phphark Privacy Policy

This Privacy Policy ("Policy") describes how phphark ("phphark," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of players and visitors ("you" or "Data Subject") who access or use the phphark online gaming platform, website, mobile applications, and all related services (collectively, the "Platform").

phphark is committed to protecting your privacy and handling your personal data responsibly, transparently, and in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable circulars and advisories issued by the National Privacy Commission (NPC) of the Philippines.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated herein by reference. Capitalized terms not defined in this Policy have the meanings given to them in our Terms & Conditions.

For the purposes of the Data Privacy Act of 2012 and this Policy, phphark acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes through the Platform.

As a Personal Information Controller, phphark determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with applicable Philippine data privacy laws.

phphark collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

phphark collects personal data through the following channels:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access the Platform. See Section 9 for details on our cookie practices.
• Third-party sources: Identity verification data from licensed KYC service providers; fraud prevention data from anti-money laundering screening services; payment confirmation data from GCash, PayMaya, and partner banks.
• Regulatory sources: Information received from PAGCOR or other Philippine government agencies in connection with our regulatory obligations, including self-exclusion registry checks.

phphark processes your personal data only for specific, legitimate purposes and on a recognized legal basis under the Data Privacy Act of 2012. The table below sets out our primary processing activities:

phphark does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data only in the following limited circumstances:

• Service Providers (Personal Information Processors): We engage trusted third-party service providers to perform functions on our behalf, including KYC and identity verification, payment processing, fraud detection, IT infrastructure, and customer support platforms. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data privacy laws.
• Payment Partners: When you make a deposit or withdrawal, relevant transaction data is shared with your chosen payment provider (e.g., GCash, PayMaya, BPI, BDO) solely to process the transaction.
• Regulatory Authorities: phphark is required by law to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies upon lawful request or as required by our operating license conditions.
• Legal Proceedings: We may disclose personal data where required by a valid court order, subpoena, or other legal process issued by a competent Philippine authority.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of phphark's assets, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

phphark retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and our regulatory obligations. The following general retention periods apply:

• Active account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of the last transaction, as required under the AMLA and PAGCOR regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for one (1) year after withdrawal of consent.
• Technical and usage logs: Retained for twelve (12) months for security monitoring and platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines on data disposal.

phphark implements a comprehensive set of technical, organizational, and physical security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including passwords and financial information, is encrypted using industry-standard algorithms.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All phphark staff with access to personal data undergo background checks and regular data privacy training.
• Two-Factor Authentication (2FA): phphark supports and encourages the use of 2FA for all player accounts to provide an additional layer of security against unauthorized access.
• Penetration Testing: The phphark Platform undergoes regular security audits and penetration testing by independent cybersecurity professionals.
• Incident Response: phphark maintains a documented personal data breach response plan in accordance with NPC Circular No. 16-03, including procedures for breach containment, assessment, notification, and remediation.

phphark uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and support our security and fraud prevention systems. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, game display options, and responsible gaming tool configurations.
• Analytics Cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phphark Platform. phphark does not use third-party advertising or behavioral tracking cookies.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phphark. You may exercise any of these rights by contacting our Data Protection Officer as described in Section 14.

If you are not satisfied with phphark's response to your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The phphark Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. phphark does not knowingly collect personal data from individuals under the age of 21.

If phphark discovers or is notified that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and take appropriate action in accordance with our legal obligations.

phphark primarily stores and processes personal data within the Republic of the Philippines. In limited circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international fraud screening services.

Where such cross-border transfers occur, phphark ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law
• Transfers only to jurisdictions that have been assessed as providing an adequate level of data protection
• Compliance with NPC requirements for cross-border data transfers as set out in NPC Advisory No. 2017-01

phphark reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players by email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how phphark protects your personal data. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phphark, please contact our Data Protection Officer or our general support team:

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