phpun Privacy Policy

This Privacy Policy applies to all personal information collected, processed, and stored by phpun in connection with the operation of the online gaming platform accessible at phpun.club (the "Platform"), including all related services, promotions, customer support channels, and account management functions.

Data Controller: For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, phpun acts as the personal information controller with respect to all personal data processed in connection with the Platform. phpun is responsible for ensuring that personal data is collected lawfully, processed only for legitimate purposes, and kept secure.

This Privacy Policy applies to all registered Players and to visitors who interact with the phpun Platform without registering an account. By accessing phpun or submitting any personal information through the Platform, you acknowledge that you have read and understood this Privacy Policy.

phpun collects the following categories of personal data depending on how you interact with the Platform:

phpun does not collect special categories of sensitive personal information (such as health data, religious beliefs, or political opinions) except where voluntarily disclosed by the Player in the context of a responsible gaming intervention or support request, in which case such information is treated with heightened care and used solely for the purpose of providing the requested support.

phpun collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in a promotion, or update your account settings.
• Automatically through the Platform — technical data and gaming activity data are collected automatically through server logs, session tracking, and standard web technologies when you access or use the phpun Platform.
• Through cookies and similar technologies — as described in Section 9 of this Privacy Policy.
• From payment processing partners — when you initiate a GCash, PayMaya, BPI, BDO, or Metrobank transaction, phpun receives transaction confirmation data from the relevant payment processor. phpun does not receive or store full bank account numbers or GCash PINs.
• From identity verification providers — where phpun uses a third-party service to assist with KYC verification, identity data may be processed by that provider under a data processing agreement with phpun.

phpun processes your personal data for the following purposes:

• Account creation and management: To register your phpun account, verify your identity and age (21+ requirement), maintain your account, and enable you to use all Platform features.
• Provision of gaming services: To provide you with access to games, process bets and winnings, manage your account balance, and operate the Platform generally.
• Payment processing: To process deposits and withdrawals, verify that payment methods are owned by the account holder, and detect and prevent payment fraud.
• KYC and regulatory compliance: To verify your identity, age, and address in compliance with applicable Philippine gaming regulations and anti-money laundering obligations.
• Customer support: To respond to your support queries, resolve disputes, and maintain records of our communications with you.
• Responsible gaming: To administer deposit limits, session reminders, cooling-off periods, and self-exclusion arrangements, and to identify and respond to potential indicators of problem gambling.
• Security and fraud prevention: To protect phpun and its Players against fraud, unauthorized account access, money laundering, and other financial crime.
• Platform improvement: To analyze aggregated, anonymized usage data to improve the Platform's features, performance, and user experience.
• Marketing communications: To send you promotional offers, bonus notifications, and other marketing communications — subject to your marketing preferences and your right to opt out at any time.
• Legal obligations: To comply with applicable Philippine laws, regulatory requirements, and any court order or direction from a regulatory authority.

phpun processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the phpun Terms and Conditions — including account management, gaming services, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering obligations under the Anti-Money Laundering Act (RA 9160, as amended), PAGCOR-related regulatory requirements, and the Data Privacy Act of 2012 itself.
• Legitimate interests: Processing carried out for phpun's legitimate business interests, including fraud prevention, Platform security, responsible gaming monitoring, and anonymized analytics — where these interests are not overridden by your rights and interests.
• Consent: For marketing communications and any other processing that is not covered by the above bases, phpun relies on your freely given, specific, and informed consent. You may withdraw consent at any time by updating your preferences or contacting phpun support.

phpun may share your personal data with the following categories of recipients, strictly for the purposes described in this Privacy Policy:

• Game Providers: Third-party game studios whose games are made available through phpun may process limited technical and session data to deliver game functionality. Game Providers operate under contractual obligations to protect player data.
• Payment Processors: GCash (Mynt — Globe Fintech Innovations), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and other payment processors receive transaction data necessary to process deposits and withdrawals.
• Identity Verification Providers: Where phpun uses a specialist KYC service provider, that provider processes identity documents under a data processing agreement with phpun and is prohibited from using the data for any purpose other than verifying identity for phpun's account.
• Cloud and Hosting Infrastructure: phpun uses cloud hosting and data storage providers. These providers access data only as directed by phpun under data processing agreements and have no independent right to use your data.
• Regulatory and Law Enforcement Authorities: phpun may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government authorities where required by law, court order, or regulatory direction.
• Professional Advisers: Lawyers, auditors, and other professional advisers engaged by phpun may access personal data subject to strict confidentiality obligations.

phpun will not share your personal data with any third party outside the categories listed above without your prior consent, except where required to do so by applicable law.

Some of phpun's third-party service providers — including certain Game Providers and cloud infrastructure partners — may be located outside the Republic of the Philippines. Where personal data is transferred to a jurisdiction outside the Philippines, phpun takes appropriate measures to ensure that the transfer is lawful and that your data receives equivalent protection, including:

• Entering into data transfer agreements that incorporate the requirements of the Data Privacy Act of 2012 and NPC-prescribed safeguards
• Transferring data only to jurisdictions or organizations that the NPC has recognized as providing an adequate level of data protection
• Relying on recipients' binding corporate rules or equivalent contractual protections where NPC adequacy recognition is not available

You may request details of the specific safeguards phpun relies on for international data transfers by contacting phpun's Data Protection Officer using the contact details in Section 14.

phpun retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply as a general guide:

After the applicable retention period expires, phpun will securely delete or irreversibly anonymize the relevant personal data in accordance with its internal data disposal procedures.

phpun uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: Required for the Platform to function correctly — for example, to maintain your login session, remember your language preference, and ensure security features operate properly. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: Used to remember your preferences and personalize your experience on phpun, such as your preferred game lobby view or responsible gaming settings.
• Analytics cookies: Used to collect anonymized, aggregated data about how Players navigate and use the Platform, which helps phpun identify areas for improvement. Analytics data does not identify individual Players.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot activity on the Platform.

phpun does not use third-party advertising or tracking cookies that send your personal data to external advertising networks for the purpose of behavioral profiling or targeted advertising on other websites.

phpun implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and phpun's servers
• Encryption at rest for sensitive personal data stored on phpun's servers, including KYC documents and payment method references
• Hashed password storage — phpun does not store passwords in plain text; passwords are stored using industry-standard cryptographic hashing algorithms
• Access controls — phpun staff access to personal data is restricted on a need-to-know basis with role-based access controls and audit logging
• Two-factor authentication available as an optional additional security layer for Player accounts
• Regular security assessments including vulnerability scanning and penetration testing of Platform infrastructure
• Incident response procedures — in the event of a personal data breach, phpun will notify affected Players and the National Privacy Commission in accordance with the Data Privacy Act of 2012 and NPC Circular 2016-03

While phpun takes all reasonable steps to protect your personal data, no online system is completely immune to security threats. Players are encouraged to maintain strong, unique passwords for their phpun accounts and to enable two-factor authentication.

phpun is strictly for adults aged 21 years and above. phpun does not knowingly collect personal information from individuals under the age of 21. The Platform is not directed at, and should not be accessed by, persons below the legal gambling age in the Philippines.

During account registration, Players are required to confirm their date of birth and agree that they are 21 or older. KYC verification with a Philippine government-issued ID serves as the formal age verification mechanism before withdrawal privileges are activated.

To exercise any of the data rights described in this Privacy Policy — including the right to access, correct, erase, object to processing, or withdraw consent — please contact phpun using the channels set out in Section 14.

When submitting a data rights request, please provide:

• Your full name as registered on your phpun account
• Your registered Philippine mobile number or email address
• A clear description of the right you wish to exercise and, where applicable, the specific data it relates to
• A copy of a valid Philippine government-issued ID, for identity verification purposes

phpun will acknowledge receipt of all data rights requests within five (5) business days and will provide a substantive response within fifteen (15) business days. Where a request is complex or involves a large volume of data, the response period may be extended by a further fifteen (15) business days, in which case phpun will notify you of the extension and the reasons for it.

phpun will not charge a fee for exercising your data rights unless a request is manifestly unfounded or excessive. In such cases, phpun may charge a reasonable administrative fee or decline the request, with written reasons provided.

If you are not satisfied with phpun's response to a data rights request, you have the right to escalate the matter to the National Privacy Commission of the Philippines.

phpun may update this Privacy Policy from time to time to reflect changes in the Platform, applicable law, or phpun's data processing practices. The effective date at the top of this document reflects the date of the most recent revision.

Where changes are material — meaning they significantly affect how your personal data is processed or your rights as a data subject — phpun will notify registered Players by:

• Displaying a notice within the phpun Platform upon next login
• Sending an SMS notification to your registered Philippine mobile number

Minor updates — such as corrections of typographical errors or clarifications that do not materially alter the substance of this Policy — may be made without advance notice. Your continued use of phpun after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree to the updated Privacy Policy, please cease using phpun and contact support to arrange account closure and data handling.

phpun has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. For any privacy-related queries, data rights requests, or concerns, please contact:

• Live Chat: Available 24/7 within your phpun account — fastest channel for urgent privacy concerns
• Email: support phpun.club — for data rights requests and formal privacy complaints; please include "Data Privacy Request" in your subject line

phpun's support team is bilingual in Tagalog and English and is available around the clock. All formal privacy complaints will receive an acknowledgment within 24 hours and a substantive response within fifteen (15) business days.