phgame2 Privacy Policy

phgame2 is committed to protecting the privacy and personal data of every Filipino player who uses our platform. We understand that trust is the foundation of the relationship between an online gaming operator and its players — and that privacy is central to that trust. This Policy sets out our practices in plain, understandable terms. We believe you have the right to know exactly what happens to your data from the moment you visit phgame2.app to the moment you close your account.

phgame2 acts as the data controller in respect of your personal information. This means we determine the purposes and means by which your data is processed. Where phgame2 engages third-party service providers to process data on our behalf, those providers act as data processors under binding data processing agreements that require them to protect your information with the same standards phgame2 applies.

This Privacy Policy applies to:

• All visitors to the phgame2.app website, regardless of whether they have a registered Account.
• All registered phgame2 Players, including those who have applied for an Account but whose application is pending or was declined.
• All individuals who contact phgame2's customer support team, regardless of whether they have an Account.

This Policy does not apply to third-party websites, services, or applications that may be linked to or accessible from phgame2.app. phgame2 is not responsible for the privacy practices of any third party. Players are encouraged to review the privacy policies of any third-party services they interact with, including their GCash, PayMaya, or banking applications.

phgame2 collects the following categories of personal information:

phgame2 collects your personal data through the following means:

• Direct collection: Information you provide when registering an Account, completing KYC, making a deposit or withdrawal request, contacting customer support, or participating in promotions.
• Automated technical collection: Data collected automatically through your use of the phgame2 website, including IP address, device identifiers, browser data, cookies, and session activity logs. See Section 10 (Cookies) for more detail.
• Third-party sources: phgame2 may receive identity verification data from KYC/AML service providers, fraud prevention services, and payment processors (such as GCash and PayMaya) to verify your identity and protect against financial crime.
• Gaming activity data: All bets, game outcomes, session data, and wallet transactions are recorded automatically by the phgame2 platform systems as part of normal operations.

phgame2 processes your personal data for the following specific purposes only:

• Account management: Creating, maintaining, verifying, and administering your phgame2 Account, including identity verification (KYC) and age confirmation.
• Service delivery: Enabling you to access and participate in gaming services, sports betting, live casino, bingo, and slots on the phgame2 Platform.
• Payment processing: Processing deposits via GCash, PayMaya, BPI, BDO, Metrobank, or UnionBank and processing withdrawal requests to your verified payment method.
• Legal compliance: Meeting obligations under Philippine law, including the Anti-Money Laundering Act (AMLA), applicable gaming regulations, and directives from the National Privacy Commission (NPC) and other regulatory bodies.
• Fraud prevention and security: Detecting, investigating, and preventing fraud, money laundering, underage gambling, duplicate Accounts, and other prohibited activities.
• Customer support: Responding to inquiries, complaints, and dispute resolution requests from Players.
• Responsible gaming: Administering responsible gaming tools including deposit limits, self-exclusion, session timers, and reality checks in line with our Responsible Gaming Policy.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may withdraw consent at any time from your Account settings.
• Platform improvement: Analyzing aggregated, anonymized usage data to improve the phgame2 platform, game selection, and user experience.

Under the Philippines Data Privacy Act of 2012, phgame2 relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing required to perform the contract between you and phgame2 (your Account registration and the Terms & Conditions you accepted). This covers Account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with Philippine law, including AMLA obligations, KYC requirements, and regulatory reporting to applicable gaming and financial regulators.
• Legitimate interest: Processing necessary for phgame2's legitimate business interests, including fraud prevention, platform security, and responsible gaming enforcement, where such interests are not overridden by your fundamental rights.
• Consent: Where you have given specific, freely given, informed, and unambiguous consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing based on consent prior to withdrawal.

phgame2 does not sell, rent, or trade your personal data to unaffiliated third parties for their own marketing or commercial purposes. phgame2 may share your data in the following limited circumstances:

7.1 Service Providers (Data Processors)

phgame2 engages trusted third-party service providers who process data strictly on phgame2's behalf, including: payment processors (GCash / PayMaya / BPI / BDO / Metrobank / UnionBank), KYC and identity verification providers, fraud detection and anti-money laundering screening services, cloud hosting and infrastructure providers, and customer support platform providers. All such providers are bound by data processing agreements requiring them to protect your data to standards equivalent to those in this Policy.

7.2 Regulatory and Law Enforcement Authorities

phgame2 may disclose personal data to Philippine regulatory bodies, law enforcement agencies, courts, or other government authorities where required or authorized by law — including but not limited to the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and applicable gaming regulators. phgame2 will only disclose the minimum information necessary to satisfy the applicable legal requirement.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of phgame2's business, personal data held by phgame2 may be transferred to the relevant acquirer or successor entity as part of that transaction. phgame2 will notify affected Players of any such transfer and the privacy practices of the successor entity prior to data being transferred.

phgame2 retains your personal data only for as long as necessary for the purposes described in this Policy or as required by applicable Philippine law. The following general retention principles apply:

• Active Account data: Retained for the duration of your active Account and for a minimum of 5 years after Account closure, in compliance with AMLA record-keeping requirements.
• KYC documents: Retained for a minimum of 5 years from the date of Account closure or the date of the last transaction, whichever is later, as required by AMLA implementing rules.
• Transaction records: All deposit, withdrawal, and gaming transaction records are retained for a minimum of 5 years from the date of the transaction.
• Customer support communications: Retained for 3 years from the date of the communication.
• Technical and cookies data: Anonymized after 13 months unless retention is required for an active investigation or legal proceeding.
• Marketing consent records: Retained for the period of consent and for 3 years thereafter as evidence of consent.

Upon expiry of the applicable retention period, phgame2 will securely delete, destroy, or anonymize your personal data in accordance with industry-standard data disposal procedures.

phgame2 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our key security controls include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and phgame2 servers.
• Encrypted storage of sensitive personal information, including government ID data and financial account numbers, at rest.
• Access controls: Strict role-based access controls limit which phgame2 staff can access personal data. Access is granted on a need-to-know basis only.
• Two-factor authentication (2FA) available to all Players for their Account login, and mandatory for phgame2 staff accessing internal systems.
• Regular security audits and penetration testing of the phgame2 Platform infrastructure.
• Incident response procedures: phgame2 maintains a data breach response plan in compliance with NPC notification requirements. In the event of a personal data breach that is likely to cause harm to affected Players, phgame2 will notify the NPC within 72 hours and notify affected Players without undue delay.

phgame2 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, maintain your login session, and analyze site usage. The following types of cookies are used:

• Strictly necessary cookies: Required for the phgame2 Platform to function. These include session cookies that maintain your login state and security tokens that protect against cross-site request forgery. These cannot be disabled without breaking platform functionality.
• Functional cookies: Remember your preferences, such as language settings, and provide a more personalized experience on phgame2.app.
• Analytics cookies: Collect anonymized information about how Players use the phgame2 Platform to help us understand page performance and improve the user experience. The data collected is aggregated and does not identify individual users.
• Security cookies: Support fraud detection and account security functions by helping identify unusual login patterns or suspicious activity.

You may manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phgame2 Platform. phgame2 does not use third-party advertising cookies to track your activity across other websites.

Under the Philippines Data Privacy Act of 2012 and phgame2's own privacy commitments, you have the following rights in relation to your personal data:

• Right to be informed: You have the right to know how phgame2 processes your personal data. This Policy fulfills that right.
• Right of access: You have the right to request a copy of the personal data phgame2 holds about you. We will respond to access requests within 30 calendar days.
• Right to rectification: If any personal data phgame2 holds about you is inaccurate or incomplete, you have the right to request correction. Many Account details can be updated directly in your Account settings.
• Right to erasure: You may request that phgame2 delete your personal data. Note that this right is subject to legal retention obligations — phgame2 cannot delete data it is legally required to retain under AMLA or other applicable Philippine law.
• Right to object: You have the right to object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interest grounds, subject to phgame2's assessment.
• Right to data portability: You may request a copy of personal data you have provided to phgame2 in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: If you believe phgame2 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact phgame2's Data Protection Officer (DPO) using the contact details in Section 15.

The phgame2 Platform is strictly intended for persons aged 21 years and above in compliance with applicable Philippine gaming regulations. phgame2 does not knowingly collect personal data from individuals under the age of 21.

As part of the KYC verification process, phgame2 verifies the date of birth of every Player before processing any withdrawal. Where phgame2 has reasonable grounds to believe that a registered Player is under 21 years of age, the Account will be immediately suspended, all pending transactions will be frozen, and personal data will be processed solely for the purpose of age investigation and any required regulatory reporting.

phgame2 primarily stores and processes personal data within the Philippines or in data centers operating under data processing agreements that impose equivalent data protection standards. Where phgame2 transfers personal data to service providers operating outside the Philippines — for example, cloud infrastructure providers or international fraud detection services — phgame2 ensures appropriate safeguards are in place, including:

• Data processing agreements that incorporate the NPC's standard contractual clauses or equivalent protections.
• Transfer only to jurisdictions determined by the NPC to provide adequate protection for personal data.
• Application of technical safeguards (encryption, pseudonymization) to data transferred internationally.

phgame2 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or regulatory guidance from the National Privacy Commission. When material changes are made, phgame2 will notify registered Players by email or through a prominent notice on the phgame2 Platform at least 7 days before the changes take effect. The updated Policy will always be available at phgame2.app/privacy-policy with the effective date clearly indicated. Your continued use of the phgame2 Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms.

phgame2 has appointed a Data Protection Officer (DPO) in compliance with the Philippines Data Privacy Act of 2012. If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to report a privacy concern, you may contact us through the following channels:

phgame2 will respond to all privacy-related inquiries within 30 calendar days of receipt. For complex requests, we may extend this period by a further 30 days where necessary, and will notify you of any extension.