Privacy Policy — phfhun

1Introduction

Welcome to phfhun. This Privacy Policy describes how phfhun ("we," "us," or "our") collects, uses, processes, stores, and protects the personal information of players and visitors ("you" or "your") who access or use the phfhun online casino and sports betting platform at phfhun.net.

phfhun is committed to protecting your privacy in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as overseen by the National Privacy Commission (NPC). As a PAGCOR-licensed gaming operator serving Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and beyond, we take our data protection obligations seriously.

By registering an account, accessing the phfhun platform, or using any of our services — including slots, live dealer games, bingo, crash games, and sports betting — you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree, please do not use the phfhun platform.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, both of which form part of your agreement with phfhun.

2Legal Basis for Processing

phfhun processes your personal data on one or more of the following legal bases, as established under the Philippine Data Privacy Act of 2012 and applicable NPC regulations:

3Personal Data We Collect

phfhun collects personal data at various points during your interaction with our platform. The categories of data we collect are described below:

3.1 Registration & Identity Data

• Full legal name, date of birth, and gender
• Philippine residential address (province, city/municipality, barangay, ZIP)
• Valid government-issued ID details (PhilSys, passport, driver's license, UMID, SSS ID, PRC ID)
• Philippine mobile number and email address
• Username and encrypted account password

3.2 KYC & Verification Data

• Scanned or photographed copies of government-issued photo IDs
• Liveness selfie images for identity confirmation
• Proof of address documents (utility bills, bank statements, barangay certificates)
• Source-of-funds declarations where required for enhanced due diligence

3.3 Financial & Transaction Data

• GCash, Maya, GrabPay, Coins.ph, and QR Ph account references (no full wallet credentials stored)
• BPI, BDO, Metrobank, or other bank account details used for deposits and withdrawals
• USDT TRC20 wallet addresses
• Transaction history: deposit amounts, withdrawal requests, game wagers, and winnings — all in Philippine Peso (₱)

3.4 Gaming & Behavioral Data

• Game session logs: game type, wager amounts, outcomes, session duration, and timestamps
• Responsible gaming tool usage: deposit limits set, self-exclusion periods, cooling-off activations
• Bonus claims, promotional activity, and tournament participation records

3.5 Technical & Device Data

• IP address and approximate geolocation (province/city level)
• Device type, operating system, browser type and version
• Session cookies, login timestamps, and platform navigation patterns
• Customer support chat logs and email correspondence

4How We Use Your Personal Data

phfhun uses your personal data strictly for the following purposes, each grounded in a legitimate legal basis as described in Section 2:

• Account Management: Creating, maintaining, and securing your phfhun player account — including password recovery, device recognition, and session management.
• Identity Verification (KYC): Confirming your age (21+), identity, and eligibility to play on the phfhun platform, as required by PAGCOR licensing conditions.
• Payment Processing: Facilitating deposits and withdrawals in Philippine Peso via GCash, Maya, BPI, BDO, Metrobank, and other supported payment channels. We do not store full payment credentials.
• Game Delivery: Providing access to slots, live dealer tables, crash games, bingo, and sports betting markets — including personalizing your game lobby based on play history.
• Fraud Prevention & Security: Detecting suspicious login attempts, unusual transaction patterns, bonus abuse, multi-accounting, and other fraudulent activities that may harm phfhun or other players.
• AMLA Compliance: Monitoring transactions for Anti-Money Laundering Act (RA 9160) compliance and filing mandatory reports with the Anti-Money Laundering Council (AMLC) where required by law.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and enabling responsible gaming tools (deposit limits, self-exclusion) at your request or where required by PAGCOR.
• Customer Support: Responding to your queries, resolving disputes, and processing complaints through live chat and email support.
• Marketing Communications: Sending promotional offers, bonus notifications, and tournament updates — only where you have given explicit consent and only via channels you have opted in to. You can opt out at any time.
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve game selection, platform performance, and user experience on phfhun.
• Legal & Regulatory Compliance: Fulfilling phfhun's obligations under PAGCOR licensing conditions, NPC regulations, Philippine tax law, and any lawful order from a competent Philippine authority.

5Data Sharing & Third Parties

phfhun does not share your personal data with third parties except in the following circumstances, each of which is governed by strict data processing agreements or legal obligations:

• PAGCOR and Regulatory Authorities: phfhun is required to share player data with PAGCOR as part of its licensing obligations, including player activity reports, KYC records, and AML disclosures as mandated by Philippine law.
• Anti-Money Laundering Council (AMLC): Transaction reports and suspicious activity reports (SARs) are filed with the AMLC in compliance with RA 9160 (Anti-Money Laundering Act) and its amendments.
• KYC & Identity Verification Providers: Third-party identity verification services may process your ID images and liveness data on phfhun's behalf under strict data processing agreements aligned with RA 10173.
• Payment Processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other payment service providers receive only the transaction data necessary to process your deposits and withdrawals.
• Game Content Providers: Third-party game developers whose titles appear on phfhun may receive anonymized game session data (e.g., wager amounts, game outcomes) for RTP auditing and game performance purposes. No personally identifiable information is shared with game developers without your knowledge.
• Cloud Infrastructure Providers: phfhun uses secure cloud hosting services with servers operating under data processing agreements that include adequate safeguards for personal data protection.
• Law Enforcement: phfhun may disclose your personal data to Philippine law enforcement agencies, courts, or government bodies where required by a lawful order, subpoena, or court judgment.

6Cookies & Tracking Technologies

phfhun uses cookies and similar tracking technologies to operate the platform, maintain your session, prevent fraud, and (with your consent) analyze usage patterns. The following categories of cookies are used on phfhun.net:

You may manage your cookie preferences at any time through your phfhun account settings or your browser's built-in privacy controls. Disabling strictly necessary cookies will affect the functionality of the phfhun platform.

7Data Retention

phfhun retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal and regulatory retention obligations under Philippine law:

• Active Account Data: Retained for the duration of your phfhun account's active status plus a minimum of five (5) years after account closure, in compliance with PAGCOR licensing and AMLA record-keeping requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of submission, or longer if required by a specific PAGCOR directive, NPC regulation, or ongoing legal proceeding.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act (RA 9160) and PAGCOR's record-keeping standards.
• Customer Support Logs: Retained for three (3) years from the date of the interaction for dispute resolution and quality assurance purposes.
• Marketing Preferences: Retained until you withdraw your consent or close your phfhun account, whichever is earlier.
• Technical & Device Logs: Retained for twelve (12) months for security monitoring and fraud prevention, after which they are anonymized or deleted.

When retention periods expire and no overriding legal obligation applies, phfhun will securely delete or anonymize your personal data so that it can no longer be linked to you.

8Data Security

phfhun implements technical, organizational, and administrative security measures designed to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your browser or device and the phfhun platform is encrypted in transit using industry-standard 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive personal data — including KYC documents, ID images, and financial records — is stored in encrypted form on phfhun's secure servers.
• Access Controls: Strict role-based access controls ensure that only authorized phfhun personnel with a legitimate need can access personal data. All data access is logged and audited.
• Two-Factor Authentication: phfhun supports two-factor authentication (2FA) for player accounts and enforces it for all internal administrative access.
• Regular Security Audits: phfhun's platform undergoes regular penetration testing and security audits by independent third-party security firms.
• Data Breach Response: In the event of a personal data breach that poses a real risk of harm to affected players, phfhun will notify the National Privacy Commission (NPC) within 72 hours of discovery and will inform affected players as required under RA 10173.

9Your Data Subject Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phfhun. These rights can be exercised by contacting our Data Protection Officer (DPO) at the contact details in Section 13:

• Right to Be Informed: You have the right to know what personal data phfhun collects about you, the purposes for which it is processed, and how long it will be retained — as set out in this Privacy Policy.
• Right of Access: You may request a copy of the personal data phfhun holds about you. We will respond to verified access requests within thirty (30) calendar days.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You can update basic account details directly from your phfhun account settings.
• Right to Erasure: You may request deletion of your personal data where there is no overriding legal or regulatory obligation requiring its retention. Note that PAGCOR licensing and AMLA requirements mean some data must be retained for a minimum period even after account closure.
• Right to Data Portability: You may request your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider, where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data where it is based on legitimate interests or for direct marketing purposes. phfhun will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails, analytics cookies), you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Lodge a Complaint: If you believe phfhun has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10Children & Minors

The phfhun platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR licensing requirements. phfhun does not knowingly collect personal data from individuals under the age of 21.

All registration attempts are subject to mandatory age and identity verification. Where phfhun discovers that personal data has been collected from a person under 21 years of age — whether through a false declaration during registration or any other means — the following actions will be taken immediately:

• The account will be permanently suspended.
• All data collected in connection with the underage account will be securely deleted, subject to any retention obligations required by PAGCOR or applicable law.
• Any deposits made will be returned to the original payment method. All winnings will be voided in accordance with phfhun's Terms & Conditions.
• The matter will be reported to PAGCOR as required under its responsible gaming framework.

If you are a parent or guardian and believe your child has accessed or registered on the phfhun platform, please contact our support team immediately via live chat or at [email protected] (plain text — not a link).

11Cross-Border Data Transfers

As a Philippines-facing platform, phfhun's primary data processing infrastructure is designed to serve Filipino players. However, some third-party service providers — including cloud infrastructure, KYC verification partners, and game content providers — may process data on servers located outside the Philippines.

Where phfhun transfers personal data outside the Philippines, we ensure that adequate safeguards are in place in compliance with NPC regulations, including:

• Binding contractual clauses in data processing agreements that impose RA 10173-equivalent obligations on overseas processors.
• Transfers only to jurisdictions or processors that the NPC has determined provide an adequate level of protection for personal data.
• Your explicit consent, where required for specific international processing activities.

phfhun does not transfer your personal data to jurisdictions identified as Prohibited Jurisdictions under our Terms & Conditions, and does not transfer data to any third party for purposes unrelated to the provision of phfhun's services to you.

12Updates to This Privacy Policy

phfhun reserves the right to update, revise, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, NPC guidance, or PAGCOR regulatory requirements. The "Last Updated" date at the top of this page will always reflect the most recent revision.

For material changes that significantly affect how we process your personal data, phfhun will provide advance notice of at least seven (7) calendar days via the email address registered to your phfhun account, or through a prominent notice on the phfhun platform. Your continued use of the platform after the effective date of the revised Privacy Policy constitutes your acknowledgment of the changes.

We encourage all phfhun players to review this Privacy Policy periodically to stay informed about how we protect their personal data. Previous versions of this Privacy Policy are available upon request by contacting our Data Protection Officer.

13Contact & Data Protection Officer

phfhun has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012 and NPC Circular No. 16-01. The DPO is responsible for overseeing phfhun's compliance with RA 10173 and serving as the point of contact for data subject rights requests and privacy concerns.

To exercise your data subject rights, raise a privacy concern, or submit a complaint regarding phfhun's handling of your personal data, please contact us through the following channels:

• 24/7 Live Chat: Available directly on the phfhun platform. Average first response time under 3 minutes. Fastest route for urgent account or data concerns.
• Email: [email protected] — please copy this address into your email client manually. Response time: 2–4 hours. For formal data subject rights requests, please include "Data Privacy Request" in your subject line and provide your registered account details for identity verification.

If you are not satisfied with phfhun's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the competent supervisory authority for data protection matters under RA 10173.