal Obligation: To comply with PAGCOR licensing conditions, Philippine anti-money laundering (AMLA) requirements, and applicable tax regulations — including mandatory player identity verification and transaction record-keeping.
• Legitimate Interest: To detect and prevent fraud, cheating, money laundering, and other prohibited activities; to improve Platform functionality and user experience; and to manage responsible gaming obligations.
• Consent: To send you marketing communications and promotional offers about phpar services. You may withdraw marketing consent at any time by contacting support or using the unsubscribe option in promotional emails.

6. Data Sharing and Disclosure

6.1 Authorised Recipients

phpar shares your personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment Processors: GCash (Mynt), PayMaya (Maya Philippines Inc.), BPI, BDO, and Metrobank — to process deposit and withdrawal transactions.
• Identity Verification Providers: Accredited KYC service providers engaged to verify player identity and screen against PAGCOR and AMLC watchlists.
• Game Technology Providers: Licensed game providers (e.g., JILI Games, Pragmatic Play) receive minimal player session data necessary for game operation. These providers are contractually prohibited from using this data for any purpose other than providing the game service.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other relevant Philippine government agencies where disclosure is required by law.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and technical support providers operating under strict data processing agreements with phpar.

6.2 No Sale of Personal Data

phpar does not sell, rent, or trade your personal data to any third party for commercial purposes. Your data is not shared with advertising networks or data brokers.

7. International Data Transfers

Some of phpar's technology providers — including game providers and cloud infrastructure services — may process data in servers located outside the Philippines. Where international transfers occur, phpar ensures they are governed by data processing agreements that provide a level of protection substantially equivalent to that required under the Data Privacy Act of 2012. phpar does not transfer personal data to jurisdictions that lack adequate data protection frameworks without implementing appropriate contractual safeguards.

8. Data Retention

phpar retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods mandated by Philippine law:

• Account Data and Transaction Records: Minimum of 5 years from the date of account closure, in compliance with AMLA record-keeping requirements.
• KYC/Identity Verification Documents: Minimum of 5 years from submission or account closure, whichever is later.
• Gaming Session Data: Up to 2 years from the session date, used for dispute resolution and responsible gaming monitoring.
• Support Interaction Records: Up to 3 years from the date of the interaction.

Following the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual.

9. Security Measures

phpar implements the following technical and organisational security measures to protect your personal data:

• Encryption: All data transmitted between your device and phpar's servers is encrypted using 256-bit TLS/SSL. Stored passwords are hashed using industry-standard cryptographic algorithms — phpar cannot retrieve your plaintext password.
• Access Controls: Access to personal data is restricted to authorised phpar personnel on a strict need-to-know basis. All staff with data access undergo regular training on data privacy obligations.
• Intrusion Detection: phpar's infrastructure is monitored 24/7 for suspicious activity. Automated systems detect and respond to potential security threats in real time.
• Two-Factor Authentication: Sensitive account actions — including withdrawals and password changes — require OTP verification to a registered Philippine mobile number.
• Data Breach Response: In the event of a personal data breach that poses a real risk to affected data subjects, phpar will notify the National Privacy Commission (NPC) and affected players as required under the Data Privacy Act of 2012 and its Implementing Rules.

10. Cookies & Tracking Technologies

phpar uses the following types of cookies and tracking technologies on phpar.club:

• Essential Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged into your phpar account. These cannot be disabled without breaking Platform functionality.
• Performance & Analytics Cookies: Used to understand how players navigate phpar.club — which pages are visited most frequently, where errors occur, and how the Platform can be improved. Analytics data is aggregated and does not identify individual players.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming configurations, so you don't have to re-enter them on every visit.

phpar does not use third-party advertising or retargeting cookies. You can manage or disable non-essential cookies through your browser's cookie settings. Note that disabling essential cookies will affect your ability to log in and use the Platform.

11. Your Data Subject Rights

Under the Republic Act No. 10173 (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 know that your personal data is being collected and processed, which this Policy fulfils.
• Right of Access: The right to request a copy of the personal data phpar holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure or Blocking: The right to request deletion or blocking of personal data that is unlawfully collected or no longer necessary for the purpose 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. You may withdraw marketing consent at any time.
• 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) of the Philippines if you believe phpar has mishandled your personal data.

To exercise any of these rights, contact phpar support via live chat at phpar.club or by email at [email protected]. phpar will respond to data subject requests within 30 days of receipt, subject to identity verification.

12. Children's Privacy

phpar's services are strictly restricted to persons who are 21 years of age or older, in accordance with PAGCOR's regulatory standards for online gambling in the Philippines. phpar does not knowingly collect personal data from persons under the age of 21. If phpar discovers that an account has been registered by a person under the minimum age, the account will be immediately closed, balances will be reviewed in accordance with phpar's Terms & Conditions, and all personal data associated with the account will be deleted in accordance with applicable law.

Parents and guardians who believe a minor has registered on phpar are encouraged to contact phpar support immediately via live chat.

13. Changes to This Privacy Policy

phpar may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or platform features. Material changes will be communicated to registered players via the email address associated with their account or via a prominent notice on phpar.club at least 7 days before the change takes effect, where practicable.

The date at the top of this Policy indicates when it was last revised. Continued use of the phpar platform after the effective date of any revision constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by phpar, please contact us through the following channels:

• Live Chat: Available 24/7 via phpar.club (Philippine Standard Time)
• Email: [email protected]
• Coverage Area: Serving Manila, Cebu, Davao, and all of the Philippines

For complaints that cannot be resolved directly with phpar, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.