phky Privacy Policy

phky ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every individual who accesses or uses the phky online gaming platform at phky.app. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This policy applies to all users of the phky platform, including registered players, visitors who browse the platform without registering, and any other individuals whose personal data phky processes in connection with the operation of its services. It covers data collected through the phky website, any associated mobile applications, and all related digital touchpoints.

This Privacy Policy should be read alongside phky's Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and phky. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters relating to personal data, this Privacy Policy shall prevail.

We encourage you to read this policy carefully and in full. If you have any questions about how phky handles your personal data, please contact our Data Protection Officer using the details provided in Section 14 of this policy.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, phky is the Personal Information Controller (PIC) in respect of the personal data it collects and processes in connection with the operation of the phky platform.

As the Personal Information Controller, phky determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data privacy law and this Privacy Policy.

Where phky engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and cloud infrastructure providers — those parties act as Personal Information Processors (PIPs) and are contractually bound to process your data only in accordance with phky's instructions and applicable law.

phky has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data privacy regulations. The DPO's contact details are provided in Section 14 of this policy.

phky collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include the following:

phky does not intentionally collect sensitive personal information as defined under RA 10173 (such as health data, religious beliefs, or political affiliations) unless it is strictly necessary for a specific regulatory purpose and you have provided explicit consent. Where such data is collected, it will be handled with the heightened protections required by law.

phky collects personal data through the following means:

• Direct Collection: Information you provide when you register for a phky account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions and surveys.
• Automated Collection: Technical and usage data collected automatically when you access the phky platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 8 for more details on our use of cookies.
• Third-Party Sources: Identity and fraud-related data received from third-party KYC verification providers, payment processors, and fraud prevention services that phky engages to verify your identity and protect the integrity of the platform.
• Regulatory Sources: In certain circumstances, phky may receive information about players from PAGCOR or other regulatory authorities as part of its compliance obligations, including information relating to self-exclusion registers.

phky uses the personal data it collects for the following purposes:

• Account Management: To create, maintain, and manage your phky player account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Service Delivery: To provide you with access to phky's gaming services, process your deposits and withdrawals, credit bonuses to your account, and deliver the core functionality of the platform.
• KYC and Regulatory Compliance: To verify your identity and age (21+) as required by PAGCOR regulations, to conduct anti-money laundering (AML) checks, and to comply with all applicable Philippine laws and regulatory requirements.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal or prohibited conduct on the phky platform.
• Customer Support: To respond to your inquiries, resolve disputes, process complaints, and provide technical assistance through phky's support channels.
• Responsible Gaming: To monitor gaming patterns and identify potential problem gambling behavior, to enforce deposit limits, cooling-off periods, and self-exclusion requests, and to fulfill phky's responsible gaming obligations.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the phky platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may withdraw this consent at any time.
• Legal Obligations: To comply with court orders, regulatory directives, and other legal obligations that require phky to process or disclose personal data.

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

• Contractual Necessity: Processing that is necessary for the performance of the contract between you and phky — specifically, the Terms & Conditions you agreed to upon registration. This includes account management, payment processing, and service delivery.
• Legal Obligation: Processing that is required for phky to comply with its legal and regulatory obligations under Philippine law, including PAGCOR licensing requirements, AML regulations, and the Data Privacy Act itself.
• Legitimate Interests: Processing carried out for phky's legitimate business interests, including fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Where phky relies on consent as the legal basis for processing, it will maintain records of that consent and will not use your data for the consented purpose after consent has been withdrawn.

phky does not sell, rent, or trade your personal data to any third party for commercial purposes. phky may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals. These providers receive only the data necessary to complete the transaction.
• KYC and Identity Verification Providers: Third-party identity verification services engaged by phky to verify your identity and age as required by PAGCOR regulations.
• Fraud Prevention Services: Specialist fraud detection and AML screening providers who assist phky in identifying and preventing fraudulent activity on the platform.
• Cloud and Infrastructure Providers: Technology service providers who host and operate the phky platform's infrastructure. These providers act as Personal Information Processors and are contractually bound to process data only on phky's instructions.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law, regulation, or court order.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by phky, subject to strict confidentiality obligations.

All third parties with whom phky shares personal data are required to maintain appropriate technical and organizational security measures and to process personal data only in accordance with phky's instructions and applicable Philippine data privacy law.

phky uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device when you visit the phky website. The following types of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the phky platform to function correctly. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymized information about how players use the phky platform, such as which pages are visited most frequently and whether error messages are received. This data helps phky improve the platform experience.
• Functional Cookies: These cookies allow the phky platform to remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience.
• Marketing Cookies: These cookies are used to deliver promotional content that is relevant to your interests. They are only placed with your consent and can be withdrawn at any time through your browser settings or the phky cookie preference center.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phky platform. For more information on managing cookies, refer to your browser's help documentation.

phky retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Active Account Data: Personal data associated with an active phky account is retained for the duration of the account's existence and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AML regulations.
• Transaction Records: Records of deposits, withdrawals, and betting activity are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC Documents: Identity verification documents are retained for the period required by applicable law, which is generally five (5) years from the date of account closure or the last transaction, whichever is later.
• Support Communications: Customer support records are retained for a period of three (3) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing Data: Data processed on the basis of consent for marketing purposes is retained until you withdraw your consent or for a maximum of two (2) years from the date of last engagement, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with phky's data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected from further processing until deletion is possible.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by phky:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, stored, and shared. This Privacy Policy fulfills phky's obligation to inform you.
• Right of Access: You have the right to request a copy of the personal data that phky holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data that phky holds about you. You may update certain account details directly through your phky account settings.
• 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 phky's legal and regulatory retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to phky's overriding legitimate grounds.
• 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, and to request that it be transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that phky has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact phky's Data Protection Officer using the contact details provided in Section 14. phky will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. In complex cases, this period may be extended by a further fifteen (15) business days, and you will be notified accordingly.

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

• Encryption: All data transmitted between your device and the phky platform is encrypted using Transport Layer Security (TLS) protocols. Sensitive data at rest is encrypted using industry-standard encryption algorithms.
• Access Controls: Access to personal data within phky's systems is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data privacy training.
• Secure Payment Processing: phky does not store full payment card details or complete bank account numbers on its servers. Payment data is handled exclusively by certified payment processors who maintain their own security certifications.
• Regular Security Assessments: phky conducts regular security assessments, vulnerability scans, and penetration testing to identify and address potential security weaknesses in the platform.
• Incident Response: phky maintains a documented data breach response procedure. In the event of a personal data breach, phky will notify affected players and the National Privacy Commission within the timeframes required by RA 10173.

While phky takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your phky account credentials and for notifying phky immediately if you suspect unauthorized access to your account.

The phky platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. phky does not knowingly collect personal data from individuals under the age of 21.

If phky becomes aware that it has inadvertently collected personal data from an individual under the age of 21, it will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be handled in accordance with phky's Terms & Conditions and applicable regulatory requirements.

If you are a parent or guardian and believe that your child has registered on the phky platform or provided personal data to phky without your consent, please contact our Data Protection Officer immediately using the details in Section 14. phky will investigate and take appropriate action promptly.

phky reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this policy, phky will notify registered players by email and/or through a prominent notice on the phky platform at least 7 days before the changes take effect.

The date of the most recent update to this Privacy Policy is displayed at the top of this page. We encourage you to review this policy periodically to stay informed about how phky protects your personal data. Your continued use of the phky platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes.

If any amendment to this Privacy Policy materially affects the way phky processes your personal data in a manner that requires your consent, phky will seek your consent before the amended processing begins.

If you have any questions, concerns, or requests relating to this Privacy Policy or phky's handling of your personal data, please contact our Data Protection Officer (DPO). The DPO is responsible for overseeing phky's compliance with the Data Privacy Act of 2012 and this Privacy Policy.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe that phky has violated your data privacy rights. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012.

For general account support, responsible gaming assistance, or other non-privacy matters, please contact phky's customer support team through the live chat feature available on the phky platform, which is staffed around the clock by Filipino agents ready to assist you in English.