Privacy Policy

SECTION 01

Introduction & Scope

This Privacy Policy applies to all personal information collected, processed, stored, or shared by phfan in connection with the operation of the phfan platform accessible at phfan.vip, including all gaming products, account services, payment facilities, customer support channels, and marketing communications.

phfan is committed to complying with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). phfan is also bound by applicable data protection requirements under its PAGCOR gaming licence.

By registering for a phfan Account, making a deposit, or accessing any feature of the phfan platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal information as described herein. If you do not agree with any part of this Policy, you should not proceed with registration or continued use of phfan.

SECTION 02

Data Controller

For the purposes of the Philippine Data Privacy Act and PAGCOR regulatory requirements, the data controller responsible for the personal information collected through the phfan platform is the licensed operator of phfan.vip. As the data controller, phfan determines the purposes and means of processing personal data collected from Philippine players and visitors.

phfan has designated a Data Protection Officer (DPO) as required under the DPA's Implementing Rules and Regulations. The DPO is responsible for overseeing phfan's compliance with data protection obligations and for handling data subject rights requests and privacy complaints. You may contact the phfan DPO through [email protected], marking your message clearly as a data privacy matter.

phfan is registered with the National Privacy Commission in accordance with applicable NPC registration requirements for personal information controllers operating in the Philippines.

SECTION 03

Data We Collect

3.1 Registration Data

When you create a phfan Account, we collect the following personal information:

• Full legal name as appearing on your Philippine government-issued ID
• Date of birth (for age verification — phfan is 21+ only under PAGCOR regulations)
• Philippine mobile number
• Email address
• Username and hashed account password
• Residential address in the Philippines

3.2 Identity Verification (KYC) Data

In compliance with PAGCOR licensing requirements and Philippine AML regulations, phfan collects the following during KYC verification:

• Scanned or photographed copies of valid Philippine government-issued ID (e.g., UMID, PhilSys National ID, driver's licence, passport)
• Selfie photographs or video for liveness verification where required
• Proof of address documentation where applicable
• Source of funds declarations for high-value accounts as required under PAGCOR AML compliance rules

3.3 Transaction and Payment Data

phfan collects financial data necessary to process deposits, withdrawals, and internal transfers, including:

• GCash account numbers, Maya wallet identifiers, and bank account details (BPI, BDO, Metrobank, and others) used for transactions
• Transaction amounts, dates, and reference numbers
• Card details (partial — phfan does not store full card numbers; card data is tokenized by our payment processor)
• Transaction history within the phfan platform

3.4 Gaming and Behavioral Data

phfan collects data about your activity on the platform for operational, regulatory, and responsible gaming purposes:

• Game history — titles played, wagers placed, outcomes, and session timestamps
• Betting patterns and frequency metrics
• Responsible gaming tool usage and settings
• Login timestamps and session duration records

3.5 Technical and Device Data

phfan automatically collects technical data when you access the platform:

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser information
• Referring URL and navigation path within the platform
• Cookie identifiers and session tokens (see Section 7)

SECTION 04

How We Use Your Data

phfan uses the personal information it collects for the following purposes:

• Account management: Creating, maintaining, and securing your phfan Account, including processing phfan login requests, password resets, and two-factor authentication
• Payment processing: Facilitating deposits via GCash, Maya, and local banks, and processing withdrawal requests to verified payment methods
• Regulatory compliance: Meeting phfan's obligations under the PAGCOR licence, including player identity verification, AML transaction monitoring, and filing of required reports to PAGCOR and the AMLC
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling indicators, administering self-exclusion and deposit limit tools, and complying with PAGCOR responsible gaming directives
• Customer support: Responding to enquiries, complaints, and disputes submitted to phfan's support team at [email protected]
• Platform security: Detecting and preventing fraud, unauthorized Account access, bonus abuse, money laundering, and other prohibited conduct
• Platform improvement: Analyzing aggregated, anonymized usage data to improve the phfan platform experience for Filipino players
• Marketing: Sending promotional offers and platform updates to players who have opted in to receive marketing communications from phfan

SECTION 05

Legal Bases for Processing

Under the Philippine Data Privacy Act, phfan processes personal information on the following legal bases:

• Contractual necessity: Processing required to create and maintain your phfan Account, process your deposits and withdrawals, and deliver gaming services you have requested
• Legal obligation: Processing required to comply with phfan's obligations under the PAGCOR gaming licence, the Philippine AML Act (Republic Act No. 9160 as amended), the DPA, and applicable PAGCOR circulars and directives
• Legitimate interests: Processing for fraud prevention, account security, platform integrity, and aggregated analytics — where these interests are not overridden by your rights and freedoms as a data subject
• Consent: Processing for marketing communications and optional analytics features — where you have given free, specific, informed, and unambiguous consent that you may withdraw at any time

SECTION 06

Data Sharing & Disclosure

6.1 Service Providers

phfan shares personal data with third-party service providers who perform functions on our behalf, including payment processors (GCash/Maya API integrators, card processing partners), identity verification providers, game platform technology providers, cloud hosting and infrastructure services, and customer relationship management systems. All such providers are bound by data processing agreements that restrict their use of your data to the specific services they provide to phfan and prohibit them from using it for their own independent purposes.

6.2 Regulatory and Law Enforcement Disclosure

phfan is required by law and by the terms of its PAGCOR licence to disclose personal data to:

• PAGCOR — as part of licensing compliance reporting and in response to regulatory investigations
• The Anti-Money Laundering Council (AMLC) — for suspicious transaction and covered transaction reporting as required under the Philippine AML Act
• Philippine law enforcement authorities — in response to lawful court orders, subpoenas, or official requests from the NBI, PNP, or other competent authorities
• The National Privacy Commission — in the event of a reportable personal data breach or in response to NPC investigations

6.3 No Sale of Personal Data

6.4 Business Transfers

In the event that phfan undergoes a corporate restructuring, merger, acquisition, or transfer of assets, personal data held by phfan may be transferred to the acquiring entity, subject to that entity assuming the same data protection obligations set out in this Policy and as required under the DPA.

SECTION 07

Cookies & Tracking Technologies

phfan uses cookies, session tokens, and similar tracking technologies to operate the platform. Cookies are small text files stored on your device by your browser when you visit phfan.vip. The following categories of cookies are used:

• Strictly necessary cookies: Required for phfan login session management, security token validation, and core platform functionality. These cannot be disabled without breaking fundamental platform features.
• Performance and analytics cookies: Used to collect aggregated data about how players navigate the phfan platform, which pages are most visited, and where technical errors occur. This data is used exclusively to improve platform performance.
• Functional cookies: Store your preferences such as language settings and responsible gaming tool configurations so they persist across sessions.

You may manage non-essential cookies through your browser settings. Most modern browsers on Android (Chrome), iPhone (Safari), and desktop allow you to block or delete cookies. Note that disabling certain cookies may degrade your phfan platform experience. phfan does not use third-party advertising cookies or tracking pixels for external ad targeting.

SECTION 08

Data Retention

phfan retains personal data for only as long as is necessary for the purpose for which it was collected, or as required by applicable legal and regulatory obligations, whichever is longer. The following general retention principles apply:

• Active Account data: Retained for the full duration of your phfan Account and for a period of at least five (5) years following Account closure, in accordance with PAGCOR record-keeping requirements
• KYC and identity documents: Retained for a minimum of five (5) years from the date of verification or Account closure, as required under Philippine AML legislation
• Transaction records: Retained for a minimum of five (5) years as required under PAGCOR and AMLC compliance frameworks
• Support and communications records: Retained for three (3) years from the date of the last communication for dispute resolution and quality assurance purposes
• Marketing data: Retained until consent is withdrawn or the Account is closed, whichever occurs first

Following the expiry of applicable retention periods, personal data is securely deleted from phfan systems or irreversibly anonymized such that it can no longer be associated with you as an individual.

SECTION 09

Security Measures

phfan implements a range of technical and organizational security measures to protect your personal data from unauthorized access, loss, alteration, or disclosure. These include:

• 256-bit SSL/TLS encryption on all data transmission between your browser and phfan servers — the same standard used by Philippine banks
• Encryption at rest for sensitive personal data including KYC documents and payment details stored in phfan's infrastructure
• Role-based access controls ensuring that phfan employees can only access personal data necessary for their specific job functions
• Multi-factor authentication for phfan administrative systems
• Regular penetration testing and vulnerability assessments by independent cybersecurity professionals
• Automated anomaly detection for suspicious login attempts and unusual transaction patterns

SECTION 10

Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by phfan:

• Right to be informed: The right to know whether phfan holds personal information about you and to receive clear information about how it is processed — satisfied by this Privacy Policy
• Right of access: The right to receive a copy of your personal information processed by phfan upon verified request
• Right to rectification: The right to have inaccurate or incomplete personal information corrected
• Right to erasure: The right to request deletion of your personal information where retention is no longer required by law or legitimate purpose, subject to legal retention obligations
• Right to object: The right to object to processing of your personal information based on legitimate interests or for direct marketing purposes
• Right to data portability: The right to receive your personal information in a structured, commonly used electronic format
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission if you believe phfan has violated your data privacy rights

To exercise any of the above rights, please contact the phfan Data Protection Officer at [email protected] with the subject line "Data Privacy Request". phfan will respond within thirty (30) days of receiving a verified request. phfan may need to verify your identity before processing your request.

SECTION 11

Minors & Age Verification

If you believe that a minor has registered for a phfan Account or that your child's personal information has been collected by phfan without your knowledge, please contact us immediately at [email protected].

SECTION 12

International Data Transfers

phfan's primary data processing infrastructure is located in Asia. Some of phfan's service providers — including game technology platform providers and cloud infrastructure services — may operate data centers in jurisdictions outside the Philippines, including Singapore and other countries in Southeast Asia.

Where personal data is transferred outside the Philippines, phfan ensures that appropriate safeguards are in place in accordance with the DPA's requirements for cross-border data transfers. These safeguards include contractual data transfer agreements that impose data protection standards equivalent to those required under the Philippine DPA, and phfan conducts due diligence on recipient countries' data protection frameworks before engaging in transfers.

phfan does not transfer KYC documents or sensitive financial data to jurisdictions that do not provide an adequate level of data protection without appropriate contractual safeguards in place.

SECTION 13

Marketing Communications

phfan may send you promotional communications — including bonus offers, new game announcements, tournament invitations, and platform updates — by SMS, email, and in-platform notification, where you have consented to receiving such communications.

You may opt out of marketing communications at any time by:

• Updating your communication preferences in Account Settings after phfan login
• Clicking the unsubscribe link included in any phfan promotional email
• Contacting phfan support at [email protected] with a request to unsubscribe

Opting out of marketing communications does not affect transactional messages that phfan is required to send you — such as Account security alerts, deposit confirmations, withdrawal status notifications, and responsible gaming reminders — as these are necessary for Account operation and regulatory compliance.

SECTION 14

Policy Amendments

phfan reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Where a material change is made, phfan will notify registered players via email to the address on file or through an in-platform notification upon next phfan login.

The date of the most recent update is indicated at the top of this page. We encourage you to review this Policy periodically. Your continued use of the phfan platform following notification of a material update constitutes your acceptance of the revised Policy.

Where an update is required to comply with a new or amended legal obligation, it may take effect immediately upon publication without prior notice. phfan will endeavor to provide advance notice of all other material changes.

SECTION 15

Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by phfan, please contact:

• phfan Data Protection Officer: [email protected] — Please mark your message clearly as a data privacy matter.

phfan undertakes to respond to all data privacy enquiries and rights requests within thirty (30) days. If you are not satisfied with phfan's response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. Information about filing a complaint with the NPC is available on the NPC's official website.

For responsible gaming concerns — including self-exclusion requests, deposit limit adjustments, or access to the PAGCOR Problem Gambling Assistance Program — please visit phfan's Responsible Gaming page or contact [email protected].