phgame3 Privacy Policy

1. Introduction and Scope

phgame3 ("the Company," "we," "us," or "our") operates the online gaming platform accessible at phgame3.org (the "Platform"). As a PAGCOR-regulated entity operating within the Republic of the Philippines, phgame3 is subject to the Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the policies and issuances of the National Privacy Commission ("NPC").

This Privacy Policy ("Policy") applies to all personal data processed by phgame3 in connection with your use of the Platform — including registration, account management, gameplay, payment processing, customer support interactions, and marketing communications. It applies to all players, registered users, and visitors to phgame3.org.

By registering an account on phgame3 or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein, to the extent that consent is the applicable legal basis for such processing.

2. Personal Data We Collect

phgame3 collects personal data in the categories described below. We collect only information that is necessary, adequate, and not excessive in relation to the purposes for which it is processed.

Sensitive Personal Information: Biometric data (selfie photographs used for KYC verification) constitutes sensitive personal information under the DPA. phgame3 processes this data solely for the purpose of identity verification as required by PAGCOR regulations and AMLA obligations, and applies heightened security measures to its storage and processing.

3. How phgame3 Uses Your Personal Data

phgame3 processes your personal data for the following purposes:

• Account creation and management — to register your phgame3 account, verify your identity, and maintain your account profile;
• KYC and regulatory compliance — to fulfill obligations under PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), and related AMLC issuances, including verifying your identity and monitoring transactions for suspicious activity;
• Payment processing — to process deposits via GCash, Maya, BPI, BDO, and other accepted payment methods, and to process withdrawal requests to your verified payment account;
• Platform operation and gameplay — to deliver gaming services, record bet outcomes, manage bonus credits, and maintain accurate account balances;
• Security and fraud prevention — to detect and prevent account takeovers, fraudulent transactions, money laundering, and unauthorised access to the Platform;
• Customer support — to investigate and resolve complaints, answer enquiries, and communicate account-related information;
• Marketing communications — where you have provided consent, to send you promotions, bonus offers, and product updates via email or SMS. You may withdraw this consent at any time;
• Responsible gaming — to monitor gaming patterns, enforce deposit limits and self-exclusion requests, and fulfil PAGCOR responsible gaming obligations;
• Platform improvement — to analyse aggregated, anonymised usage data to improve platform performance, game selection, and user experience.

phgame3 does not use your personal data for automated decision-making that produces significant legal effects without human review, except where required for fraud detection, in which case you may request a human review of any automated decision affecting your account.

4. Legal Basis for Processing

phgame3 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contract performance — processing necessary to provide the services you have requested under the phgame3 Terms & Conditions, including account operation, payment processing, and gameplay;
• Legal obligation — processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, NPC issuances, and other applicable Philippine laws;
• Legitimate interests — processing necessary for fraud prevention, security monitoring, and platform integrity, where these interests are not overridden by your privacy 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.

5. Data Sharing and Disclosure

phgame3 does not sell, rent, or trade your personal data to third parties for their independent marketing purposes. We share personal data only in the following circumstances:

• Payment processors — GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), BPI, BDO, and other payment service providers as necessary to process your transactions. These providers are contractually bound to process data only for payment purposes;
• Identity verification providers — third-party KYC service providers who assist with government ID verification and biometric matching, operating under data processing agreements with phgame3;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or regulatory direction;
• Law enforcement — where phgame3 is required by court order, subpoena, or other lawful process to disclose information to law enforcement or judicial authorities;
• Game software providers — limited technical and gameplay data shared with licensed game providers to deliver gaming services, under contractual data protection obligations;
• Business transfers — in the event of a merger, acquisition, or sale of substantially all assets of phgame3, your personal data may be transferred as part of that transaction, subject to this Policy continuing to apply or a successor privacy policy of equivalent protection.

All third-party processors engaged by phgame3 are subject to written data processing agreements requiring them to maintain appropriate technical and organisational security measures and to process data only on phgame3's documented instructions.

6. Cookies and Tracking Technologies

phgame3 uses cookies and similar tracking technologies to operate the Platform effectively, ensure security, and improve user experience. The types of cookies used include:

• Essential cookies — strictly necessary for Platform operation, including session management, phgame3 login authentication, and security token validation. These cannot be disabled without impairing Platform functionality;
• Functional cookies — remember your preferences (e.g., language settings, game lobby display options) to personalise your experience;
• Analytics cookies — collect anonymised, aggregated data about how users navigate the Platform, which game categories are most visited, and session duration. This data is used solely to improve Platform performance;
• Security cookies — detect and prevent fraudulent activity, credential stuffing attacks, and unusual login behaviour on the phgame3 Platform.

phgame3 does not use third-party advertising cookies or cross-site tracking technologies that serve advertisements on behalf of external advertisers.

You may manage non-essential cookies through your browser settings. Disabling essential cookies will impair your ability to use the phgame3 Platform, including the login functionality.

7. Data Retention

phgame3 retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal obligations. The following retention schedule applies:

• Account and identity data — retained for the duration of your active phgame3 account, plus a minimum of 5 years following account closure, in compliance with AMLA record-keeping requirements;
• KYC documents (government IDs, selfies) — retained for a minimum of 5 years following submission, in accordance with PAGCOR and AMLC guidelines;
• Financial transaction records — retained for a minimum of 5 years, in compliance with AMLA obligations and PAGCOR reporting requirements;
• Gaming activity data — retained for a minimum of 3 years following account closure for dispute resolution and responsible gaming purposes;
• Customer support records — retained for 2 years following the resolution of each support interaction;
• Marketing consent records — retained for the duration of the marketing relationship plus 1 year following opt-out;
• Technical and device data (logs) — retained for 12 months from collection for security and fraud investigation purposes.

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

8. Data Security

phgame3 implements technical and organisational security measures designed to protect your personal data against accidental loss, unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmissions between your device and phgame3 servers;
• Encryption at rest for sensitive personal data, including biometric data and financial account references;
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need;
• Two-factor authentication requirements for administrative access to systems storing personal data;
• Continuous automated monitoring for anomalous access patterns, brute-force attempts, and data exfiltration indicators;
• Regular security assessments and penetration testing of Platform infrastructure;
• Data processing agreements with all third-party processors imposing equivalent security obligations.

In the event of a personal data breach that is likely to pose a real risk to your rights and freedoms, phgame3 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay in accordance with the DPA and NPC Circular No. 16-03.

9. Your Rights as a Data Subject

Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by phgame3:

• Right to be Informed — to know what personal data phgame3 holds about you and how it is being processed;
• Right of Access — to request a copy of the personal data phgame3 holds about you;
• Right to Rectification — to request correction of inaccurate or incomplete personal data without undue delay;
• Right to Erasure or Blocking — to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, or where your consent has been withdrawn, subject to phgame3's legal retention obligations;
• Right to Object — to object to the processing of your personal data, including for direct marketing purposes;
• Right to Data Portability — to receive a structured, commonly used electronic copy of the personal data you have provided to phgame3;
• Right to Damages — to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data;
• Right to File a Complaint — to file a complaint with the National Privacy Commission (NPC) if you believe your rights under the DPA have been violated.

To exercise any of the above rights, please contact phgame3's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." phgame3 will respond within 15 business days of receiving a verified request. We may need to verify your identity before processing your request.

10. Children and Minors

The phgame3 Platform is strictly restricted to individuals who are 21 years of age or older. phgame3 does not knowingly collect or process personal data from individuals under the age of 21. Age verification is enforced through the mandatory KYC process, which requires submission of a valid government-issued Philippine identification document.

If phgame3 becomes aware that it has collected personal data from a person under 21 years of age, that account will be immediately closed, all data associated with the account will be securely deleted except where retention is required by law, and any deposits will be returned to the source payment method following investigation.

Parents and guardians are responsible for ensuring that individuals under their care do not access the phgame3 Platform using the guardian's account credentials or payment methods.

11. Third-Party Services and Links

The phgame3 Platform may contain links to or integrations with third-party services, including payment gateways such as GCash and Maya. This Privacy Policy applies only to personal data processed by phgame3 in connection with the Platform. phgame3 is not responsible for the privacy practices of third-party services, and we encourage you to review the privacy policies of any third-party services you access in connection with using phgame3.

Game software providers whose titles are accessible on the phgame3 Platform may receive limited technical data (such as session identifiers and gameplay results) as necessary to deliver their services. These providers operate under data processing agreements with phgame3 and are not permitted to use this data for their own independent marketing or profiling purposes.

12. Amendments to This Policy

phgame3 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Material changes will be communicated to registered phgame3 players via email and/or a prominent notice on the Platform at least 14 days before taking effect, except where changes are required by law or regulatory directive, in which case they may take effect immediately.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the phgame3 Platform after any amendment takes effect constitutes your acknowledgement of the revised Policy. If you do not accept the amended Policy, you must cease using the Platform and contact our Data Protection Officer to close your account and request deletion of your personal data subject to applicable retention requirements.

13. Contact and Data Protection Officer

phgame3 has appointed a Data Protection Officer ("DPO") in compliance with Section 21 of the Data Privacy Act and its IRR. If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to report a privacy concern, please contact:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. Information on filing a complaint with the NPC is available on the NPC's official website at privacy.gov.ph.