phparm Casino — Privacy Policy

1. Who We Are (Data Controller)

1.1 For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, phparm is the Personal Information Controller ("PIC") in respect of personal data collected through the phparm Casino platform at phparm.vip.

1.2 phparm is the operator of the online gaming platform accessible at phparm.vip, serving players primarily located in the Republic of the Philippines. All questions regarding this Privacy Policy or the exercise of your data subject rights should be directed to our Data Protection Officer using the contact information in Section 13 of this Policy.

2. Personal Data We Collect

phparm collects the following categories of personal data in connection with the operation of the phparm platform:

2.1 Sensitive Personal Information. Certain data collected by phparm for KYC and AML compliance purposes, including government-issued ID numbers and financial account details, may constitute Sensitive Personal Information under the DPA. phparm processes such data only to the extent required for legal compliance and platform operation, with appropriate security safeguards.

3. How We Collect Your Personal Data

phparm collects personal data through the following means:

• Directly from you — when you register a phparm Account, complete KYC verification, make deposits or withdrawals, contact customer support, or voluntarily provide information through any Platform feature;
• Automatically — through cookies, log files, and similar technologies when you access and navigate the phparm Platform (see Section 6 on Cookies);
• From payment processors — GCash, Maya, BPI, BDO, and other payment service providers transmit transaction-related data to phparm in connection with deposit and withdrawal processing;
• From identity verification services — where phparm engages third-party KYC or identity verification providers to assist with age and identity verification requirements;
• From fraud prevention and AML monitoring services — data shared with or received from services used to detect, prevent, and investigate fraud and money laundering.

4. Purposes of Processing & Legal Basis

phparm processes your personal data for the following purposes, each supported by an applicable legal basis under RA 10173:

• Account creation and management — to register and maintain your phparm Account, authenticate your phparm Login, and administer your Wallet. Legal basis: performance of contract.
• Payment processing — to process GCash and Maya deposits, BPI and BDO transfers, and all withdrawals from your phparm Wallet. Legal basis: performance of contract; compliance with legal obligation.
• Age verification and KYC compliance — to verify that you are 21 years of age or older and to satisfy PAGCOR-related regulatory requirements and Philippine AML obligations under RA 9160 (Anti-Money Laundering Act). Legal basis: compliance with legal obligation.
• Game delivery and sports betting — to provide the phparm Casino games, live dealer services, bingo, and sportsbook that constitute the core services of the Platform. Legal basis: performance of contract.
• Responsible gaming and player protection — to monitor gaming activity for signs of problem gambling, enforce deposit limits and self-exclusion requests, and fulfil responsible gaming obligations. Legal basis: legitimate interest; compliance with legal obligation.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, collusion, money laundering, and other prohibited conduct on the phparm Platform. Legal basis: legitimate interest; compliance with legal obligation.
• Customer support — to respond to support queries, complaints, and disputes from phparm players. Legal basis: performance of contract; legitimate interest.
• Marketing communications — to send promotional offers, bonus announcements, and phparm platform updates, where you have provided consent or where permitted by law. Legal basis: consent (can be withdrawn at any time).
• Platform improvement and analytics — to analyse Platform usage patterns, identify technical issues, and improve the phparm user experience. Legal basis: legitimate interest.

5. Data Sharing and Disclosure

5.1 phparm does not sell your personal data to any third party under any circumstances.

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

• Payment service providers — GCash, Maya, BPI, BDO, Coins.ph, and other payment processors receive transaction data necessary to process your deposits and withdrawals;
• Identity and KYC verification providers — third-party services engaged to assist with age verification and identity document checking for PAGCOR and AML compliance;
• Game content providers — game software providers whose titles are offered in the phparm Casino lobby may receive anonymised session data for technical support and RNG certification purposes;
• AML and fraud monitoring services — platforms used to screen transactions and accounts against financial crime and fraud indicators;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies to the extent required by law;
• Legal and professional advisers — lawyers, accountants, and auditors engaged by phparm under confidentiality obligations;
• Law enforcement — where phparm is required by Philippine law, court order, or lawful government request to disclose personal data.

5.3 All third-party service providers engaged by phparm as Personal Information Processors (PIPs) are contractually required to process personal data only in accordance with phparm's instructions and in compliance with the DPA.

6. Cookies and Tracking Technologies

6.1 phparm uses cookies and similar tracking technologies on the phparm Platform. Cookies are small data files stored on your device that help phparm operate the Platform, remember your preferences, and analyse usage patterns.

6.2 The types of cookies phparm uses include:

• Strictly necessary cookies — essential for the operation of the phparm Platform, including maintaining your login session after phparm Login and remembering your Wallet state. These cannot be disabled without disrupting platform functionality.
• Functional cookies — remember your preferences such as language settings and recently played games to improve your phparm experience.
• Analytics cookies — collect anonymised information about how players navigate the phparm Platform to help us identify performance issues and improve the user experience.
• Fraud prevention cookies — used to detect and prevent fraudulent access attempts, bot activity, and multiple-account creation.

6.3 You can control cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent you from logging in to your phparm Account or using core platform features.

7. Data Retention

7.1 phparm retains personal data for as long as your phparm Account is active and for a period thereafter as required by applicable Philippine law, including AML record-keeping requirements under RA 9160 (which mandate a minimum retention period of five (5) years following the relevant transaction).

7.2 Following Account closure, phparm will retain Identity Data, Financial Data, and Gaming Data for a minimum of five (5) years, or such longer period as required by applicable PAGCOR regulations or Philippine law.

7.3 Marketing communications data will be retained only as long as you maintain your consent or until you opt out of marketing, at which point it will be deleted or anonymised within thirty (30) days.

7.4 Technical data such as IP address logs may be retained for shorter periods of up to twelve (12) months unless longer retention is required for fraud investigation or legal proceedings.

8. Data Security

8.1 phparm implements technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS encryption for all data transmitted between your device and the phparm Platform;
• Hashing of passwords — phparm staff cannot access your phparm Login password in plaintext;
• Access controls limiting internal access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Firewall and intrusion detection systems protecting phparm servers;
• OTP (one-time PIN) verification for phparm Login on new devices and for sensitive account actions.

8.2 Despite phparm's security measures, no data transmission over the internet or storage system can be guaranteed to be 100% secure. You are responsible for keeping your phparm Login credentials confidential and for using the Platform on secure, private devices and connections.

8.3 Data Breach Notification. In the event of a personal data breach that is likely to result in significant harm to affected data subjects, phparm will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with NPC Circular 16-03.

9. Your Rights as a Data Subject

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by phparm:

• Right to be Informed — to be notified about the manner in which your personal data is being or will be processed, as set out in this Privacy Policy;
• Right to Access — to obtain confirmation of whether phparm holds personal data about you, and to receive a copy of that data;
• Right to Object — to object to the processing of your personal data on legitimate grounds, including processing for direct marketing purposes;
• Right to Erasure — to request deletion of your personal data where phparm no longer has a legitimate purpose or legal obligation to retain it;
• Right to Rectification — to request correction of inaccurate or incomplete personal data held by phparm;
• Right to Data Portability — to receive a structured, commonly used electronic copy of personal data you provided to phparm, where technically feasible;
• Right to File a Complaint — to lodge a complaint with the National Privacy Commission (NPC) if you believe phparm has violated your rights under the DPA.

To exercise any of these rights, contact phparm's Data Protection Officer using the contact information in Section 13. phparm will respond to verified data subject requests within thirty (30) calendar days of receipt, or within such extended period as permitted by the DPA where the request is complex.

10. Protection of Minors

10.1 The phparm Platform is strictly for players aged twenty-one (21) years and older. phparm does not knowingly collect or process personal data from individuals under the age of 21. Age verification is a mandatory step of the phparm Account registration process.

10.2 If phparm discovers or is notified that personal data has been collected from a person under 21, phparm will promptly delete that data and close the associated Account. If you believe a minor has created a phparm Account, please contact our support team immediately.

10.3 Players are reminded to secure their phparm Login credentials and devices to prevent minors in their household from accessing the Platform.

11. Cross-Border Data Transfers

11.1 Some of phparm's third-party service providers — including game content providers, cloud infrastructure providers, and analytics vendors — may be located or store data outside the Republic of the Philippines.

11.2 Where personal data is transferred outside the Philippines, phparm implements appropriate safeguards to ensure that such transfers comply with the DPA and NPC issuances, including contractual clauses requiring overseas recipients to provide a level of protection equivalent to that required under Philippine law.

11.3 Core financial data related to GCash and Maya transactions is processed within payment infrastructure that operates under Philippine regulatory oversight.

12. Updates to This Privacy Policy

phparm may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Material changes will be communicated to players via registered mobile number or prominent notice on the phparm Platform. Your continued use of phparm following the effective date of an updated Policy constitutes acceptance of the revised terms. If you do not agree with the updated Policy, you must discontinue use of the Platform and request Account closure.

13. Contact & Data Protection Officer

For all privacy-related inquiries, data subject rights requests, or to contact phparm's Data Protection Officer, please use the following contact:

Data Protection Officer, phparm Casino

Email: support@phparm.vip — subject line: "Data Privacy Request"

phparm's support team is available 24 hours a day, 7 days a week. Data subject rights requests will be handled by the designated DPO and responded to within the timeframes required by RA 10173 and its Implementing Rules.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Republic of the Philippines if you believe phparm has not adequately addressed a privacy concern. The NPC may be contacted through its official website (search "National Privacy Commission Philippines" — not linked here per site policy).