Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") applies to all personal information collected by phsly through our website, mobile applications, and related services (collectively, the "Platform"). phsly operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and complies with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

This Policy describes:

• What personal information we collect from you and why we collect it.
• How we use, process, and store your personal information.
• With whom we share your information and under what circumstances.
• How we protect your information from unauthorized access or misuse.
• Your rights regarding your personal data and how to exercise those rights.
• Our use of cookies and similar tracking technologies.
• How we handle data transfers and international processing.
• Changes to this Privacy Policy and how we will notify you.

By creating an account, depositing funds, or otherwise using phsly services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein. If you do not agree with this Policy, you must immediately cease using phsly and contact us to close your account.

2. Information We Collect

2.1 Information You Provide to Us

When you register for a phsly account, make deposits or withdrawals, participate in promotions, or contact customer support, you voluntarily provide us with personal information, including:

Category	Examples
Identity Information	Full legal name, date of birth, gender, government-issued ID number, photograph on ID
Contact Information	Email address, phone number, residential address, postal code
Financial Information	Bank account details, GCash/PayMaya account numbers, credit/debit card information, transaction history
Account Credentials	Username, password, security questions and answers
Verification Documents	Government-issued ID (passport, driver's license, PRC ID), proof of address (utility bill, bank statement)
Communication Data	Customer support chat transcripts, emails, feedback, survey responses

2.2 Information We Collect Automatically

When you access or use the phsly Platform, we automatically collect certain technical and usage information through cookies, web beacons, server logs, and similar technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), mobile network information.
• Usage Data: Pages visited, games played, betting history, deposit and withdrawal patterns, session duration, time spent on specific pages, click paths, referral sources.
• Location Data: IP address, geolocation data (with your consent where required), time zone, language preferences.
• Connection Information: Internet service provider, connection speed, network type (Wi-Fi, cellular).

2.3 Information from Third Parties

phsly may receive information about you from third-party sources, including:

• Payment Processors: GCash, PayMaya, banks, and card networks provide transaction confirmation and fraud detection data.
• Identity Verification Services: Third-party identity verification providers confirm your identity and age to comply with regulatory requirements.
• Marketing Partners: Affiliate networks and advertising platforms may provide referral data if you access phsly through a partner link.
• Public Sources: Publicly available information used to verify identity or comply with anti-money laundering (AML) regulations.

3. How We Use Your Information

phsly uses your personal information for the following purposes, all of which are necessary to provide, improve, and protect our services:

3.1 Account Management and Service Delivery

• Create, maintain, and manage your phsly account.
• Verify your identity and age to comply with legal requirements (21+ restriction).
• Process deposits, withdrawals, and other financial transactions.
• Enable you to place bets, play casino games, and participate in promotions.
• Provide customer support and respond to your inquiries.
• Send transactional notifications such as deposit confirmations, withdrawal approvals, and bonus credits.

3.2 Legal and Regulatory Compliance

• Comply with PAGCOR regulations and Philippine gambling laws.
• Fulfill Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations.
• Detect, prevent, and investigate fraud, cheating, money laundering, and other illegal activities.
• Respond to legal requests, court orders, and government investigations.
• Enforce our Terms and Conditions and other policies.
• Maintain records required by law for audit and reporting purposes.

3.3 Platform Improvement and Analytics

• Analyze usage patterns to improve user experience and Platform functionality.
• Conduct research and statistical analysis to enhance game offerings and betting markets.
• Test new features, products, and services before public release.
• Optimize website and mobile app performance, security, and reliability.
• Monitor and diagnose technical issues and system errors.

3.4 Marketing and Communications

• Send promotional emails, SMS messages, and push notifications about bonuses, new games, and special offers (with your consent where required).
• Personalize marketing content based on your gaming preferences and activity history.
• Administer loyalty programs, VIP rewards, and player incentives.
• Conduct surveys and request feedback to improve our services.

3.5 Security and Fraud Prevention

• Protect against unauthorized access, account takeover, and identity theft.
• Monitor for suspicious betting patterns, bonus abuse, and collusion.
• Implement responsible gaming tools and self-exclusion measures.
• Verify payment methods to prevent fraudulent transactions.

4. How We Share Your Information

phsly does not sell your personal information to third parties. However, we may share your information with trusted service providers and partners under the following circumstances:

4.1 Service Providers and Business Partners

We share personal information with third-party vendors who perform services on our behalf, including:

• Payment Processors: GCash, PayMaya, banks, and card networks process your deposits and withdrawals.
• Identity Verification Services: Third-party providers verify your identity and age to comply with regulatory requirements.
• Game Providers: Software providers such as Evolution Gaming, Pragmatic Play, and PG Soft deliver casino games and sports betting platforms.
• Cloud Services: Hosting providers store and process data securely in cloud infrastructure.
• Customer Support Tools: Live chat platforms and helpdesk software enable us to assist you efficiently.
• Marketing and Analytics Services: Email service providers, SMS gateways, and analytics tools help us communicate with you and understand Platform usage.

All service providers are contractually obligated to protect your data, use it only for the purposes specified, and comply with applicable data protection laws.

4.2 Legal and Regulatory Authorities

phsly may disclose your personal information to law enforcement, regulatory bodies, courts, or government agencies when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with legal obligations, court orders, subpoenas, or regulatory investigations.
• Enforce our Terms and Conditions or protect our legal rights.
• Detect, prevent, or address fraud, security breaches, or illegal activities.
• Protect the safety, property, or rights of phsly, our users, or the public.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your personal information may be transferred to the acquiring entity or successor. We will notify you via email or prominent notice on the Platform before your information is transferred and becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your information with third parties when you have given explicit consent, such as participating in co-branded promotions or sharing your achievements on social media.

5. Data Security and Protection

phsly implements industry-standard technical, administrative, and physical security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using SSL/TLS protocols. Sensitive information such as passwords and payment details are encrypted at rest.
• Access Controls: Access to personal information is restricted to authorized employees and service providers who need the information to perform their duties. Access is granted on a need-to-know basis and monitored through audit logs.
• Secure Infrastructure: Our servers and databases are hosted in secure data centers with firewalls, intrusion detection systems, and regular security audits.
• Regular Testing: We conduct vulnerability assessments, penetration testing, and security reviews to identify and address potential threats.
• Employee Training: All phsly employees receive data privacy and security training and are bound by confidentiality obligations.

While we take all reasonable steps to protect your information, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

6. Cookies and Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit the phsly Platform. Cookies help us recognize your device, remember your preferences, and improve your user experience. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device until deleted or expired).

6.2 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly. These cookies enable you to log in, navigate the site, and use secure features. Without these cookies, phsly cannot provide core services.
• Performance Cookies: Collect anonymous information about how you use the Platform, such as which pages you visit most often and whether you encounter errors. This data helps us improve Platform performance.
• Functionality Cookies: Remember your preferences (language, location, username) to provide a personalized experience.
• Advertising Cookies: Track your activity across websites to deliver targeted advertisements based on your interests. These cookies are set by third-party advertising networks.

6.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive a warning before a cookie is stored. However, disabling essential cookies may prevent you from accessing certain features of the Platform. For more information on managing cookies, consult your browser's help documentation.

7. Your Privacy Rights

Under the Data Privacy Act of 2012 and applicable Philippine regulations, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. We will provide this information in a structured, commonly used, and machine-readable format where feasible.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most account information directly through your phsly account settings.

7.3 Right to Erasure

You have the right to request deletion of your personal information under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. However, we may retain certain information to comply with legal obligations, resolve disputes, or enforce our Terms and Conditions.

7.4 Right to Restrict Processing

You have the right to request that we limit how we use your personal information in certain situations, such as when you contest the accuracy of the data or object to processing.

7.5 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes. You can opt out of marketing communications at any time by clicking the unsubscribe link in emails or adjusting your notification preferences in your account settings.

7.6 Right to Data Portability

You have the right to receive your personal information in a portable format and to transmit it to another service provider where technically feasible.

7.7 Right to Withdraw Consent

Where we rely on your consent to process personal information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing prior to withdrawal.

7.8 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer via email at [email protected] or through live chat support. We will respond to your request within 30 days and may request additional information to verify your identity before processing your request.

8. Data Retention

phsly retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods vary depending on the type of data and regulatory requirements:

• Account Information: Retained for the duration of your account plus 5 years after account closure to comply with PAGCOR and AML regulations.
• Transaction Records: Retained for 5 years after the transaction date as required by Philippine law.
• Communications: Customer support chat transcripts and emails are retained for 3 years for quality assurance and dispute resolution purposes.
• Marketing Data: Retained until you withdraw consent or request deletion, after which it is deleted within 90 days.

After the retention period expires, we securely delete or anonymize your personal information so that it can no longer be associated with you.

9. International Data Transfers

phsly primarily stores and processes personal information within the Philippines. However, some of our service providers and business partners may be located outside the Philippines, which means your personal information may be transferred to, stored in, or accessed from countries with different data protection laws. When we transfer data internationally, we ensure that appropriate safeguards are in place, such as:

• Standard contractual clauses approved by the National Privacy Commission.
• Data processing agreements requiring third parties to comply with Philippine data protection standards.
• Certification under recognized international data protection frameworks.

By using phsly, you consent to the transfer of your personal information to countries outside the Philippines under these safeguards.

10. Children's Privacy

phsly is intended solely for individuals aged 21 and older. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have collected personal information from someone under 21, we will take immediate steps to delete that information and close the associated account. Parents or guardians who believe their child has provided personal information to phsly should contact us immediately at [email protected].

11. Changes to This Privacy Policy

phsly reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated Privacy Policy on the Platform with a new "Last Updated" date.
• Sending an email notification to the address associated with your account.
• Displaying a prominent notice on the Platform homepage or upon login.

Your continued use of phsly after changes are posted constitutes acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information.

12. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 through the phsly Platform
• Mailing Address: phsly Data Protection Officer, Manila, Philippines

We are committed to resolving privacy concerns promptly and fairly. If you believe we have not adequately addressed your concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.