phnjoy Privacy Policy

1 Who We Are and How to Contact Us

phnjoy is a PAGCOR-licensed online casino and sports betting platform operating at phnjoy.cam and associated subdomains. For the purposes of Republic Act No. 10173 (the Data Privacy Act of 2012) and its Implementing Rules and Regulations, phnjoy acts as the Personal Information Controller with respect to the personal data of registered players and website visitors collected through the phnjoy platform.

phnjoy has appointed a designated Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and for receiving and responding to data privacy inquiries and complaints from Filipino data subjects.

To exercise your data privacy rights or raise a concern about how phnjoy handles your personal data, you may contact the phnjoy Data Protection Officer by:

• Email: [email protected] — mark the subject line "Data Privacy Request"
• Live Chat: Available 24/7 from your logged-in phnjoy account dashboard

phnjoy will acknowledge all data privacy requests within three (3) business days and will endeavour to resolve substantive requests within thirty (30) calendar days, consistent with the timelines required by the National Privacy Commission.

2 Personal Data We Collect

phnjoy collects personal data that is necessary, relevant, and proportionate to the purposes for which it is processed. The categories of personal data we collect are described in the table below:

phnjoy does not collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act — such as health, genetic, religious, or political information — except where a player voluntarily discloses such information in the context of a responsible gaming or self-exclusion request.

3 How We Collect Your Personal Data

phnjoy collects personal data through the following means:

3.1 Direct Collection

You provide personal data directly to phnjoy when you register for an account, complete the KYC identity verification process, make a deposit or withdrawal request, contact our customer support team, respond to a promotional survey, or update your account profile settings.

3.2 Automated Collection

When you access and use the phnjoy platform, certain technical and usage data is collected automatically through server logs, browser cookies, session tracking technologies, and analytics tools. This data is collected to ensure platform security, detect fraudulent activity, and improve the performance and user experience of the phnjoy platform for Filipino players.

3.3 Third-Party Sources

phnjoy may receive personal data about you from the following third-party sources:

• Identity verification service providers used to validate government-issued Philippine identification documents during the KYC process;
• Payment processors and financial institutions (including GCash, Maya, BPI, BDO, and Metrobank) who may confirm payment details or flag suspicious transactions in accordance with Philippine anti-money laundering regulations;
• PAGCOR's national self-exclusion registry, which phnjoy checks to verify that a prospective player has not enrolled in a cross-platform self-exclusion program.

4 Why We Process Your Personal Data

phnjoy processes your personal data for the following specific purposes:

• Account creation and management: To register and maintain your phnjoy player account, verify your identity, and administer your account settings and preferences.
• KYC and regulatory compliance: To fulfil phnjoy's mandatory Know Your Customer obligations under its PAGCOR licence, and to comply with the Anti-Money Laundering Act (AMLA) and its implementing regulations enforced by the Anti-Money Laundering Council (AMLC) of the Philippines.
• Payment processing: To process GCash deposits and withdrawals, bank transfers, and other payment transactions; to verify that withdrawal funds are remitted to accounts registered in the player's own name; and to maintain accurate financial records.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent registrations, multi-accounting, money laundering, and other prohibited activities that could harm phnjoy players or the integrity of the platform.
• Responsible gaming: To administer deposit limits, session controls, cooling-off periods, and self-exclusion requests; to monitor account activity patterns for signs of problem gambling; and to comply with PAGCOR's responsible gaming framework requirements.
• Customer support: To respond to player inquiries, resolve disputes, and maintain records of communications for quality assurance and compliance purposes.
• Marketing communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time from your account settings.
• Platform improvement: To analyse aggregated and anonymised usage data to improve the performance, design, and features of the phnjoy platform.

5 Legal Bases for Processing

Under the Data Privacy Act of 2012, phnjoy processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between phnjoy and you as a registered player — including account management, payment processing, game delivery, and customer support.
• Legal obligation: Processing is required to comply with phnjoy's legal and regulatory obligations under the PAGCOR framework, the Anti-Money Laundering Act, and other applicable Philippine law.
• Legitimate interests: Processing is necessary for phnjoy's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and improving its services — provided such interests are not overridden by your rights and freedoms as a data subject.
• Consent: For marketing communications and optional account personalisation features, phnjoy relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time by updating your communication preferences in your account settings.

6 Sharing Your Personal Data

phnjoy does not sell or rent your personal data to any third party. We share your personal data only in the following limited circumstances:

6.1 Service Providers (Personal Information Processors)

phnjoy engages trusted third-party service providers to assist in operating the platform, including: KYC identity verification providers, payment gateway operators, cloud hosting and infrastructure providers, fraud detection and security services, and customer support software providers. All third-party processors are bound by data processing agreements that require them to handle your personal data in accordance with the Data Privacy Act and phnjoy's instructions.

6.2 Regulatory and Law Enforcement Authorities

phnjoy is required by law to disclose certain personal data and transaction records to PAGCOR as part of its regulatory reporting obligations, to the Anti-Money Laundering Council (AMLC) where transactions meet the reporting thresholds under the AMLA, and to Philippine law enforcement agencies in response to lawful orders, subpoenas, or court processes.

6.3 Game Providers

Some game providers whose products are integrated into the phnjoy platform may receive limited technical identifiers (such as anonymised session tokens) to deliver their games. phnjoy does not share your full identity or financial data with game providers beyond what is strictly necessary for game delivery and dispute resolution.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of phnjoy's business or assets, personal data held by phnjoy may be transferred to the acquiring entity, subject to that entity agreeing to process your personal data in accordance with the Data Privacy Act and this Privacy Policy.

7 Data Retention Periods

phnjoy retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• KYC identity documents and verification records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR and the Anti-Money Laundering Council.
• Financial transaction records (deposits, withdrawals, wager histories): Retained for a minimum of five (5) years from the date of each transaction.
• Account activity logs and security records: Retained for a minimum of two (2) years from the date of generation.
• Customer support communications: Retained for two (2) years from the date of the last communication in a support thread.
• Marketing communication preferences and consent records: Retained for the duration of your active account and for two (2) years following account closure.

Following the expiry of the applicable retention period, phnjoy will securely delete or anonymise your personal data in a manner that prevents reconstruction of the original data.

8 Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by phnjoy:

To exercise any of these rights, contact the phnjoy Data Protection Officer at [email protected] with the subject line "Data Privacy Request." Please include sufficient information to allow phnjoy to verify your identity before processing your request. phnjoy will not charge a fee for exercising your data privacy rights unless your request is manifestly unfounded, repetitive, or excessive.

9 Cookies and Tracking Technologies

9.1 What Cookies We Use

The phnjoy platform uses the following categories of cookies and similar tracking technologies:

• Strictly necessary cookies: Essential for the platform to function correctly, including session authentication, security tokens, and account login state. These cannot be disabled without preventing access to the platform.
• Functional cookies: Remember your preferences such as language settings, responsible gaming configurations, and display preferences to provide a personalised experience.
• Analytics cookies: Used to collect aggregated, anonymised data about how players interact with the phnjoy platform, enabling phnjoy to identify performance issues and improve the user experience.
• Security and fraud prevention cookies: Help detect and prevent fraudulent activity, multi-accounting, and unusual session behaviour.

9.2 Managing Cookies

You may manage your cookie preferences through your browser's settings. Please note that disabling strictly necessary cookies will prevent you from logging into your phnjoy account and using the platform's core services. phnjoy does not use third-party advertising or retargeting cookies.

10 Children's Privacy and Age Restrictions

The phnjoy platform is strictly intended for individuals who are at least twenty-one (21) years of age. phnjoy does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the phnjoy account registration and KYC process.

If phnjoy becomes aware that personal data has been collected from an individual under the age of 21, the relevant account will be immediately suspended, the personal data will be deleted as promptly as practicable consistent with phnjoy's legal obligations, and any deposited funds will be returned to their source. Parents or guardians who believe a minor has registered a phnjoy account should contact [email protected] immediately.

11 Security Measures

phnjoy employs a range of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction:

• Transport Layer Security (TLS): All data transmitted between your device and the phnjoy platform is encrypted using TLS encryption.
• Data encryption at rest: Sensitive personal data and identity documents stored in phnjoy's systems are encrypted using AES-256 encryption.
• Access controls: Access to personal data within phnjoy's systems is granted on a need-to-know basis using role-based access controls. All data access by phnjoy personnel is logged and audited.
• Two-factor authentication: Available for all phnjoy player accounts and mandatory for administrative access to phnjoy's internal systems.
• Regular security assessments: phnjoy conducts periodic vulnerability assessments and security reviews of its platform and data infrastructure.
• Employee training: All phnjoy personnel with access to personal data receive data privacy and security training consistent with the requirements of the Data Privacy Act.

While phnjoy takes every reasonable precaution to protect your personal data, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your phnjoy account, enable two-factor authentication, and notify phnjoy immediately if you suspect any unauthorised access to your account.

12 Changes to This Privacy Policy

phnjoy may update this Privacy Policy from time to time to reflect changes in its data processing practices, legal obligations, or regulatory requirements. When material changes are made, phnjoy will notify registered players by email to their registered address and/or by displaying a prominent notice on the phnjoy platform dashboard prior to the updated policy taking effect.

The date of the most recent revision is displayed at the top of this Privacy Policy. Your continued use of the phnjoy platform after the effective date of a revised Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree with the revised Privacy Policy, you should discontinue use of the phnjoy platform and may request account closure by contacting the phnjoy support team.

The current version of this Privacy Policy is always available at phnjoy.cam/privacy-policy.