phgold Privacy Policy

1. Who We Are

phgold is the operator of the online gaming platform accessible at phgold.club ("Platform"). For the purposes of the Data Privacy Act of 2012, phgold acts as the Personal Information Controller (PIC) in respect of the personal data of registered players and website visitors. phgold operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR).

For all privacy-related inquiries, including requests to exercise your data subject rights, you may contact our Data Protection Officer (DPO) as described in Section 13 of this Policy.

2. Personal Data We Collect

2.1 Identity and Contact Data

When you register a phgold account, we collect information necessary to establish your identity, verify your age, and comply with PAGCOR's Know Your Customer (KYC) obligations under Philippine anti-money laundering regulations. This includes:

• Full legal name as it appears on a valid Philippine government-issued ID
• Date of birth (for age verification — you must be 21 or older)
• Philippine mobile number
• Email address
• Residential address in the Philippines
• Government-issued ID type and number (e.g., PhilSys ID, passport, driver's license, UMID)
• Selfie photograph with ID (for KYC verification)

2.2 Financial Data

To process deposits and withdrawals, phgold collects and processes payment-related information, including:

• GCash mobile number and account name
• Maya account details
• Bank account details for BPI, BDO, Metrobank, or UnionBank transfers
• Cryptocurrency wallet addresses (for USDT TRC20 transactions)
• Transaction history, deposit amounts, and withdrawal records

2.3 Gaming Activity Data

phgold records all gaming activity associated with your account, including game sessions played, wagers placed, winnings and losses, betting history, bonus usage and wagering progress, and any sports betting selections.

2.4 Technical and Device Data

When you access the phgold platform, our systems automatically collect certain technical data, including your IP address, device type and model, operating system, browser type and version, session timestamps, and login location data.

2.5 Communications Data

If you contact phgold's support team, we retain records of your communications, including live chat transcripts, email correspondence, and any documentation submitted in connection with a support request.

3. How We Collect Personal Data

phgold collects personal data through the following channels:

• Direct submission: Information you provide during account registration, KYC verification, deposit or withdrawal requests, and customer support interactions.
• Automated collection: Technical and device data collected automatically when you access the phgold website or mobile application via cookies, web beacons, log files, and similar tracking technologies.
• Third-party providers: Identity verification and KYC data from accredited verification service providers; payment data from GCash, Maya, and other payment processors; and fraud risk signals from security service partners.
• PAGCOR regulatory reporting: In some instances, phgold may receive or be required to share data with PAGCOR as part of its ongoing regulatory obligations.

4. Purpose and Legal Basis for Processing

phgold processes your personal data only where there is a lawful basis to do so under the Data Privacy Act of 2012. The primary purposes and corresponding legal bases for our data processing activities are as follows:

• Contract performance: Processing necessary to create and manage your phgold account, execute financial transactions, and deliver the gaming services you have requested.
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, the Anti-Money Laundering Act of 2001 (RA 9160 as amended), and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of platform features — where phgold's legitimate interests are not overridden by your fundamental rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Disclosure and Data Sharing

phgold does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following limited circumstances:

5.1 Service Providers (Personal Information Processors)

phgold engages third-party service providers who process personal data on our behalf as Personal Information Processors (PIPs) under binding data processing agreements. These include: KYC and identity verification providers, payment processors (GCash, Maya, banking partners), cloud infrastructure and hosting providers, cybersecurity and fraud prevention services, and customer support software platforms.

5.2 Regulatory and Law Enforcement Disclosure

phgold discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities when required by law, regulation, or valid legal process. phgold will notify affected users of government data requests where legally permitted to do so.

5.3 Corporate Transactions

In the event of a merger, acquisition, or sale of assets involving phgold, personal data held by phgold may be transferred to the successor entity, subject to the same privacy protections as set out in this Policy. Affected users will be notified in advance of any such transfer.

6. Cookies and Tracking Technologies

The phgold website uses cookies and similar tracking technologies to ensure proper platform functionality, maintain user sessions, prevent fraud, and analyze platform usage patterns. The categories of cookies used by phgold are:

• Strictly necessary cookies: Essential for the operation of the phgold platform, including session management, login authentication, and security functions. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Used to remember your preferences and settings, such as your preferred language and display settings.
• Analytical cookies: Used to collect aggregated, anonymized data about how users interact with the phgold platform. This data helps phgold improve platform performance and user experience.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and suspicious login attempts.

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the phgold platform.

7. Data Retention

phgold retains your personal data for as long as is necessary to fulfill the purposes described in this Policy, to comply with our legal and regulatory obligations, and to resolve disputes or enforce agreements. Specific retention periods include:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years following each transaction, in compliance with AMLC record-keeping requirements.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the activity.
• Support communications: Retained for two (2) years from the date of the interaction, unless the communication relates to an ongoing dispute.
• Technical and device logs: Retained for twelve (12) months, except where logs are required as evidence in connection with a security incident or investigation.

Following the expiration of the applicable retention period, phgold will securely delete or anonymize your personal data in accordance with NPC-approved data disposal procedures.

8. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and phgold servers
• Encryption of sensitive data at rest, including financial credentials and government ID data
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis
• Two-factor authentication (2FA) for player account access and phgold administrative systems
• Regular security audits and penetration testing of phgold's infrastructure
• Automated intrusion detection and anomalous login monitoring
• Data breach response procedures compliant with NPC notification requirements (72-hour breach notification obligation)

9. Your Rights as a Data Subject

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 phgold:

• Right to be Informed: The right to be notified of how your personal data is collected, used, and disclosed — as set out in this Privacy Policy.
• Right to Access: The right to request a copy of the personal data phgold holds about you, and information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update certain information directly through your phgold account settings.
• Right to Erasure / Right to be Forgotten: 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 phgold's legal retention obligations.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Object: The right to object to the processing of your personal data, in particular where processing is based on legitimate interests or for direct marketing purposes.
• Right to Damages: The right to claim compensation for any damages sustained as a result of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data.
• Right to File a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please submit a written request to phgold's Data Protection Officer at the contact details in Section 13. phgold will respond to verified requests within fifteen (15) business days, or within such extended period as permitted by applicable regulations.

10. Children's Privacy

The phgold platform is strictly intended for individuals who are 21 years of age or older. phgold does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted on every account as a mandatory requirement of PAGCOR regulation.

If phgold becomes aware that personal data has been collected from a person under the age of 21, the account will be immediately suspended, all associated data will be deleted in accordance with NPC guidelines, and any deposited funds will be returned.

If you are a parent or guardian and believe your child may have circumvented phgold's age verification controls and created an account, please contact our DPO immediately at [email protected].

11. Cross-Border Data Transfers

phgold's primary data processing operations are conducted within the Philippines. In certain cases, personal data may be transferred to and processed by phgold's service providers operating outside the Philippines — for example, cloud infrastructure providers or KYC verification platforms with regional processing centers.

Where such cross-border transfers occur, phgold ensures that the recipient provides a comparable level of data protection through one of the following mechanisms: contractual data transfer agreements incorporating the NPC's standard data protection clauses; the recipient's certification under a recognized data protection framework; or the recipient's location in a country deemed by the NPC to provide adequate data protection.

12. Changes to This Privacy Policy

phgold reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws and regulations, or phgold platform operations. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision.

Material changes to this Policy will be communicated to registered players via the registered email address or via an in-platform notification at least seven (7) days prior to the effective date of the change, where practicable. Changes required by regulatory order may take effect immediately. Your continued use of the phgold platform following the effective date of any revised Policy constitutes acceptance of the updated terms.

13. Contact Us & Data Protection Officer

phgold has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and handling data subject rights requests. To contact phgold's DPO or our general privacy team:

You also have the right to file a complaint directly with the National Privacy Commission (NPC) of the Philippines. The NPC is the supervisory authority for data protection matters in the Republic of the Philippines.