phperry Casino — Privacy Policy

1. Introduction

phperry ("we," "us," "our," or "phperry") operates the online casino and sports betting platform accessible at phperry.club (the "Platform"). As a PAGCOR-licensed operator serving Filipino players, phperry is committed to protecting the privacy and personal data of all individuals who interact with our Platform.

This Privacy Policy ("Policy") describes the types of personal data phperry collects, the purposes for which that data is processed, the legal bases for processing, the parties with whom data may be shared, and the rights available to data subjects under Philippine law. This Policy applies to all registered account holders, unregistered visitors, and any other individuals whose personal data phperry processes in connection with the Platform.

By registering an account, using the Platform, or otherwise providing personal data to phperry, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein, to the extent that consent is required as a legal basis for processing.

2. Data Controller

The data controller responsible for your personal data under this Policy is phperry, the operator of the phperry.club Platform, licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) to provide online gaming services in the Philippines.

phperry has designated a Data Protection Officer ("DPO") in accordance with Section 21 of RA 10173. The DPO is responsible for overseeing phperry's data protection compliance, handling data subject requests, and liaising with the National Privacy Commission of the Philippines. Contact details for the DPO are set out in Section 14 of this Policy.

3. Personal Data We Collect

phperry collects the following categories of personal data:

3.1 Identity Data. Full legal name, date of birth, nationality, and copies of government-issued identification documents (such as Philippine System ID, driver's license, passport, SSS ID, or Unified Multi-Purpose ID) collected during Know Your Customer (KYC) verification as required under phperry's PAGCOR license conditions.

3.2 Contact Data. Email address, Philippine mobile number, and, where voluntarily provided, residential address.

3.3 Account Data. Username, encrypted password (phperry does not store passwords in plain text), account preferences, responsible gaming limit settings, and communication preferences.

3.4 Financial Data. GCash account details, PayMaya account details, bank account information (BPI, BDO, Metrobank, or other Philippine banks), transaction reference numbers, deposit amounts, withdrawal amounts, and account balance history. phperry does not store full payment card numbers; card processing, where applicable, is handled by certified PCI-DSS compliant payment processors.

3.5 Gaming Data. Game session logs, bet amounts, game outcomes, win/loss records, and game history for all casino and sports betting activity conducted through the Platform.

3.6 Technical Data. IP address, device identifiers, browser type and version, operating system, screen resolution, referring URLs, and session timestamps collected automatically when you access the Platform.

3.7 Communications Data. Records of communications between you and phperry's customer support team, including live chat transcripts, email correspondence, and any complaints or dispute records.

4. How We Collect Your Data

phperry collects personal data through the following means:

• Account Registration: Data you provide when creating and verifying your phperry account, including during KYC submission.
• Platform Use: Data generated automatically through your use of the Platform, including login events, gameplay, deposits, and withdrawals.
• Customer Support: Data you provide when contacting phperry's support team via live chat or email.
• Cookies and Tracking Technologies: Data collected automatically via cookies and similar technologies as described in Section 8.
• Third-Party Payment Providers: Transaction confirmation data shared by GCash, PayMaya, and Philippine banks to verify deposits and process withdrawals.
• Identity Verification Partners: Results of identity and age verification checks conducted through PAGCOR-approved identity verification partners.

5. Legal Basis for Processing

phperry processes personal data on the following legal bases under RA 10173 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing required to perform the contract between phperry and the account holder, including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with phperry's PAGCOR license conditions, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine legal requirements, including mandatory KYC verification and transaction monitoring.
• Legitimate Interests: Processing necessary for phperry's legitimate interests, including fraud prevention, platform security, responsible gaming enforcement, and improving the Platform, provided such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for direct marketing communications (where consent is required) and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Data

phperry uses the personal data described in Section 3 for the following purposes:

• Creating, managing, and verifying your phperry account;
• Processing deposits and withdrawals through GCash, PayMaya, BPI, BDO, Metrobank, and other Philippine payment methods;
• Providing access to casino games, live dealer tables, poker rooms, bingo, and sports betting markets;
• Fulfilling phperry's PAGCOR-mandated KYC and responsible gaming obligations, including age verification (21+), self-exclusion enforcement, and deposit limit administration;
• Complying with Anti-Money Laundering Act (AMLA) transaction monitoring and reporting obligations;
• Preventing fraud, detecting cheating, and protecting the integrity of the Platform and its players;
• Providing customer support and resolving disputes;
• Sending transactional communications (account confirmations, payment receipts, security alerts) — these are not optional as they are necessary for Platform operation;
• Sending promotional communications about phperry bonuses and offers, subject to your communication preferences — you may opt out at any time;
• Analysing Platform usage to improve performance, game selection, and user experience;
• Complying with applicable Philippine law and responding to lawful requests from government authorities, including PAGCOR, the Anti-Money Laundering Council (AMLC), and law enforcement agencies.

7. Data Sharing and Disclosure

7.1 Service Providers. phperry shares personal data with trusted third-party service providers who process data on phperry's behalf, including payment processors (GCash, PayMaya, Philippine banking partners), KYC and identity verification partners, cloud hosting providers, game software providers, and customer support platform providers. All such providers are contractually bound to process data only for the purposes specified by phperry and to maintain appropriate security standards.

7.2 PAGCOR and Regulatory Authorities. As a PAGCOR-licensed operator, phperry is required to share player data, transaction records, and audit information with PAGCOR upon request. phperry may also be required to disclose personal data to other Philippine government agencies, including the Anti-Money Laundering Council (AMLC), Bureau of Internal Revenue (BIR), and law enforcement authorities, where required by applicable law or court order.

7.3 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of phperry's assets, personal data held by phperry may be transferred to the acquiring entity, subject to the same data protection obligations as described in this Policy. phperry will notify affected data subjects of such a transfer.

7.4 No Sale of Data. phperry does not sell, rent, or trade personal data to third parties for their own marketing purposes.

7.5 Cross-Border Transfers. Some of phperry's service providers may process data outside the Philippines. Where such transfers occur, phperry ensures that appropriate safeguards are in place in accordance with the requirements of RA 10173 and the National Privacy Commission's guidelines on cross-border data transfers.

8. Cookies and Tracking Technologies

8.1 What Are Cookies. Cookies are small text files placed on your device when you access the Platform. phperry uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and deliver relevant content.

8.2 Types of Cookies Used.

• Strictly Necessary Cookies: Required for the Platform to function, including session authentication and security. These cannot be disabled without affecting Platform functionality.
• Performance Cookies: Collect anonymous data about how visitors use the Platform to help phperry improve performance and user experience.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming limits, to provide a more personalized experience.
• Analytics Cookies: Used to understand aggregate usage patterns. phperry uses analytics tools that process data in a privacy-preserving manner.

8.3 Cookie Management. You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies will affect your ability to use the Platform.

9. Data Security

phperry implements appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the Platform;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of Platform systems;
• Incident response procedures for detecting and responding to data breaches in compliance with RA 10173's breach notification requirements.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, phperry will notify you and the National Privacy Commission as required under RA 10173.

10. Data Retention

phperry retains personal data for the period necessary to fulfil the purposes described in this Policy, subject to the following considerations:

• Account Data: Retained for the duration of your account and for five (5) years following account closure, as required by phperry's PAGCOR license conditions and AMLA obligations.
• KYC and Identity Documents: Retained for five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction Records: Retained for five (5) years following the transaction date, as required by AMLA and BIR regulations.
• Gaming Records: Retained for a minimum of three (3) years following the relevant gaming session, as required by PAGCOR.
• Customer Support Records: Retained for three (3) years following the resolution of the relevant communication or dispute.
• Technical Logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, phperry will securely delete or anonymize your personal data.

11. Your Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by phperry:

• Right to be Informed: The right to be informed of how your personal data is being or has been processed, including the purposes and legal bases for processing.
• Right of Access: The right to obtain confirmation that phperry processes your personal data and to receive a copy of that data.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or completed.
• Right to Erasure or Blocking: The right to request the erasure or blocking of your personal data where processing is unlawful, where data is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and there is no other legal basis for processing. This right is subject to phperry's legal retention obligations under AMLA and PAGCOR regulations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible.
• Right to Object: The right to object to processing based on legitimate interests or for direct marketing purposes.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phperry has processed your personal data in violation of RA 10173.

To exercise any of the above rights, please contact phperry's Data Protection Officer using the contact details in Section 14. phperry will respond to verified requests within the timeframes prescribed by RA 10173.

12. Children's Privacy

The phperry Platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR regulations and Philippine gaming law. phperry does not knowingly collect personal data from individuals under the age of 21. If phperry becomes aware that it has collected personal data from a person under 21 years of age, it will take immediate steps to delete that data and terminate the associated account. If you believe that phperry may have inadvertently collected data from an underage individual, please contact us immediately at the details provided in Section 14.

13. Changes to This Policy

phperry reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, phperry will publish a revised Policy on the Platform with an updated "Last Updated" date and, where required by RA 10173, will provide prior notice to affected data subjects via email or Platform notification. Your continued use of the Platform following publication of a revised Policy constitutes acceptance of the updated Policy.

14. Contact and Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or need to report a privacy concern, please contact phperry's Data Protection Officer:

Email: [email protected] (plain text — not a clickable link)
Response time: phperry endeavors to acknowledge data subject requests within seventy-two (72) hours and to respond substantively within the timeframes prescribed by RA 10173 and the National Privacy Commission's guidelines.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with phperry's handling of your personal data.