phchas Privacy Policy

1. Introduction

phchas ("phchas", "we", "us", "our") operates the online gaming and sports betting platform accessible at phchas.club (the "Platform"). We are committed to protecting the privacy and personal data of all players and visitors who interact with the Platform.

This Privacy Policy ("Policy") describes how phchas collects, uses, stores, shares, and protects personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and the implementing rules and regulations issued by the National Privacy Commission ("NPC"). It also reflects the data-related obligations imposed on phchas by PAGCOR as part of its online gaming licensing framework.

By registering an account on phchas.club, accessing the Platform, or using any phchas service, you consent to the collection and processing of your personal data as described in this Policy. If you do not agree, you must discontinue use of the Platform.

This Policy should be read alongside the phchas Terms & Conditions and Responsible Gaming Policy, which together constitute the complete agreement governing your use of the Platform.

2. Definitions

• "Personal Data" means any information that directly or indirectly identifies a natural person, including name, mobile number, date of birth, address, financial details, and device identifiers.
• "Sensitive Personal Information" means personal data about an individual's race, ethnic origin, marital status, age, color, religious affiliations, health, education, genetic or sexual life, legal proceedings, and government identifiers including Philippine passport numbers, PhilSys IDs, driver's license numbers, and Social Security System numbers.
• "Data Subject" means the individual to whom personal data relates — in this context, the registered phchas player or Platform visitor.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "NPC" means the National Privacy Commission of the Republic of the Philippines.
• "PAGCOR" means the Philippine Amusement and Gaming Corporation, the regulatory authority overseeing phchas operations.
• "KYC" means Know Your Customer verification, the process by which phchas verifies the identity of registered players before processing withdrawals.

3. Information We Collect

phchas collects personal data through several channels. The categories of data collected are described below.

3.1 Registration & Account Data

When you create a phchas account, we collect:

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (for age verification — 21+ requirement)
• Residential address in the Philippines
• Philippine mobile number (primary account identifier)
• Email address (optional but recommended for account recovery)
• Username selected at registration
• Account password (stored in hashed, non-reversible form — phchas never stores plaintext passwords)

3.2 KYC & Identity Verification Data

Before processing your first withdrawal, phchas requires:

• A copy of a valid Philippine government-issued photo ID (PhilSys National ID, Passport, SSS ID, UMID, Driver's License, or Voter's ID)
• A selfie photograph for liveness verification
• Proof of payment method ownership (e.g., screenshot of registered GCash or bank account showing your name)
• Source-of-funds documentation for large deposits where required by anti-money laundering procedures

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts, dates, and payment channel used (GCash, PayMaya, BPI, BDO, Metrobank)
• GCash or PayMaya account number / bank account number associated with transactions
• Bonus history, wagering activity, and balance records
• Full transaction history maintained for regulatory and audit purposes

3.4 Gameplay & Betting Data

• Game sessions played, bet amounts, game outcomes, and session duration
• Sports betting selections, odds accepted, and bet settlement results
• Game preferences inferred from activity patterns (used for personalized lobby recommendations)

3.5 Technical & Device Data

• IP address at login and during active sessions
• Device type, operating system, and browser version
• Mobile network carrier (Globe, Smart, DITO, etc.)
• Geolocation data (country/region level) for regulatory compliance
• Session logs including login timestamps and duration

3.6 Communications Data

• Records of live chat conversations with phchas support staff
• Email correspondence with phchas
• Responses to surveys or promotional communications where you have opted in

4. How We Use Your Personal Data

phchas uses the personal data we collect for the following purposes:

5. Legal Basis for Processing

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

• Consent: Processing for marketing communications, optional profile features, and survey participation is based on your freely given, specific, and informed consent. You may withdraw consent for marketing at any time through your account settings or by contacting support.
• Contractual Necessity: Processing required to provide the gaming services, manage your account, process payments, and deliver customer support is necessary for the performance of our contract with you as established by the phchas Terms & Conditions.
• Legal Obligation: Processing for KYC, anti-money laundering compliance, PAGCOR regulatory reporting, age verification, and NPC-mandated data practices is required by Philippine law and cannot be refused without affecting your ability to use the Platform.
• Legitimate Interests: Processing for fraud prevention, platform security, session monitoring, and responsible gaming risk assessment is conducted on the basis of phchas's legitimate interest in operating a safe, secure, and legally compliant platform, provided such interests are not overridden by your fundamental rights and freedoms.

6. Data Sharing & Disclosure

phchas does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• PAGCOR and Philippine Regulatory Authorities: Transaction records, player identity data, and suspicious activity reports are disclosed to PAGCOR as required under phchas's operating license and applicable Philippine gaming regulations.
• Anti-Money Laundering Council (AMLC): phchas is subject to AMLA reporting obligations and will disclose transaction data to the AMLC where required by law without prior notice to the player.
• Payment Processors: GCash, PayMaya, BPI, BDO, and Metrobank receive transaction data strictly necessary to process deposits and withdrawals. These providers operate under their own privacy policies and applicable Philippine financial regulations.
• KYC and Identity Verification Providers: Third-party identity verification services may process your ID document images and selfie data solely for the purpose of verifying your identity. These providers are contractually bound to process data only for KYC purposes.
• Game Providers: JILI Games, PG Soft, Pragmatic Play, and other licensed game providers may receive anonymized session and gameplay data necessary to deliver their games. No directly identifying personal data is shared with game providers beyond what is technically required to establish a game session.
• Law Enforcement and Courts: phchas will disclose personal data to law enforcement agencies, courts, or other government bodies in the Philippines when required to do so by a valid legal order, warrant, or other compulsory legal process.
• Professional Advisers: Legal, accounting, and audit professionals engaged by phchas may access personal data strictly as necessary for their advisory services, subject to professional confidentiality obligations.

7. Cookies & Tracking Technologies

phchas.club uses cookies and similar tracking technologies to operate the Platform, maintain your login session, and improve your experience. The following types of cookies are used:

• Strictly Necessary Cookies: Required for core Platform functions including login session management, account authentication, and security. These cannot be disabled without breaking the Platform's core functionality.
• Functional Cookies: Store your preferences such as language settings, lobby layout choices, and game category filters. These persist across sessions for convenience.
• Analytics Cookies: Collect anonymized usage data to help phchas understand how players navigate the Platform, which features are most used, and where technical issues occur. This data is aggregated and not linked to individual identities.
• Security Cookies: Used for fraud detection and bot mitigation, including verifying that a login attempt originates from a real user on a recognized device.

You can manage cookie preferences through your browser settings. Disabling functional cookies may limit certain personalization features but will not prevent you from accessing core gaming and account services.

8. Data Retention

phchas retains personal data for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes. The following retention periods apply:

• Account data (active accounts): Retained for the lifetime of the active account.
• Account data (closed accounts): Retained for a minimum of 7 years following account closure to comply with PAGCOR licensing requirements and Philippine anti-money laundering laws.
• KYC documents: Retained for a minimum of 5 years from the date of verification or from the date of the last transaction, whichever is later, as required under the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of 10 years as required by Philippine financial regulations applicable to PAGCOR-licensed operators.
• Communication records (live chat, email): Retained for 3 years from the date of the last communication.
• Marketing consent records: Retained for as long as consent is active and for 3 years following withdrawal of consent to demonstrate compliance.

Upon expiry of applicable retention periods, phchas will securely delete or irreversibly anonymize personal data in accordance with NPC guidelines.

9. Data Security

phchas implements technical and organizational security measures appropriate to the risks associated with processing personal data in the online gaming environment. Key security measures include:

• 256-bit Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and phchas.club
• Encrypted storage of account passwords using industry-standard one-way hashing algorithms — phchas never stores or has access to your plaintext password
• Segregated storage of KYC documents in access-controlled secure environments separate from general account data
• Two-factor authentication (SMS OTP) available to all players and required for high-value transactions
• Automated fraud monitoring and anomalous login detection systems
• Regular security audits and penetration testing of Platform infrastructure
• Staff training on data protection obligations and strict access controls limiting which personnel can access player data

10. Your Privacy Rights

Under the Data Privacy Act of 2012, all Filipino players have the following rights with respect to their personal data held by phchas. These rights may be exercised by contacting phchas's Data Protection Officer as described in Section 16.

• Right to be Informed: You have the right to know whether phchas holds personal data about you, the purposes for which it is processed, and the categories of data held.
• Right to Access: You may request a copy of the personal data phchas holds about you, together with information about how it is being processed.
• Right to Rectification: You may request correction of any personal data that is inaccurate, incomplete, or outdated. Certain account details (such as your legal name and date of birth) may require re-submission of identity documents to update.
• Right to Erasure: You may request deletion of your personal data where processing is no longer necessary for the original purpose, where you withdraw consent (where consent is the legal basis), or where processing is unlawful. This right is subject to phchas's legal obligations to retain data under PAGCOR licensing requirements and anti-money laundering laws, which may prevent full erasure during applicable retention periods.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. objections to marketing communications can be actioned immediately through account settings.
• Right to Data Portability: You may request your personal data in a structured, commonly used, and machine-readable format where technically feasible and where processing is based on consent or contractual necessity.
• Right to Restrict Processing: You may request that phchas restricts processing of your data to storage only, pending resolution of a dispute over accuracy, lawfulness, or a pending objection.
• Right to File a Complaint: If you believe phchas has violated your privacy rights, you may file a complaint with the National Privacy Commission of the Philippines.

11. Children's Privacy

phchas.club is strictly prohibited for use by anyone under 21 years of age, consistent with PAGCOR's minimum age requirements for online casino participation in the Philippines. phchas does not knowingly collect personal data from individuals under 21. Age verification is performed as part of the account registration and KYC process.

If phchas becomes aware that personal data of an individual under 21 has been collected, the account will be immediately suspended, all associated data will be securely deleted to the extent permitted by law, and the matter will be referred to PAGCOR if required. If you believe an underage individual has registered on the Platform, please contact phchas support or our Data Protection Officer immediately.

12. International Data Transfers

phchas primarily processes player data within the Philippines. Where data is transferred to service providers or game platform infrastructure hosted outside the Philippines — for example, for cloud storage, game delivery networks, or KYC processing — phchas ensures that such transfers comply with the cross-border data transfer requirements of the Data Privacy Act of 2012 and are subject to appropriate data protection safeguards.

Where data is transferred to countries that do not provide an equivalent level of data protection to Philippine law, phchas puts in place appropriate contractual protections (such as standard contractual clauses or data processing agreements requiring recipient compliance with equivalent data protection standards) before any transfer occurs.

13. Third-Party Services

phchas.club may contain functional integrations with third-party services including payment processors (GCash, PayMaya, BPI, BDO, Metrobank) and licensed game providers (JILI, PG Soft, Pragmatic Play, and others). These third parties operate under their own privacy policies and are independent data controllers in respect of data they collect directly through their own systems.

phchas is not responsible for the privacy practices of third-party services. When you interact with a third-party payment gateway or game provider interface, we encourage you to review that provider's privacy policy to understand how your data is handled in their systems.

14. Responsible Gaming & Data Processing

phchas processes gameplay and transaction data as part of its responsible gaming obligations under PAGCOR's framework. This includes monitoring for behavioral patterns that may indicate problem gambling — such as rapidly increasing deposit frequency, extended uninterrupted sessions, or chasing-loss betting patterns.

Where such patterns are detected, phchas may proactively reach out to the player with responsible gaming resources or, in serious cases, apply temporary account restrictions as a protective measure. This processing is conducted on the legal basis of legitimate interests — specifically phchas's obligation and genuine commitment to player welfare — and is a condition of its PAGCOR operating license.

Data related to voluntary responsible gaming tool usage — including deposit limits set, cooling-off periods requested, and self-exclusion applications — is stored securely and treated with heightened sensitivity. This data is never used for marketing profiling and is only accessed by the phchas responsible gaming team for protective purposes.

Learn more about the tools available to you on the Responsible Gaming page. Sumugal nang may responsibilidad.

15. Amendments to This Policy

phchas reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, PAGCOR requirements, or NPC guidance. When material changes are made, phchas will notify registered players via the mobile number or email address associated with their account, and will post the updated Policy on phchas.club with a revised "Last Updated" date.

Your continued use of the Platform following the effective date of an amended Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed of any updates.

16. Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phchas, please contact our Data Protection Officer through the following channels:

• Live Chat: Available 24/7 on phchas.club — select "Privacy" as your inquiry type. Filipino and English support available.
• Email (Privacy Requests): support@phchas.club — mark the subject line "Privacy Request / Data Subject Rights." Responses within 3 business days for standard requests; within 15 business days for complex subject access requests.

If you are not satisfied with our response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC), the independent regulatory authority for data protection matters in the Philippines.