phfun.com Privacy POLICY PROMISE SHIELD

1. Introduction

1.1 phfun.com is committed to protecting the privacy and personal data of all players who use our platform. We understand that trust is the foundation of any good relationship — and that includes how we handle your information.

1.2 This Privacy Policy applies to all personal data collected through the phfun.com website (phfuncom.org), mobile platform, customer support channels, and any other phfun.com services. It applies to all registered players and visitors to the phfun.com platform.

1.3 phfun.com acts as the Data Controller for all personal data collected through the platform. Our Data Protection Officer (DPO) can be contacted at the email address provided in Section 12 of this Policy.

2. Personal Data We Collect

2.1 phfun.com collects personal data that is necessary to provide our services, comply with legal obligations, and improve the player experience. The categories of data we collect include:

2.2 phfun.com does not collect sensitive personal information (as defined under RA 10173) unless strictly required for legal compliance purposes, such as government-issued ID numbers for KYC verification. Such data is handled with heightened security measures.

3. How We Use Your Personal Data

3.1 phfun.com uses your personal data only for the purposes for which it was collected. Specifically, we use your data to:

• Create and manage your phfun.com account;
• Verify your identity and age (21+ requirement) in compliance with PAGCOR regulations;
• Process deposits and withdrawals through GCash, PayMaya, and Philippine bank transfers;
• Provide customer support and respond to your inquiries;
• Detect, prevent, and investigate fraud, money laundering, and other illegal activities;
• Monitor gaming activity for responsible gaming purposes, including identifying problem gambling patterns;
• Send you account-related notifications (e.g., transaction confirmations, security alerts);
• Send promotional communications, where you have opted in to receive them;
• Comply with our legal and regulatory obligations under Philippine law and PAGCOR requirements;
• Improve the phfun.com platform through analytics and performance monitoring.

3.2 phfun.com will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

4. Legal Basis for Processing

4.1 phfun.com processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms and Conditions you agreed to upon registration (e.g., account management, payment processing);
• Legal Obligation: Processing required to comply with applicable Philippine laws and PAGCOR regulatory requirements (e.g., KYC verification, anti-money laundering reporting);
• Legitimate Interests: Processing necessary for phfun.com's legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your explicit consent, such as receiving marketing communications. You may withdraw consent at any time.

5. Data Sharing & Disclosure

5.1 phfun.com does not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your data only in the following limited circumstances:

• Service Providers: Trusted third-party vendors who assist in operating the phfun.com platform (e.g., payment processors, cloud hosting providers, KYC verification services). These providers are contractually bound to process your data only on our instructions and in compliance with RA 10173;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulatory mandate;
• Law Enforcement: Philippine law enforcement agencies, where required by a valid court order or legal process;
• Business Transfers: In the event of a merger, acquisition, or sale of phfun.com's business assets, your data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

5.2 All third parties with whom phfun.com shares personal data are required to maintain appropriate security measures and to use the data only for the specified purpose.

6. Data Retention

6.1 phfun.com retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

6.2 For active phfun.com accounts, personal data is retained for the duration of the account relationship. For closed or suspended accounts, phfun.com retains personal data for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering regulations and PAGCOR requirements.

6.3 Transaction records, including deposit and withdrawal history, are retained for a minimum of five (5) years as required by the Anti-Money Laundering Act of 2001 (RA 9160, as amended). After the applicable retention period, personal data is securely deleted or anonymized.

7. Cookies & Tracking Technologies

7.1 phfun.com uses cookies and similar tracking technologies (such as web beacons and local storage) to enhance your experience on the platform. A cookie is a small text file placed on your device when you visit phfun.com.

7.2 The types of cookies we use include:

• Essential Cookies: Required for the phfun.com platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against fraudulent activity. These cannot be disabled without affecting platform functionality;
• Performance Cookies: Used to collect anonymized data about how players use phfun.com, such as which pages are visited most frequently and how long sessions last. This data helps us improve the platform;
• Functional Cookies: Used to remember your preferences, such as language settings and game display options, to provide a more personalized experience;
• Analytics Cookies: Used to understand aggregate player behavior and platform performance. Data collected through analytics cookies is anonymized and cannot be used to identify individual players.

7.3 You can control cookie settings through your browser preferences. Please note that disabling essential cookies may affect your ability to use certain features of phfun.com. phfun.com does not use cookies to track your activity on unrelated third-party websites.

8. Data Security

8.1 phfun.com implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• AES-256 encryption for all stored personal and financial data;
• TLS/SSL encryption for all data transmitted between your device and phfun.com servers;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing of the phfun.com platform;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Continuous monitoring for suspicious activity and potential data breaches.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phfun.com will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required under RA 10173. Affected players will be notified without undue delay.

8.3 While phfun.com takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phfun.com login credentials and for ensuring the security of the device you use to access the platform.

9. Your Data Privacy Rights

9.1 Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by phfun.com:

• Right to be Informed: You have the right to be informed about how phfun.com collects and processes your personal data, as described in this Policy;
• Right to Access: You have the right to request a copy of all personal data phfun.com holds about you, along with information about how it is being used;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• 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 our legal retention obligations;
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe phfun.com has violated your data privacy rights.

9.2 To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 12. phfun.com will respond to all verified data subject requests within thirty (30) days of receipt.

10. Children's Privacy

10.1 phfun.com is strictly intended for individuals who are at least twenty-one (21) years of age. phfun.com does not knowingly collect personal data from individuals under the age of 21.

10.2 If phfun.com becomes aware that personal data has been collected from an individual under the age of 21, we will immediately suspend the associated account, delete the personal data, and report the incident as required by applicable law.

10.3 If you are a parent or guardian and believe that your child has registered on phfun.com, please contact us immediately at the email address provided in Section 12 so that we can take appropriate action.

11. Changes to This Privacy Policy

11.1 phfun.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or platform features. The "Last Updated" date at the top of this Policy will be revised accordingly.

11.2 For material changes to this Policy, phfun.com will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect, where reasonably practicable.

11.3 Your continued use of phfun.com following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how phfun.com protects your personal data.

12. Contact Our Data Protection Officer

12.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by phfun.com, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Support Hours: 8:00 AM – 12:00 MN Philippine Standard Time (PHT / GMT+8)
• Platform: phfuncom.org

12.2 phfun.com aims to respond to all data privacy inquiries and requests within thirty (30) days. For urgent matters involving potential data breaches or unauthorized account access, please indicate "URGENT – DATA PRIVACY" in your message subject line for prioritized handling.