Privacy Policy

1. Introduction

phcom ("phcom," "we," "us," "our") is committed to protecting the privacy and personal data of all users of the phcom Platform at phcom.net. This Privacy Policy describes how phcom collects, processes, stores, shares, and protects personal information in connection with your use of our online gaming services, including live casino, slots, bingo, sabong, and sports betting.

This policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. phcom is registered with and subject to the oversight of the National Privacy Commission of the Philippines ("NPC").

By registering for a phcom Account, making a deposit, or otherwise using the phcom Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller

phcom is the data controller responsible for your personal data collected through the phcom Platform. As data controller, phcom determines the purposes and means of processing your personal data.

phcom has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. Contact details for the DPO are provided in Section 16 of this policy.

Where phcom engages third-party service providers to process personal data on its behalf, those providers act as data processors and are bound by data processing agreements that require them to handle your data in accordance with this policy and applicable law.

3. Personal Data We Collect

phcom collects the following categories of personal data from users of the Platform:

3.1 Identity Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — 21+ requirement);
• Gender (optional, for personalization purposes);
• Government-issued ID number and copies of identification documents submitted during KYC verification.

3.2 Contact Data

• Philippine mobile number;
• Email address;
• Residential address (barangay, city/municipality, province, ZIP code).

3.3 Financial Data

• GCash or PayMaya account number linked to your phcom Wallet;
• Bank account details (BPI, BDO, Metrobank, or other supported banks) for withdrawal processing;
• Transaction history, including deposits, withdrawals, and bet records.

3.4 Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session logs, login timestamps, and access records;
• Cookies and similar tracking technologies (see Section 10).

3.5 Gaming Data

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

3.6 Communications Data

• Records of your communications with phcom customer support via live chat, email, or Viber;
• Survey responses and feedback submitted to phcom.

4. How We Collect Your Data

phcom collects personal data through the following means:

• Direct collection: Information you provide when registering your phcom Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the phcom Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity and fraud verification data from third-party KYC and anti-money laundering (AML) service providers; payment data from GCash, PayMaya, and banking partners; and publicly available information used for fraud prevention purposes.

5. How We Use Your Personal Data

phcom processes your personal data for the following purposes:

• Account management: To register, maintain, and administer your phcom Account, including processing deposits, withdrawals, and bet settlements;
• Identity and age verification: To verify that you are at least 21 years of age and to confirm your identity in compliance with PAGCOR regulations and AML requirements;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform;
• Regulatory compliance: To comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012;
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Marketing and promotions: To send you promotional offers, bonuses, and platform updates where you have consented to receive such communications. You may opt out at any time;
• Platform improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the phcom Platform;
• Legal proceedings: To establish, exercise, or defend legal claims involving phcom.

6. Legal Basis for Processing

phcom processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and phcom (i.e., to operate your Account and provide gaming services);
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA, and tax reporting obligations;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection 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.

7. Data Sharing and Disclosure

phcom does not sell your personal data to third parties. We may share your personal data with the following categories of recipients:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals;
• KYC and AML providers: Third-party identity verification and anti-money laundering service providers engaged to assist with regulatory compliance;
• Game content providers: Licensed game studios and content providers whose games are available on the phcom Platform, to the extent necessary for game operation and dispute resolution;
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers engaged to support the technical operation of the Platform;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies, where disclosure is required by law or regulatory obligation;
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process;
• Professional advisers: Legal counsel, auditors, and accountants engaged by phcom in connection with its business operations.

All third-party service providers engaged by phcom are required to process personal data only in accordance with phcom's instructions and applicable data protection law.

8. Data Retention

8.1 phcom retains your personal data for as long as your phcom Account is active and for a period of five (5) years following Account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.

8.2 Transaction records and bet history are retained for a minimum of five (5) years from the date of the transaction, as required by applicable Philippine law.

8.3 Communications with customer support are retained for three (3) years from the date of the communication.

8.4 Where personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, phcom will securely delete or anonymize the data.

9. Data Security

9.1 phcom 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 all data transmitted between your device and the phcom Platform;
• Encryption of sensitive data at rest, including financial information and government ID data;
• Access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of the phcom Platform;
• Two-factor authentication (2FA) available for all player accounts;
• Secure data centers with physical access controls.

9.2 While phcom takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. phcom cannot guarantee absolute security but is committed to maintaining industry-standard protections at all times.

9.3 Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phcom will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

10. Cookies and Tracking Technologies

10.1 phcom uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. The following types of cookies are used:

• Essential cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Analytics cookies: Used to collect anonymized data about how players use the phcom Platform, helping us improve performance and user experience.
• Preference cookies: Used to remember your settings and preferences, such as language and display options.
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of phcom's marketing campaigns. These are only set with your consent.

10.2 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phcom Platform.

10.3 phcom does not use cookies to collect sensitive personal data such as financial information or government ID details.

11. Your Data Rights

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

• Right to be informed: You have the right to be informed about how phcom collects and processes your personal data, as set out in this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data phcom holds about you;
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data;
• Right to erasure: You have 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 phcom's legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used format and to transmit it to another data controller, where technically feasible;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phcom has violated your data privacy rights.

To exercise any of these rights, please contact phcom's Data Protection Officer using the contact details in Section 16. phcom will respond to all data rights requests within thirty (30) days of receipt.

12. Children's Privacy

12.1 The phcom Platform is strictly intended for adults aged 21 years and above. phcom does not knowingly collect personal data from individuals under the age of 21.

12.2 If phcom becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated Account will be closed. If you believe a minor has registered on phcom, please contact our support team immediately.

12.3 Parents and guardians are encouraged to use parental control tools to prevent minors from accessing online gaming platforms, including phcom.

13. International Data Transfers

13.1 phcom primarily stores and processes personal data within the Philippines. Where personal data is transferred to service providers located outside the Philippines, phcom ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to provide a level of data protection equivalent to that required under Philippine law.

13.2 By using the phcom Platform, you consent to the transfer of your personal data to countries outside the Philippines where phcom's service providers are located, subject to the safeguards described in this section.

14. Third-Party Links

14.1 The phcom Platform may contain links to third-party websites or services. phcom is not responsible for the privacy practices of those third parties and encourages you to review their privacy policies before providing any personal data.

14.2 The inclusion of a link to a third-party website does not constitute an endorsement by phcom of that website or its content.

15. Updates to This Privacy Policy

15.1 phcom reserves the right to update this Privacy Policy at any time. When material changes are made, phcom will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

15.2 The date of the most recent revision is displayed at the top of this page. Your continued use of the phcom Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated policy.

15.3 If you do not agree to the revised Privacy Policy, you must discontinue use of the Platform and may request closure of your Account.

16. Contact Us & Data Protection Officer

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

• Data Protection Officer: phcom DPO
• Email: [email protected]
• Live Chat: Available 24/7 via the phcom Platform
• Response Time: phcom aims to respond to all privacy-related enquiries within 30 days of receipt.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.