Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") applies to phhsky and governs the collection, use, storage, disclosure, and protection of personal information gathered through the phhsky website, mobile applications, and all related services (collectively, the "Platform"). This Policy applies to all registered users, visitors, and any individual whose personal data is processed by phhsky in connection with our services.

phhsky is committed to processing personal data lawfully, transparently, and only for specified, legitimate purposes. If you have any questions about this Policy or how your data is handled, you may contact our Data Protection Officer (DPO) at [email protected].

2. Legal Basis for Data Processing

phhsky processes personal data on the following legal bases under Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our contractual obligations to you as a registered player, including account management, payment processing, and game service delivery;
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulatory requirements, Anti-Money Laundering Act (AMLA) obligations, and Bureau of Internal Revenue (BIR) reporting requirements;
• Legitimate Interest: Processing is necessary for fraud prevention, security monitoring, and the continuous improvement of our Platform;
• Consent: For specific processing activities such as marketing communications and profiling for personalized promotions, we rely on your freely given, specific, and informed consent.

3. Personal Data We Collect

phhsky collects personal data through various means, including direct collection during registration and gameplay, automated collection through cookies and analytics tools, and third-party verification services. The categories of personal data we collect include:

3.1 Identity and Contact Information

• Full legal name as it appears on government-issued identification;
• Date of birth (to verify you are 21 years of age or older);
• Residential address, including barangay, city or municipality, province, and postal code;
• Email address and mobile phone number;
• Government-issued identification numbers (e.g., Philippine passport, driver's license, SSS/GSIS number, TIN) collected during KYC verification.

3.2 Financial Information

• GCash account number and registered mobile number;
• Maya / PayMaya account details;
• Bank account information (for bank transfer withdrawals via BPI, BDO, Metrobank, or other accredited Philippine banks);
• Transaction history, including deposits, withdrawals, and wager amounts;
• Source of funds documentation (for enhanced due diligence on large transactions).

3.3 Technical and Usage Data

• IP address and geographic location data;
• Device identifiers, operating system, and browser type;
• Session logs, including login timestamps, session duration, and pages visited;
• Game activity logs, including games played, wager amounts, and win/loss records;
• Cookies and similar tracking technologies (see Section 8 for details).

3.4 Communications Data

• Records of all communications between you and phhsky customer support;
• Live chat transcripts, email correspondence, and support ticket history;
• Responses to surveys, feedback forms, and promotional participation records.

4. How We Use Your Personal Data

5. Disclosure of Personal Data

phhsky does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may, however, share your personal data with the following categories of recipients under strictly controlled circumstances:

• PAGCOR and Regulatory Authorities: As required by our operating license and Philippine gaming regulations, we are obligated to disclose player data to PAGCOR upon request and as part of regular regulatory reporting;
• Anti-Money Laundering Council (AMLC): Transaction records and suspicious activity reports may be submitted to the AMLC in compliance with Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments;
• Payment Processing Partners: Financial institutions and e-wallet service providers (GCash, Maya, BPI, BDO, etc.) receive transaction data necessary to process your deposits and withdrawals;
• Identity Verification Providers: Third-party KYC service providers process identity documents to assist with account verification, operating under data processing agreements that bind them to equivalent data protection standards;
• Law Enforcement and Courts: We may disclose personal data when legally compelled by subpoena, court order, or other binding legal process issued by Philippine authorities;
• IT Infrastructure and Cloud Providers: Technical service providers hosting and maintaining the phhsky Platform may process data on our behalf under strict contractual data protection obligations.

All third-party service providers that process phhsky player data are required to maintain confidentiality, implement appropriate technical and organizational security measures, and process data solely for the purposes specified by phhsky.

6. Data Retention

phhsky retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AMLA record-keeping obligations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and applicable tax regulations;
• Customer support communications: Retained for three (3) years from the date of the last communication;
• Technical and session logs: Retained for a maximum of twelve (12) months, after which they are anonymized or permanently deleted;
• Marketing and consent records: Retained until you withdraw consent or for three (3) years from your last interaction with marketing communications, whichever is earlier.

7. 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 processed by phhsky:

• Right to be Informed: You have the right to know that your personal data is being collected and processed, and to receive clear information about how it is used;
• Right of Access: You may request a copy of the personal data we hold about you, including information on how it has been processed;
• Right to Rectification: You may request correction of inaccurate, incomplete, or outdated personal data at any time;
• Right to Erasure or Blocking: You may request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing, profiling, and certain other purposes based on legitimate interest;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: You have 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 these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days of receipt, as required by the Data Privacy Act.

8. Cookies and Tracking Technologies

phhsky uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your login session, prevent fraud, and analyze usage patterns. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled, as they are required for login sessions, security, and core game functionality;
• Performance and Analytics Cookies: Collect anonymized information about how players use the Platform to help us improve performance and user experience;
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations;
• Marketing and Profiling Cookies: Used only with your consent to deliver personalized promotions and track the effectiveness of our marketing activities.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to access core Platform features, but may limit personalization and some functional conveniences.

9. Data Security

phhsky implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Multi-factor authentication (MFA) options for account access;
• Regular penetration testing and vulnerability assessments by independent security firms;
• Role-based access controls limiting employee access to personal data on a strictly need-to-know basis;
• Encrypted storage of sensitive data at rest, including financial information and identity documents;
• Continuous 24/7 security monitoring and automated intrusion detection systems.

In the event of a personal data breach that poses a real risk to the rights and freedoms of affected data subjects, phhsky will notify the National Privacy Commission (NPC) within seventy-two (72) hours of discovery, and will communicate directly with affected users as soon as reasonably practicable.

10. Children and Minors

The phhsky Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. phhsky does not knowingly collect personal data from persons under the age of 21. If we discover that a minor has registered an account or provided personal data, we will immediately close the account, void all transactions, and permanently delete the associated personal data.

If you are a parent or guardian and believe that a minor in your care has created a phhsky account, please contact us immediately at [email protected] so we can take prompt corrective action.

11. International Data Transfers

phhsky primarily processes and stores personal data within the Philippines. Where it becomes necessary to transfer data outside the Philippines — for example, to international cloud infrastructure providers or game software suppliers — phhsky ensures that equivalent levels of data protection are maintained through contractual safeguards, including data processing agreements that impose obligations consistent with the Philippine Data Privacy Act.

12. Changes to This Privacy Policy

phhsky reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated via Platform notification or email to your registered address. The "Last Updated" date at the top of this page indicates the most recent revision.

Your continued use of the phhsky Platform following any update to this Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed of how we are protecting your data.

13. Contact and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact the phhsky Data Protection Officer:

Email: [email protected]
Response time: Within 30 calendar days of receipt
Languages: English and Tagalog
Availability: 24 hours a day, 7 days a week

You also have the right to escalate unresolved concerns to the National Privacy Commission of the Philippines (NPC) at [email protected] or by visiting the NPC's official website.