phpart Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") is issued by phpart ("phpart," "we," "us," "our") and governs the collection, use, processing, storage, and disclosure of personal data of all registered players, prospective players, and visitors ("you," "your," "User") who interact with the phpart website at phpart.club, its subdomains, mobile web applications, and all related services (collectively, the "Platform").

phpart processes personal data in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission of the Philippines (NPC). This Policy also reflects applicable requirements under PAGCOR's regulatory framework for online gaming operators.

By registering an account on phpart, making a deposit, or otherwise using the Platform, you acknowledge that you have read this Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller

phpart is the personal information controller ("PIC") responsible for your personal data processed in connection with the Platform. For the purposes of the Data Privacy Act of 2012, phpart determines the purposes and means of processing personal data collected through the Platform.

phpart has designated a Data Protection Officer (DPO) who oversees compliance with this Policy and applicable data privacy laws. Contact details for the DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

phpart collects the following categories of personal data:

4. How We Collect Your Data

phpart collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing identity verification (KYC), making deposits or withdrawal requests, contacting support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, session tokens, server logs, and similar tracking technologies (see Section 9).
• Third-Party Sources: Identity and financial verification data received from payment processors (e.g., GCash, Maya, BPI, BDO), KYC verification service providers, and fraud detection services — to the extent permitted by applicable law.
• Regulatory Sources: Information required to be collected and cross-referenced under PAGCOR regulations and the Anti-Money Laundering Act (AMLA) of the Philippines.

5. How We Use Your Personal Data

phpart processes your personal data for the following purposes:

1. Account Management: Creating, maintaining, and securing your phpart account; processing login sessions; enabling two-factor authentication.
2. Payment Processing: Processing deposits and withdrawals via GCash, Maya, BPI, BDO, UnionBank, 7-Eleven CLiQQ, and other supported channels; verifying the source of funds.
3. Regulatory Compliance: Meeting obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (Republic Act No. 9160, as amended), and the Data Privacy Act of 2012. This includes filing suspicious transaction reports (STRs) where required.
4. Age Verification: Verifying that all registered players are at least 21 years of age, as required under Philippine law and PAGCOR regulations.
5. Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior; administering self-exclusion requests and deposit limit settings.
6. Customer Support: Responding to inquiries, resolving disputes, and providing technical assistance via live chat and email.
7. Fraud Prevention & Security: Detecting and preventing fraudulent activity, money laundering, bonus abuse, and unauthorized account access.
8. Platform Improvement: Analyzing aggregated, de-identified usage data to improve game selection, user interface, and overall Platform performance.
9. Marketing Communications: Sending promotional offers, bonus notifications, and relevant Platform updates to players who have not opted out of such communications. You may opt out at any time via your account settings or by contacting support.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, phpart processes your personal data on the following legal bases:

• Consent: Where you have provided explicit consent, including consent to marketing communications and to this Privacy Policy at account registration.
• Contractual Necessity: Processing necessary to perform our contract with you (i.e., providing the gaming and payment services you have subscribed to through account registration).
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA obligations, and Data Privacy Act requirements.
• Legitimate Interests: Processing necessary for phpart's legitimate interests in fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights and interests.

7. Sharing Your Personal Data

phpart does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phpart may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, Maya, BPI, BDO, UnionBank, and other payment service providers, for the purpose of processing your financial transactions.
• KYC / AML Service Providers: Third-party identity verification and fraud detection providers engaged by phpart to fulfil its regulatory compliance obligations.
• Game Providers: Licensed game software providers whose games are available on the Platform, to the extent necessary to operate the games and resolve disputes.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities, where required by law or upon lawful request.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers operating under data processing agreements with phpart that require them to protect your data to at least the same standard as phpart.
• Legal & Professional Advisors: Lawyers, auditors, and compliance consultants, under professional confidentiality obligations.

8. Data Retention

phpart retains your personal data for as long as necessary to fulfil the purposes for which it was collected, as required by applicable law, or as necessary to resolve disputes and enforce our agreements. 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 and AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years in accordance with AMLA obligations.
• Gaming Activity Logs: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes.
• Support Communications: Retained for a minimum of two (2) years.
• Technical and Log Data: Retained for a maximum of twelve (12) months in aggregate form.

Upon the expiry of applicable retention periods, phpart will securely delete or anonymize your personal data.

9. Cookies & Tracking Technologies

phpart uses cookies and similar tracking technologies (including session tokens and local storage) to operate and improve the Platform. Cookies are small text files placed on your device when you access the Platform.

9.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and session timeout preferences.
• Analytics Cookies: Collect aggregated, de-identified data on how players use the Platform to enable phpart to improve performance and user experience.
• Marketing Cookies: Used to deliver relevant promotional content based on your interests and Platform activity. You may opt out of marketing cookies via your account settings.

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

10. Data Security

phpart implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and phpart's servers;
• Encryption of sensitive data at rest, including financial and identity data;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Multi-factor authentication for administrative system access;
• Regular security audits and penetration testing by independent cybersecurity professionals;
• Real-time fraud detection and anomaly monitoring systems;
• Incident response procedures for managing data security breaches in accordance with NPC notification requirements.

11. Your Data Privacy Rights

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

• Right to be Informed: The right to be informed of how phpart collects and processes your personal data (addressed by this Policy).
• Right of Access: The right to request a copy of the personal data phpart holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where phpart no longer has a legal basis for processing it, subject to retention obligations under PAGCOR and AMLA regulations.
• 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 a copy of your personal data in a commonly used, machine-readable format.
• Right to File a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe phpart has violated your data privacy rights.

To exercise any of these rights, contact phpart's Data Protection Officer using the details provided in Section 15. phpart will respond to all valid requests within thirty (30) days.

12. Children's Privacy

The phpart Platform is strictly intended for adults aged twenty-one (21) years and above. phpart does not knowingly collect personal data from individuals under 21 years of age. If phpart becomes aware that personal data has been collected from a person under 21, phpart will take immediate steps to delete such data and close the associated account in accordance with its age verification and responsible gaming policies.

If you believe a person under 21 has created a phpart account, please contact support immediately at [email protected].

13. International Data Transfers

phpart's primary data processing operations are based in the Philippines. Where phpart engages third-party service providers located outside the Philippines (for example, cloud infrastructure providers), phpart ensures that appropriate safeguards are in place to protect your personal data in accordance with the requirements of the Data Privacy Act of 2012 and NPC guidance on cross-border data transfers. Such safeguards may include standard contractual clauses, adequacy decisions, or other mechanisms approved by the NPC.

14. Amendments to This Policy

phpart reserves the right to update or amend this Privacy Policy at any time. Where changes are material, phpart will notify you by email or by a prominent notice on the Platform prior to the changes taking effect. The "Last updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the Platform following notification of any amendment constitutes your acceptance of the revised Policy.

phpart encourages you to review this Policy periodically to stay informed of how your personal data is being protected.

15. Contact & Data Protection Officer

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data by phpart, please contact:

• Live Chat: Available 24/7 via the in-Platform chat widget (average response: 3–5 minutes)
• Email: [email protected] (subject line: "Data Privacy Request")

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. Information on how to contact the NPC is available through official Philippine government channels.

phpart · phpart.club · Philippines Online Gaming Platform · Compliance with RA 10173 (Data Privacy Act of 2012) · PAGCOR Regulated