phtreasure Privacy Policy

1 Introduction

1.1 phtreasure is committed to protecting the privacy and personal data of all users of the phtreasure platform. This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by phtreasure.

1.2 This Policy applies to all personal data collected through the phtreasure website, mobile application, customer support channels, and any other interaction you have with phtreasure. It should be read alongside our Terms & Conditions, which govern your use of the phtreasure platform.

1.3 phtreasure is committed to compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as all applicable guidelines issued by the National Privacy Commission (NPC) of the Philippines.

2 Data Controller

2.1 For the purposes of applicable data protection legislation, phtreasure is the data controller responsible for your personal data collected through the phtreasure platform.

2.2 phtreasure has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our DPO using the details set out in Section 14 of this Policy.

3 Personal Data We Collect

3.1 phtreasure collects and processes the following categories of personal data:

3.2 phtreasure does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by law (e.g., responsible gaming assessments).

3.3 Where you fail to provide personal data that phtreasure is required to collect by law or under the terms of our agreement with you, phtreasure may not be able to provide you with access to the platform or certain services.

4 How We Use Your Personal Data

4.1 phtreasure uses your personal data for the following purposes:

• Account Management: To register and maintain your phtreasure account, verify your identity, and manage your account settings;
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver customer support;
• Legal Compliance: To comply with anti-money laundering (AML) obligations, KYC requirements, PAGCOR reporting obligations, and other applicable laws;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, cheating, and other illegal activities;
• Responsible Gaming: To monitor gaming behaviour, identify at-risk players, and administer responsible gaming tools such as deposit limits and self-exclusion;
• Marketing Communications: To send you promotional offers, bonuses, and updates about phtreasure — only where you have provided your consent or where we have a legitimate interest to do so;
• Platform Improvement: To analyse usage patterns, improve our games and services, and personalise your phtreasure experience;
• Dispute Resolution: To investigate and resolve complaints, disputes, and legal claims.

5 Legal Basis for Processing

5.1 phtreasure processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide the phtreasure gaming services you have registered for);
• Legal Obligation: Processing is necessary to comply with applicable laws and regulations, including AML, KYC, and PAGCOR requirements;
• Legitimate Interests: Processing is necessary for phtreasure's legitimate interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Where you have given your explicit consent to receive marketing communications or for other specific processing activities. You may withdraw your consent at any time by contacting phtreasure support.

6 Data Sharing & Disclosure

6.1 phtreasure does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only where necessary:

• Payment Processors: GCash, PayMaya, and banking partners for the purpose of processing deposits and withdrawals;
• Game Providers: Third-party game software providers who supply games available on the phtreasure platform, subject to strict data processing agreements;
• Identity Verification Services: KYC and AML compliance service providers;
• IT & Security Providers: Cloud hosting, cybersecurity, and fraud detection service providers;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities where required by law;
• Legal & Professional Advisers: Lawyers, auditors, and other professional advisers where necessary for legal proceedings or compliance purposes.

6.2 All third-party service providers who process personal data on behalf of phtreasure are required to enter into data processing agreements and are bound by strict confidentiality and data security obligations.

7 Data Retention

7.1 phtreasure retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

7.2 The following retention periods apply to the main categories of personal data held by phtreasure:

• Account & Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and PAGCOR record-keeping requirements;
• Financial & Transaction Data: Retained for a minimum of five (5) years from the date of each transaction;
• Communications Data: Support correspondence retained for three (3) years from the date of the interaction;
• Technical & Usage Data: Retained for up to two (2) years for analytics and security purposes.

7.3 In some circumstances, phtreasure may anonymise your personal data so that it can no longer be associated with you, in which case phtreasure may retain and use such anonymised data indefinitely without further notice.

8 Data Security

8.1 phtreasure has implemented appropriate technical and organisational security measures to protect your personal data against accidental loss, unauthorised access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phtreasure platform;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Two-factor authentication (2FA) options for player accounts;
• 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, phtreasure will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Philippine Data Privacy Act and NPC Circular No. 16-03.

8.3 While phtreasure takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for keeping your phtreasure account credentials confidential and for notifying us immediately of any suspected unauthorised access.

9 Cookies & Tracking Technologies

9.1 phtreasure uses cookies and similar tracking technologies to enhance your experience on the platform, analyse usage patterns, and deliver relevant content. A cookie is a small text file placed on your device when you visit the phtreasure website.

9.2 phtreasure uses the following types of cookies:

• Strictly Necessary Cookies: Essential for the operation of the phtreasure platform, including maintaining your login session and enabling secure transactions. These cannot be disabled;
• Performance & Analytics Cookies: Help phtreasure understand how players use the platform, which pages are most visited, and where errors occur, allowing us to improve our services;
• Functionality Cookies: Remember your preferences such as language settings, game preferences, and display options to personalise your experience;
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of phtreasure marketing campaigns. These are only set with your consent.

9.3 You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phtreasure platform. For more information on managing cookies, refer to your browser's help documentation.

10 Your Data Protection Rights

10.1 Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by phtreasure:

• Right to be Informed: You have the right to be informed about how your personal data is being collected and processed, as set out in this Policy;
• Right of Access: You have the right to request a copy of the personal data phtreasure holds about you;
• 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) of the Philippines if you believe your data protection rights have been violated.

10.2 To exercise any of the above rights, please contact phtreasure's Data Protection Officer using the contact details in Section 14. phtreasure will respond to all verified requests within thirty (30) days in accordance with NPC guidelines.

10.3 phtreasure may need to verify your identity before processing your request to ensure that personal data is not disclosed to any person who has no right to receive it.

11 Children's Privacy

11.1 The phtreasure platform is strictly intended for individuals who are 21 years of age or older. phtreasure does not knowingly collect personal data from persons under the age of 21.

11.2 If phtreasure becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such data and close the associated account. Any deposits made by an underage player will be returned to the depositing payment method.

11.3 If you are a parent or guardian and believe that your child has provided personal data to phtreasure, please contact us immediately at the details provided in Section 14 so that we can take appropriate action.

12 International Data Transfers

12.1 phtreasure primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed by service providers located outside the Philippines, such as cloud infrastructure providers or game software suppliers.

12.2 Where personal data is transferred outside the Philippines, phtreasure ensures that appropriate safeguards are in place to protect your data, including contractual clauses that impose data protection obligations on the recipient equivalent to those required under Philippine law.

12.3 By using the phtreasure platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject always to the protections described herein.

13 Changes to This Privacy Policy

13.1 phtreasure 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 updated Policy will be posted on the phtreasure website with a revised effective date.

13.2 Where changes are material, phtreasure will notify registered players via email or a prominent notice on the platform prior to the changes taking effect. Your continued use of the phtreasure platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

13.3 We encourage you to review this Privacy Policy periodically to stay informed about how phtreasure is protecting your personal information.

14 Contact & Data Protection Officer

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the way phtreasure handles your personal data, please contact our Data Protection Officer:

14.2 You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with phtreasure's response to your data protection concern. The NPC can be reached through their official government channels.