phvvvv Privacy Policy

1. Introduction

phvvvv ("we," "us," "our," "the Company") is committed to protecting the privacy and personal data of every individual who accesses or uses the phvvvv Platform at phvvvv.app ("the Platform"). This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information in connection with your use of the Platform, and explains the rights available to you under applicable Philippine privacy law.

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. By accessing the Platform or creating a phvvvv account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform as a whole. In the event of any conflict between this Policy and the Terms & Conditions solely with respect to data privacy matters, this Policy shall prevail.

2. Data Controller

phvvvv is the personal information controller responsible for your data as defined under RA 10173. For all matters relating to this Policy, data subject rights requests, or privacy concerns, you may contact our designated Data Privacy Officer (DPO) at the following:

• Email: [email protected] (subject line: "Data Privacy Request")
• Platform: phvvvv.app
• Response time: phvvvv aims to acknowledge all DPO inquiries within 3 business days and to resolve them within 15 business days, consistent with NPC guidelines.

Our DPO is responsible for overseeing phvvvv's data protection strategy, ensuring compliance with RA 10173, and serving as the primary point of contact between phvvvv and data subjects or the National Privacy Commission.

3. Data We Collect

phvvvv collects personal data in the following categories depending on how you interact with the Platform:

3.1 Registration & Identity Data

When you create a phvvvv account, we collect your full legal name, date of birth, gender, nationality, residential address (city and province within the Philippines), email address, and Philippine mobile number. This data is required to establish your account and verify your identity in accordance with PAGCOR Know Your Customer (KYC) requirements.

3.2 Identity Verification Documents

To comply with applicable KYC and AML regulations, we may collect copies of government-issued identification documents such as your Philippine National ID, passport, SSS/GSIS card, driver's license, or Voter's ID, as well as supporting documents such as proof of billing address and source-of-funds declarations.

3.3 Financial & Transaction Data

We collect data related to your deposits, withdrawals, and gaming transactions, including payment method identifiers (e.g., GCash mobile number, BPI account nickname), transaction amounts, timestamps, and transaction reference numbers. We do not store full bank account numbers or card numbers on our servers.

3.4 Gaming & Behavioral Data

We collect data about your activity on the Platform, including game sessions played, bet amounts, win/loss records, bonus usage, login timestamps, and session durations. This data is used for account management, responsible gaming monitoring, fraud detection, and Platform improvement.

3.5 Technical & Device Data

We automatically collect certain technical information when you access the Platform, including your IP address, browser type and version, operating system, device identifiers, screen resolution, referring URL, and pages visited. This information is collected via server logs and cookies.

3.6 Communications Data

If you contact phvvvv customer support via live chat, email, or other channels, we retain records of those communications, including the content of your messages, timestamps, and any attachments you provide, for quality assurance and dispute resolution purposes.

4. Purpose & Legal Basis for Processing

phvvvv processes your personal data only where a lawful basis exists under RA 10173. The primary purposes and their corresponding legal bases are as follows:

• Account creation and management — necessary for the performance of the contract between you and phvvvv (i.e., the Terms & Conditions you agreed to upon registration).
• Identity verification and KYC compliance — required to comply with PAGCOR licensing conditions and Philippine AML regulations, constituting a legal obligation on phvvvv's part.
• Processing deposits, wagers, and withdrawals — necessary for the performance of our contractual obligations to you.
• Fraud prevention and security monitoring — constitutes a legitimate interest of phvvvv in protecting the integrity of the Platform and the interests of all players.
• Responsible gaming monitoring — a legitimate interest and, in certain circumstances, a legal obligation under PAGCOR guidelines to identify and assist players who may be experiencing gambling-related harm.
• Marketing and promotional communications — based on your explicit consent at the time of registration or subsequently through your account communication preferences. You may withdraw this consent at any time.
• Regulatory reporting — a legal obligation to report to PAGCOR, the AMLC, the NPC, or other competent Philippine authorities as required by applicable law.
• Customer support and dispute resolution — necessary for the performance of our contractual obligations and our legitimate interest in resolving disputes fairly.
• Platform analytics and improvement — a legitimate interest in understanding how the Platform is used in order to improve features and user experience, conducted using aggregated or pseudonymized data where possible.

phvvvv will not process your personal data for purposes incompatible with those listed above without first obtaining your explicit consent or identifying a new lawful basis and notifying you accordingly.

5. Sharing Your Personal Data

phvvvv does not sell, rent, or trade your personal data to any third party. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment service providers — GCash (Mynt), Maya (Voyager Innovations), GrabPay, BPI, BDO, Metrobank, InstaPay operators, and 7-Eleven (via Cliqq) process your financial transactions. These providers act as independent data controllers for their own services and are bound by their own privacy policies and applicable Bangko Sentral ng Pilipinas (BSP) regulations.
• Identity verification providers — third-party KYC service providers may process your identification documents on our behalf under strict data processing agreements and are prohibited from using your data for any other purpose.
• Fraud and AML detection services — specialized providers assist us in monitoring for suspicious activity. Any data shared is subject to confidentiality obligations.
• Cloud infrastructure and hosting providers — our Platform is hosted on secure cloud infrastructure. Server operators may have technical access to data but are contractually prohibited from accessing it for non-operational purposes.
• PAGCOR and Philippine regulatory authorities — we are legally obligated to submit reports and, where required, player data to PAGCOR, the AMLC, the NPC, and other competent authorities upon lawful request.
• Law enforcement agencies — in response to a valid court order, subpoena, or lawful request from Philippine law enforcement authorities.

All third-party service providers engaged by phvvvv are subject to contractual data processing agreements that require them to implement appropriate data protection measures, process your data only for specified purposes, and comply with RA 10173.

6. International Data Transfers

phvvvv's primary operations are based in the Philippines. However, some of our technology service providers and cloud infrastructure partners may store or process data in data centers located outside the Philippines. Where such international transfers occur, phvvvv ensures that adequate safeguards are in place consistent with the requirements of RA 10173 and NPC guidelines, including contractual clauses that require overseas recipients to provide a standard of data protection equivalent to that required under Philippine law.

By using the Platform, you acknowledge and consent to the transfer of your personal data to these overseas service providers where necessary for the operation of the Platform, subject to the safeguards described above.

7. Cookies & Similar Technologies

phvvvv uses cookies and similar technologies (collectively "Cookies") on the Platform. Cookies are small text files stored on your device that help us recognize you, maintain your session, and understand how you use the Platform.

We use the following categories of Cookies:

• Strictly necessary Cookies — these are essential for the Platform to function. They maintain your login session, remember your language preference, and enable secure navigation. These Cookies cannot be disabled without disrupting Platform functionality.
• Performance and analytics Cookies — these collect anonymized information about how players use the Platform (e.g., which pages are visited most frequently, error reports). This data is used solely to improve Platform performance and user experience.
• Functional Cookies — these remember your preferences and settings (e.g., your preferred game lobby view or currency display) to provide a more personalized experience on return visits.

phvvvv does not use third-party advertising Cookies or behavioral tracking Cookies that build profiles across unrelated websites. You may manage or delete Cookies through your browser settings. Please note that disabling strictly necessary Cookies will affect your ability to log in and use the Platform normally.

8. Data Retention

phvvvv retains your personal data for as long as your account remains active and for a period thereafter as mandated by applicable law. The following general retention periods apply:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and AML obligations under Republic Act No. 9160 (Anti-Money Laundering Act), as amended.
• Financial transaction records — retained for a minimum of five (5) years from the date of each transaction, as required by BSP and AMLC regulations.
• KYC and verification documents — retained for the same period as account and identity data above.
• Gaming activity logs — retained for a minimum of three (3) years after account closure, unless a longer period is required for dispute resolution or regulatory purposes.
• Customer support communications — retained for two (2) years from the date of the communication, unless the content is relevant to an ongoing dispute or regulatory matter.
• Marketing consent records — retained for the duration of the consent and for one (1) year thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymized, or rendered irreversibly de-identified, in accordance with NPC guidelines on data disposal.

9. Security Measures

phvvvv implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• Encryption in transit: all data exchanged between your browser or device and phvvvv servers is encrypted using TLS 1.2 or higher.
• Encryption at rest: sensitive personal data and financial records stored on phvvvv servers are encrypted using industry-standard algorithms.
• Access controls: access to personal data within phvvvv's systems is restricted on a need-to-know basis. Staff who handle personal data undergo mandatory privacy and security training and are bound by confidentiality obligations.
• Intrusion detection: phvvvv employs automated monitoring systems to detect and respond to unauthorized access attempts or anomalous activity on our servers.
• Regular security reviews: phvvvv conducts periodic vulnerability assessments and security audits of the Platform and its underlying infrastructure.
• Incident response: phvvvv maintains a documented data breach response procedure. In the event of a personal data breach that poses a real risk to data subjects, phvvvv will notify the NPC within 72 hours of discovery and will inform affected players as required under RA 10173.

While phvvvv takes data security seriously, no internet-based system can guarantee absolute security. You are responsible for maintaining the confidentiality of your phvvvv account credentials and for using secure networks when accessing the Platform.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by phvvvv:

1. Right to be informed — you have the right to know that phvvvv is collecting your personal data, the purposes for which it is processed, and the recipients to whom it may be disclosed.
2. Right to access — you have the right to request a copy of the personal data phvvvv holds about you, along with information about how it is used.
3. Right to correction — you have the right to request that inaccurate, outdated, or incomplete personal data be corrected or updated without undue delay.
4. Right to erasure or blocking — you have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, where consent has been withdrawn, or where processing is unlawful, subject to phvvvv's legal retention obligations.
5. Right to object — you have the right to object to the processing of your personal data, particularly where processing is based on legitimate interests or where it is used for direct marketing purposes.
6. Right to data portability — you have 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.
7. Right to damages — you have the right to claim compensation for damages sustained due to inaccurate, incomplete, or unauthorized processing of your personal data.
8. Right to file a complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phvvvv has violated your data privacy rights.

To exercise any of the above rights, please submit a written request to our Data Privacy Officer at [email protected] with the subject line "Data Subject Rights Request." We will verify your identity before processing any request and will respond within the timeframe required under applicable NPC guidelines. Some requests may be subject to legal limitations where retention of your data is required by law.

11. Minors

The phvvvv Platform is strictly intended for individuals who are 21 years of age or older, consistent with the minimum age for participation in casino-style gaming under applicable Philippine regulations. phvvvv does not knowingly collect personal data from individuals under the age of 21.

If phvvvv becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the relevant account, delete all associated personal data, and, where applicable, report the incident as required. If you believe a minor has registered on the Platform, please notify us immediately at [email protected].

12. Third-Party Links

The phvvvv Platform does not contain links to external third-party websites as part of its standard navigation or content. In the event that any third-party reference appears in informational content on the Platform, please note that phvvvv has no control over the privacy practices, content, or data handling of any third-party website. This Policy applies solely to the phvvvv Platform and not to any external websites or services.

13. Updates to This Policy

phvvvv reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or Platform features. When material changes are made, we will notify registered players via email to their registered address and display a prominent notice on the Platform prior to the changes taking effect.

The effective date at the top of this Policy will be updated each time it is revised. We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of any revised Policy constitutes your acknowledgment of and, where required, consent to the updated terms.

The current version of this Policy is always accessible at phvvvv.app/privacy-policy.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by phvvvv, please contact our Data Privacy Officer using the details below. We are committed to addressing your inquiry promptly and transparently.

• Data Privacy Officer — phvvvv
• Email: [email protected] (subject: "Data Privacy Request")
• Website: phvvvv.app

If you are not satisfied with our response to your data privacy concern, you have the right to escalate your complaint directly to the National Privacy Commission (NPC) of the Philippines, the competent supervisory authority responsible for enforcing RA 10173. Information on how to file a complaint with the NPC is available through official Philippine government channels.