phkilig Privacy Policy

1. Introduction

1.1 phkilig is committed to protecting the privacy and personal data of all users of the phkilig Platform. This Privacy Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

1.2 This Policy applies to all personal data collected by phkilig through the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and use of our website and mobile application.

1.3 phkilig acts as the Personal Information Controller ("PIC") in respect of the personal data it collects and processes. Where phkilig engages third-party service providers to process data on its behalf, those providers act as Personal Information Processors ("PIP") and are bound by data processing agreements consistent with the DPA.

2. Personal Data We Collect

phkilig collects the following categories of personal data:

2.1 Registration and Identity Data:

• Full legal name, date of birth, and gender;
• Government-issued identification number and document type;
• Residential address (including city — Manila, Cebu, Davao, Quezon City, Makati, or other Philippine cities);
• Email address and mobile phone number;
• Username and encrypted password.

2.2 Financial and Transaction Data:

• GCash account number or PayMaya/Maya account details;
• Bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) where applicable;
• Debit card details (card number is not stored in full; only masked card data is retained);
• Deposit and withdrawal history, transaction amounts in Philippine Peso (₱), and timestamps.

2.3 Gameplay and Platform Data:

• Game history, bet amounts, win/loss records, and session durations;
• Bonus and promotion usage history;
• Responsible gaming settings, including deposit limits and self-exclusion records.

2.4 Technical and Device Data:

• IP address, device type, operating system, and browser type;
• Cookies and similar tracking technologies (see Section 8);
• Login timestamps and session activity logs.

2.5 Communications Data:

• Records of customer support interactions via live chat or email;
• Survey responses and feedback submitted through the Platform.

3. How We Use Your Personal Data

phkilig uses your personal data for the following purposes:

• Account Management: To register, verify, and maintain your phkilig account, including KYC identity verification as required by Philippine gaming regulations;
• Service Delivery: To provide access to phkilig games, process deposits and withdrawals in Philippine Peso, and deliver bonuses and promotions;
• Legal Compliance: To comply with the DPA, anti-money laundering laws (AMLA), PAGCOR regulatory requirements, and other applicable Philippine laws;
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other prohibited conduct;
• Responsible Gaming: To monitor gameplay patterns and enforce responsible gaming measures, including self-exclusion and deposit limits;
• Customer Support: To respond to your inquiries, resolve disputes, and improve our support services;
• Platform Improvement: To analyze usage patterns, conduct research, and improve the phkilig Platform's features and performance;
• Marketing Communications: To send you promotional offers and updates about phkilig, where you have provided consent or where permitted by applicable law. You may opt out at any time.

4. Legal Basis for Processing

phkilig processes your personal data on the following legal bases under the DPA:

• Contractual Necessity: Processing necessary to perform our contract with you (i.e., to provide the phkilig Platform and services);
• Legal Obligation: Processing required to comply with applicable Philippine laws, including AMLA, PAGCOR regulations, and tax obligations;
• Legitimate Interests: Processing necessary for phkilig's legitimate interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications.

5. Data Sharing and Disclosure

5.1 phkilig does not sell, rent, or trade your personal data to third parties for their own commercial purposes.

5.2 phkilig may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya/Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions;
• Identity Verification Providers: Third-party KYC service providers engaged to verify your identity in compliance with Philippine regulations;
• Technology Service Providers: Cloud hosting, analytics, and platform infrastructure providers engaged to operate the phkilig Platform;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, and other Philippine government agencies where disclosure is required by law or regulation;
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid legal order or where necessary to prevent or investigate criminal activity.

5.3 Where phkilig engages third-party processors, it ensures that appropriate data processing agreements are in place, requiring those processors to handle your data in accordance with the DPA and this Privacy Policy.

6. Data Retention

6.1 phkilig retains your personal data for as long as your phkilig account is active and for such additional period as is necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

6.2 In accordance with Philippine AMLA requirements, transaction records are retained for a minimum of five (5) years from the date of the transaction. KYC documentation is retained for a minimum of five (5) years from account closure.

6.3 Upon expiry of the applicable retention period, phkilig will securely delete or anonymize your personal data in accordance with its data disposal procedures.

7. Data Security

7.1 phkilig implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include SSL/TLS encryption for data in transit, encrypted storage for sensitive data at rest, access controls and authentication requirements for phkilig systems, and regular security assessments.

7.2 In the event of a personal data breach that is likely to result in harm to you, phkilig will notify the NPC and affected data subjects in accordance with the DPA's breach notification requirements.

7.3 While phkilig takes all reasonable steps to protect your data, no internet transmission is completely secure. You are responsible for maintaining the security of your phkilig login credentials.

8. Cookies and Tracking Technologies

8.1 phkilig uses cookies and similar technologies (collectively, "Cookies") on the Platform. Cookies are small text files stored on your device that help us recognize you, maintain your session, and improve your experience.

phkilig uses the following types of Cookies:

• Essential Cookies: Required for the Platform to function, including session management and security. These cannot be disabled.
• Analytics Cookies: Used to understand how players use the phkilig Platform, enabling us to improve performance and features.
• Preference Cookies: Used to remember your settings and preferences on the Platform.

8.2 You may control non-essential Cookies through your browser settings. Disabling certain Cookies may affect the functionality of the phkilig Platform.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act, you have the following rights in respect of your personal data held by phkilig:

• Right to be Informed: The right to be informed of how your data is collected and processed;
• Right of Access: The right to obtain a copy of your personal data held by phkilig;
• Right to Rectification: The right to correct inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to legal retention obligations;
• Right to Object: The right to object to processing of your personal data, including for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact the phkilig Data Protection Officer via our support team. phkilig will respond to your request within thirty (30) days, as required by the DPA.

10. Children's Privacy

10.1 The phkilig Platform is strictly for persons aged 21 years and older. phkilig does not knowingly collect personal data from persons under 21 years of age. If phkilig becomes aware that it has collected personal data from an underage individual, it will promptly delete such data and close the associated account.

10.2 If you believe that phkilig has inadvertently collected data from a person under 21, please contact our support team immediately.

11. International Data Transfers

11.1 phkilig primarily processes personal data within the Philippines. Where data is transferred to service providers located outside the Philippines, phkilig ensures that appropriate safeguards are in place, consistent with the DPA's requirements for cross-border data transfers, including contractual clauses requiring the recipient to provide a level of data protection equivalent to that required under Philippine law.

12. Changes to This Privacy Policy

12.1 phkilig reserves the right to update this Privacy Policy at any time. The revised Policy will be posted on the Platform with an updated effective date. Where changes are material, phkilig will endeavor to notify registered players via email or in-platform notification.

12.2 Your continued use of the phkilig Platform following the posting of a revised Privacy Policy constitutes your acceptance of the changes.

13. Contact and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or phkilig's data processing practices, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.