phpak Privacy Policy

1. Introduction

phpak.club ("phpak", "we", "us", "our") is committed to protecting the privacy and personal data of all users of our online gaming platform. This Privacy Policy ("Policy") explains what personal data phpak collects from players and visitors, why we collect it, how we use and protect it, and the rights you have over your own data under Philippine law — in particular, the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

By registering an account on phpak or otherwise accessing our platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not consent to this Policy, you must not use phpak.

2. Data Controller

phpak.club is the data controller responsible for the personal data collected through the phpak platform. As data controller, phpak determines the purposes and means of processing your personal data and is accountable for ensuring that processing is carried out in accordance with this Policy and applicable Philippine data privacy law.

For all data privacy inquiries, requests, and complaints, phpak can be contacted via the details set out in Section 14 of this Policy.

3. Personal Data We Collect

phpak collects the following categories of personal data, depending on your interaction with the platform:

• Identity data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., UMID number, Passport number, Driver's License number).
• Contact data: Philippine mobile number, email address, and residential address.
• Account data: Username, encrypted password, account registration date, account status, and KYC verification status.
• Financial data: GCash number, Maya account details, bank account numbers (where provided for bank transfer withdrawals), deposit and withdrawal transaction records, and wallet balance history.
• Gaming data: Game history, session logs, bets placed, winnings, losses, bonus usage, and responsible gaming tool settings (deposit limits, self-exclusion status).
• Technical data: IP address, device type, browser type, operating system, login timestamps, and session duration.
• Communications data: Records of correspondence between you and phpak's support team, including live chat transcripts and email exchanges.
• KYC documentation: Scanned or photographed copies of government-issued Philippine identification documents and proof of address submitted for identity verification.

4. How We Collect Your Data

phpak collects personal data through the following means:

• Direct provision: Data you provide when registering an account, completing KYC, contacting support, or updating your profile.
• Automated collection: Technical data collected automatically when you access the phpak platform, including via cookies, server logs, and similar technologies.
• Payment processors: Financial data transmitted by GCash, Maya, and other integrated payment providers when you initiate a deposit or withdrawal through phpak.
• Identity verification providers: Data returned by third-party KYC service providers engaged by phpak to verify government-issued Philippine identification documents.
• Fraud prevention services: Data received from third-party fraud detection and AML screening services as part of phpak's compliance obligations.

5. Purpose and Legal Basis for Processing

phpak processes your personal data for the following purposes and on the following legal bases:

• Account management and service delivery — to create and maintain your phpak account, process deposits and withdrawals, and provide access to Games. Legal basis: performance of contract.
• KYC and identity verification — to verify your identity and age in compliance with applicable legal and regulatory requirements. Legal basis: legal obligation.
• Anti-money laundering (AML) and fraud prevention — to screen transactions and account activity for indicators of money laundering, fraud, or other financial crime. Legal basis: legal obligation and legitimate interest.
• Responsible gaming compliance — to enforce the 21+ age requirement, administer player-requested deposit limits and self-exclusion, and monitor for signs of problem gambling. Legal basis: legal obligation and legitimate interest.
• Customer support — to handle your inquiries, complaints, and dispute submissions. Legal basis: performance of contract and legitimate interest.
• Platform security — to protect the phpak platform and its users from unauthorised access, fraud, and abuse. Legal basis: legitimate interest.
• Marketing communications — to send you promotional offers and platform updates, where you have consented. Legal basis: consent. You may withdraw this consent at any time by contacting phpak support.
• Legal compliance and regulatory reporting — to meet phpak's obligations under Philippine law, including reporting obligations to relevant regulatory authorities. Legal basis: legal obligation.

6. Sharing Your Personal Data

phpak does not sell your personal data to third parties. phpak may share your personal data with the following categories of recipients, strictly as necessary for the purposes described in this Policy:

• Payment service providers: GCash (G-Xchange, Inc.), Maya (Voyager Innovations), and other payment processors integrated into phpak's cashier, to process deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to verify the authenticity of government-issued Philippine identification documents.
• Fraud and AML screening providers: Third-party compliance technology providers that screen transactions and user profiles against watchlists and risk indicators.
• Game providers: Game studios whose titles are available on phpak (e.g., JILI Games, PG Soft) may receive anonymised session data for RNG certification and game performance auditing purposes.
• Regulatory and law enforcement authorities: phpak will disclose personal data to PAGCOR, the National Privacy Commission of the Philippines, AMLC, or other competent authorities where required by law or regulatory directive.
• Professional advisers: Legal, accounting, and audit firms engaged by phpak, subject to professional confidentiality obligations.

All third-party service providers engaged by phpak are contractually required to process personal data solely for the purposes for which it was shared and to implement appropriate technical and organisational security measures.

7. Data Retention

phpak retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law, whichever is longer.

• Account data and transaction records are retained for a minimum of five (5) years from the date of the last transaction or account closure, in compliance with AML record-keeping requirements under the Anti-Money Laundering Act (AMLA) of the Philippines.
• KYC documentation is retained for a minimum of five (5) years following account closure.
• Support communications are retained for three (3) years.
• Technical and session data collected for security purposes is retained for twelve (12) months.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents reconstruction of the original data.

8. Security Measures

phpak implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phpak's servers;
• Encryption of sensitive data fields (including passwords and payment identifiers) at rest using industry-standard cryptographic algorithms;
• Role-based access controls limiting phpak staff access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of phpak's platform infrastructure;
• Intrusion detection systems and real-time monitoring for anomalous access patterns;
• Secure deletion protocols applied to data that has reached the end of its retention period.

While phpak takes all reasonable precautions to protect your data, no system is entirely immune from risk. If you suspect that your phpak account has been compromised, contact support immediately via live chat.

9. Cookies and Tracking Technologies

phpak uses cookies and similar tracking technologies to operate the platform, maintain session state, detect fraud, and analyse platform performance. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies and security tokens. They cannot be disabled without rendering the platform inoperable.
• Functional cookies: Used to remember your preferences, language settings, and recent game history. These improve your experience but are not essential.
• Analytics cookies: Used to collect anonymised data on how players use phpak, including pages visited, session duration, and navigation paths. This data helps phpak improve the platform.
• Security cookies: Used to detect and prevent fraudulent activity, including bot access and account takeover attempts.

You may control non-essential cookies through your browser settings. Disabling cookies may affect the functionality of certain parts of the phpak platform.

10. Your Data Privacy Rights

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

• Right to be informed: The right to know what personal data phpak collects about you and how it is used — this Policy fulfils that obligation.
• Right to access: The right to request a copy of the personal data phpak holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where phpak no longer has a legal basis to retain it, subject to phpak's legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to object: The right to object to processing of your personal data for direct marketing purposes.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe phpak has breached your data privacy rights.

To exercise any of these rights, contact phpak's Data Privacy Officer using the details in Section 14. phpak will respond to verified requests within thirty (30) days.

11. Children's Privacy

phpak is strictly an adult platform. Access is limited to persons aged 21 and above. phpak does not knowingly collect personal data from persons under 21 years of age. If phpak determines that an account has been registered by a minor, the account will be immediately closed, all personal data associated with it deleted, and any deposited funds returned via the original payment method. If you believe a minor has registered on phpak, please contact support immediately.

12. Cross-Border Data Transfers

phpak's primary data processing infrastructure is located within or serving the Philippine market. Where personal data is transferred to third-party service providers whose systems are located outside the Philippines (for example, cloud hosting providers or international KYC services), phpak ensures that such transfers are made only to recipients that offer an adequate level of data protection through contractual safeguards consistent with the requirements of RA 10173 and its Implementing Rules.

13. Changes to This Privacy Policy

phpak reserves the right to amend this Privacy Policy at any time. Users will be notified of material changes via the email address or mobile number registered to their phpak account and/or via a prominent notice on the platform. The effective date at the top of this Policy will be updated accordingly. Continued use of phpak following the effective date of any amendment constitutes acceptance of the revised Policy.

14. Contact & Complaints

For questions, data access requests, or complaints regarding this Privacy Policy or phpak's handling of your personal data, please contact us:

• Data Privacy Officer, phpak
• Email: [email protected]
• Live Chat: Available 24/7 via the phpak platform
• Response time: Within 30 days for formal data privacy requests

If you are not satisfied with phpak's response to your complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines at privacy.gov.ph (plain text — not a link).