Privacy Policy

1. Introduction

phtt Casino ("phtt," "we," "us," or "our") operates the online gaming platform accessible at phtt.club. We are committed to protecting the privacy and personal data of all users ("you," "Player," or "Data Subject") in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy describes how phtt Casino collects, uses, stores, shares, and protects your personal data when you visit our website, register an account, or use any of our gaming services. It also explains the rights you have as a data subject and how you can exercise them.

By registering an account with phtt Casino or continuing to use our 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. If you do not agree with this Privacy Policy, please discontinue use of the phtt Casino platform immediately.

This Privacy Policy should be read alongside our Terms & Conditions, which govern your use of the phtt Casino platform.

2. Personal Data We Collect

phtt Casino collects the following categories of personal data from registered players and platform visitors:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you are 21 years of age or older)
• Residential address in the Philippines (barangay, city/municipality, province)
• Valid email address
• Active Philippine mobile number
• Nationality and citizenship

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or facial photograph for liveness verification where required
• Source of funds documentation for high-value accounts

2.3 Financial Data

• GCash or PayMaya (Maya) account details used for deposits and withdrawals
• Bank account details (bank name, account number) for bank transfer transactions
• Debit card details (card number, expiry date) where applicable
• Transaction history including deposit amounts, withdrawal amounts, and dates

2.4 Gaming & Account Activity Data

• Game history, wager amounts, wins, and losses
• Account login history including timestamps and IP addresses
• Responsible gaming settings and self-exclusion status
• Bonus and promotion usage history
• Customer support communications and complaint records

2.5 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, time spent on pages, and navigation patterns
• Cookie identifiers and session data (see Section 9)

3. How We Collect Your Data

phtt Casino collects personal data through the following means:

• 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 when you access the phtt Casino platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment verification data from payment processors such as GCash and Maya.
• Regulatory sources: Information received from PAGCOR, the AMLC, or other Philippine regulatory authorities in connection with our legal compliance obligations.

4. How We Use Your Personal Data

phtt Casino uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phtt Casino account, including processing your registration and verifying your identity.
• Age verification: To confirm that you are at least 21 years of age, as required by Philippine gaming regulations.
• Service delivery: To provide you with access to our gaming platform, process your deposits and withdrawals, and deliver the services you have requested.
• Legal compliance: To comply with our obligations under Philippine law, including the Data Privacy Act, the Anti-Money Laundering Act, PAGCOR licensing requirements, and other applicable regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the phtt Casino platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools including deposit limits, loss limits, and self-exclusion.
• Customer support: To respond to your inquiries, complaints, and support requests.
• Marketing communications: To send you promotional offers, bonuses, and news about phtt Casino, 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 phtt Casino platform.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including KYC/AML obligations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests are not overridden by your rights and interests.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

phtt Casino does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the phtt Casino platform, including KYC/identity verification providers, payment processors (GCash, Maya, and banking partners), cloud hosting providers, customer support platforms, and fraud detection services. All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

6.2 Regulatory Authorities

We are required by Philippine law to share certain personal data with regulatory authorities including PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and the National Privacy Commission (NPC), where required by applicable law or regulatory direction.

6.3 Law Enforcement

We may disclose personal data to Philippine law enforcement agencies where required by a valid court order, subpoena, or other legal process, or where we reasonably believe disclosure is necessary to prevent imminent harm or illegal activity.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of phtt Casino's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

7. Data Retention

phtt Casino retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically, we retain:

• Account and KYC data: For the duration of your account and for a minimum of five (5) years after account closure, as required by Philippine AML regulations.
• Transaction records: For a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Gaming activity data: For a minimum of three (3) years from the date of the activity.
• Customer support records: For a minimum of two (2) years from the date of the last interaction.
• Marketing consent records: For the duration of your consent and for one (1) year after withdrawal of consent.

When personal data is no longer required for any lawful purpose, phtt Casino will securely delete or anonymize it in accordance with our data retention and disposal procedures.

8. Data Security

phtt Casino implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• AES-256 encryption for data at rest and TLS 1.3 encryption for data in transit
• Multi-factor authentication for all administrative access to systems containing personal data
• Regular penetration testing and vulnerability assessments by independent security firms
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• 24/7 security monitoring and intrusion detection systems
• Regular staff training on data protection and information security
• Secure data centers with physical access controls

While phtt Casino takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phtt Casino will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by the Data Privacy Act.

9. Cookies & Tracking Technologies

phtt Casino uses cookies and similar tracking technologies to enhance your experience on the phtt.club platform. This section explains what cookies we use and how you can manage them.

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They allow the website to recognize your device, remember your preferences, and collect information about how you use the site. phtt Casino uses both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a set period).

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the phtt Casino platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming settings to provide a more personalized experience.
• Analytics Cookies: Collect anonymized information about how players use the phtt Casino platform, including pages visited and time spent, to help us improve our services.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and activity on the platform. These are only placed with your consent.

9.3 Managing Cookies

You can manage your cookie preferences through the cookie consent banner displayed when you first visit phtt.club, or through your browser settings. Please note that disabling certain cookies may affect the functionality of the phtt Casino platform. Strictly necessary cookies cannot be disabled as they are essential for the platform to operate securely.

10. Your Data Subject Rights

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

• Right to be Informed: The right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phtt Casino holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: 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 our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

11. Children's Privacy

phtt Casino does not knowingly collect personal data from individuals under the age of 21. Our platform is strictly intended for adults aged 21 and above, as required by Philippine gaming regulations.

If you are a parent or guardian and believe that a minor has provided personal data to phtt Casino without your consent, please contact us immediately at [email protected]. We will take prompt steps to verify the situation and, where confirmed, delete the minor's personal data from our systems and close any associated account.

phtt Casino employs mandatory age verification procedures during the registration process to prevent underage access to our platform. Any account found to belong to a person under 21 years of age will be immediately suspended and all associated data will be handled in accordance with applicable law.

12. Updates to This Privacy Policy

phtt Casino 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. The most current version of this Privacy Policy will always be published on this page, with the date of last revision clearly indicated at the top.

Where changes to this Privacy Policy are material — meaning they significantly affect your rights or how we process your personal data — phtt Casino will notify you by email to your registered address or by a prominent notice on the phtt Casino platform prior to the changes taking effect.

Your continued use of the phtt Casino platform following the publication of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated Privacy Policy, you must discontinue use of the platform and may request account closure by contacting our support team.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way phtt Casino handles your personal data, please contact our Data Protection Officer (DPO):

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the phtt Casino platform
• Response Time: We aim to respond to all privacy-related inquiries within 15 business days

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through their official government channels.