phfum Privacy Policy – How We Protect Your Personal Data

1. Introduction

1.1 This Privacy Policy applies to all personal data collected by phfum through the phfum.net website, mobile browser interface, and any related services (collectively, the "Platform").

1.2 phfum operates in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its implementing rules and regulations. phfum has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with this policy and applicable data protection laws.

1.3 This policy should be read alongside our Terms & Conditions, which govern your use of the phfum Platform. Capitalized terms not defined herein have the meanings given in the Terms & Conditions.

1.4 If you have questions about this Privacy Policy or how phfum handles your personal data, please contact us at the details provided in Section 13.

2. Personal Data We Collect

2.1 phfum collects personal data that you provide directly, data generated through your use of the Platform, and data received from third parties where permitted by law.

2.2 phfum does not collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data beyond what is required for KYC purposes.

2.3 You are not required to provide all requested information, but failure to provide mandatory data (such as identity and contact information) may prevent you from registering or using certain phfum services.

3. How We Use Your Personal Data

3.1 phfum uses your personal data for the following purposes:

• Account Management: To create, maintain, and secure your phfum account, including identity verification and KYC compliance;
• Service Delivery: To process deposits and withdrawals, provide access to games, and deliver the services you request;
• Regulatory Compliance: To comply with anti-money laundering (AML) obligations, age verification requirements, and reporting obligations under Philippine law;
• Responsible Gaming: To monitor gaming patterns, identify potential problem gambling behavior, and administer self-exclusion and limit-setting tools;
• Customer Support: To respond to your inquiries, resolve disputes, and improve our support services;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other prohibited conduct;
• Platform Improvement: To analyze usage patterns and improve the phfum Platform's features, performance, and user experience;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications.

3.2 phfum will not use your personal data for any purpose incompatible with those listed above without first obtaining your consent or as otherwise permitted by law.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform our contract with you (i.e., providing the phfum gaming platform and related services);
• Legal Obligation: Processing required to comply with applicable laws, including AML regulations, gaming regulations, and tax reporting requirements;
• Legitimate Interests: Processing necessary for phfum's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications. You may withdraw consent at any time.

5. Data Sharing & Disclosure

5.1 phfum does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients only as necessary:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your transactions;
• KYC & Identity Verification Providers: Third-party services that assist phfum in verifying your identity and complying with AML obligations;
• Game Software Providers: Licensed game studios whose software powers phfum's game library, to the extent necessary for game operation and auditing;
• Regulatory Authorities: Philippine government agencies and regulators, where disclosure is required by law or court order;
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers operating under strict data processing agreements;
• Professional Advisors: Legal, accounting, and auditing firms, subject to professional confidentiality obligations.

5.2 All third-party service providers engaged by phfum are contractually required to process personal data only on phfum's instructions and in accordance with applicable data protection laws.

5.3 phfum may disclose personal data if required to do so by law, regulation, legal process, or governmental request, or where disclosure is necessary to protect the rights, property, or safety of phfum, its players, or the public.

6. Cookies & Tracking Technologies

6.1 phfum uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze Platform usage.

6.2 phfum uses the following types of cookies:

• Essential Cookies: Required for the Platform to function. These cannot be disabled without affecting core functionality (e.g., session management, login state);
• Analytics Cookies: Help phfum understand how players use the Platform, which pages are most visited, and where improvements can be made;
• Preference Cookies: Remember your settings and preferences (e.g., language, display options) to personalize your experience;
• Security Cookies: Used to detect and prevent fraudulent activity and unauthorized access.

6.3 You can control cookie settings through your browser. Note that disabling certain cookies may affect the functionality of the phfum Platform. phfum does not use cookies to serve third-party advertising.

7. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and phfum servers;
• Encrypted storage of sensitive data including passwords (hashed) and financial information;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication options for player accounts.

7.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phfum will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

8. Data Retention

8.1 phfum retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods include:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by AML regulations;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming History: Retained for a minimum of three (3) years;
• Support Communications: Retained for two (2) years from the date of the last communication;
• Marketing Consent Records: Retained until consent is withdrawn and for one (1) year thereafter.

8.2 When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, phfum will securely delete or anonymize the data.

9. Your Data Subject Rights

9.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phfum:

• Right to be Informed: The right to know what personal data phfum collects and how it is used;
• Right of Access: The right to request a copy of the personal data phfum holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

9.2 To exercise any of the above rights, please contact phfum's Data Protection Officer at [email protected]. phfum will respond to all verified data subject requests within fifteen (15) business days, in accordance with the requirements of the Data Privacy Act of 2012.

9.3 phfum may need to verify your identity before processing a data subject request. This is to ensure that personal data is not disclosed to unauthorized parties.

10. Children's Privacy

10.1 The phfum Platform is strictly intended for persons aged 21 years and above. phfum does not knowingly collect personal data from individuals under the age of 21.

10.2 If phfum becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all associated data will be deleted, and any deposits will be returned to the originating payment method.

10.3 If you believe a minor has registered on the phfum Platform, please contact our support team immediately at [email protected] so that we can take prompt action.

11. International Data Transfers

11.1 phfum's primary data processing operations are based in the Philippines. In some cases, personal data may be transferred to and processed by service providers located outside the Philippines, including game software providers and cloud infrastructure partners.

11.2 Where personal data is transferred outside the Philippines, phfum ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require recipients to apply data protection standards equivalent to those required under Philippine law.

11.3 By using the phfum Platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of phfum's services, subject to the safeguards described in this section.

12. Updates to This Privacy Policy

12.1 phfum reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The date of the most recent revision is displayed at the top of this page.

12.2 Where changes are material, phfum will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect. Your continued use of the phfum Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

12.3 We encourage you to review this Privacy Policy periodically to stay informed about how phfum protects your personal data. The current version is always available at phfum.net/privacy-policy.

13. Contact & Data Protection Officer

13.1 If you have any questions, concerns, or requests regarding this Privacy Policy or phfum's data practices, please contact our Data Protection Officer:

13.2 Our support team is available 24/7, including Philippine public holidays. We aim to acknowledge all privacy-related inquiries within two (2) business days and resolve them within fifteen (15) business days.

13.3 If you are not satisfied with phfum's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC and how to file a complaint is available through official Philippine government channels.