phgun Privacy Policy

Introduction

Welcome to phgun. We are a PAGCOR-regulated online casino and sportsbook serving Filipino players across the Philippines, including those in Manila, Cebu, Davao, Quezon City, Makati, and all other regions of the country. This Privacy Policy ("Policy") describes how phgun collects, uses, discloses, stores, and protects the personal information of individuals who visit, register on, or otherwise use the phgun Platform at phgun.net.

phgun is committed to handling your personal data responsibly, transparently, and in full compliance with the Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission ("NPC"). We believe that your right to informational privacy is a fundamental human right that we are bound to respect and uphold.

This Policy applies to all personal data processed by phgun in connection with the Platform, whether collected online, via mobile application, through customer support channels, or in any other context where phgun interacts with you as an individual. Please read this Policy carefully. If you do not agree with our data practices as described here, you should not register an account or use the phgun Platform.

This Policy should be read together with phgun's Terms and Conditions and Responsible Gaming Policy, both of which are available on this website.

Data Controller Identity

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules, phgun acts as the Personal Information Controller ("PIC") with respect to all personal data collected through the Platform. As PIC, phgun determines the purposes and means by which your personal data is processed.

phgun has appointed a designated Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy and applicable data protection law, managing data subject rights requests, coordinating with the National Privacy Commission, and maintaining phgun's internal data protection governance framework.

The phgun DPO can be contacted directly at [email protected] with the subject line "Data Privacy Request" or "Attention: DPO". All data rights requests and privacy-related inquiries will be handled by or under the supervision of the DPO.

Personal Data We Collect

phgun collects personal data from you in the following categories, depending on how you interact with the Platform:

phgun does not intentionally collect sensitive personal information as defined under RA 10173 (such as health data, biometric data beyond facial photographs for KYC purposes, political opinions, or religious beliefs) unless strictly required for regulatory compliance or fraud prevention. Where such data is collected, additional consent and safeguards will be applied.

How We Use Your Personal Data

phgun processes your personal data for the following specific purposes:

• Account Registration and Management: To create, maintain, and administer your phgun account, verify your identity, and provide access to Platform features;
• KYC and Regulatory Compliance: To fulfil PAGCOR-mandated Know Your Customer verification obligations and comply with Philippine Anti-Money Laundering Act (AMLA) requirements, including customer due diligence and enhanced due diligence procedures;
• Payment Processing: To process your deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other approved payment channels, and to maintain accurate financial records of all transactions in Philippine Peso (PHP);
• Platform Delivery: To provide access to phgun's games (slots, live casino, bingo, fishing games, sportsbook including PBA and international sports markets), process wagers, calculate and credit winnings, and manage bonus and promotional credits;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other conduct prohibited under phgun's Terms and Conditions;
• Customer Support: To respond to your support inquiries, resolve disputes, and maintain records of your support interactions for quality assurance purposes;
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling, administer self-exclusion and deposit limit tools, and fulfil phgun's responsible gaming obligations under PAGCOR guidelines;
• Legal Obligations: To comply with applicable Philippine law, respond to lawful regulatory inquiries, and cooperate with PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent authorities;
• Marketing Communications (with consent): To send you promotional offers, bonus notifications, game launch announcements, and other marketing communications about phgun, where you have provided express consent to receive such communications.

Legal Basis for Processing

phgun processes your personal data on the following legal bases as recognised under RA 10173 and its Implementing Rules:

• Contractual Necessity: Processing necessary to perform our contract with you under the phgun Terms and Conditions (e.g., account management, payment processing, game delivery);
• Legal Obligation: Processing required to comply with a legal obligation applicable to phgun as a PAGCOR-licensed operator under Philippine law (e.g., KYC, AML reporting, regulatory record-keeping);
• Legitimate Interests: Processing necessary for phgun's legitimate interests in fraud prevention, platform security, business analytics, and responsible gaming monitoring, where these interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent (e.g., marketing communications). You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Disclosure and Sharing of Personal Data

phgun does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We disclose your personal data only in the following circumstances:

• Regulatory and Government Authorities: phgun will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, and other competent Philippine government authorities where required or permitted by applicable law;
• Payment Processors: We share the financial data necessary to process your deposits and withdrawals with GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), and your nominated bank (BPI, BDO, Metrobank) strictly to execute your payment instructions. These entities process your data as separate Personal Information Controllers subject to their own privacy policies;
• Game Content Providers: phgun shares technical data (session identifiers, wager data) with certified third-party game providers to deliver their game content on the Platform. These providers operate under data processing agreements with phgun that restrict their use of your data to the purposes of game delivery only;
• Identity Verification and Fraud Prevention Services: phgun engages accredited third-party KYC and fraud prevention service providers to assist with identity verification, document authentication, and fraud detection. These providers process your data solely under phgun's instructions pursuant to binding data processing agreements;
• Professional Advisers: phgun may share personal data with its legal advisers, auditors, and compliance consultants where necessary in connection with legal proceedings, regulatory audits, or professional advice, subject to professional confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of phgun's business assets, your personal data may be disclosed to the relevant counterparty as part of that transaction, subject to equivalent data protection commitments.

In all cases, phgun limits disclosure to the minimum personal data necessary for the specific purpose and requires receiving parties to maintain appropriate confidentiality and security standards.

Cookies and Tracking Technologies

phgun uses cookies and similar tracking technologies (including local storage, session storage, and pixel tags) on the Platform for the following purposes:

• Essential Cookies: Strictly necessary for the Platform to function correctly, including maintaining your logged-in session, remembering your language preferences, and enabling secure payment workflows. These cookies cannot be disabled without impairing Platform functionality;
• Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the Platform (page views, session duration, navigation paths) to help phgun improve user experience and Platform performance;
• Security Cookies: Used to detect and prevent fraudulent activity, including session hijacking, cross-site request forgery, and multi-accounting attempts;
• Preference Cookies: Used to remember your Platform settings and preferences (e.g., preferred game categories, display settings) between sessions.

phgun does not use third-party advertising or behavioural targeting cookies. You may manage your cookie preferences through your browser settings. Please note that disabling essential cookies will affect your ability to use the Platform's core features. For detailed information about specific cookies used on the Platform, please contact phgun support.

Data Security

phgun implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security framework includes:

• TLS 1.2/1.3 encryption for all data transmitted between your device and phgun's servers;
• AES-256 encryption for sensitive personal data and financial data stored at rest;
• Role-based access controls ensuring that only authorised phgun personnel with a legitimate business need can access personal data;
• Multi-factor authentication requirements for all phgun administrative system access;
• Regular penetration testing and vulnerability assessments conducted by independent security firms;
• Intrusion detection and prevention systems monitoring the Platform in real time;
• A documented data breach response procedure aligned with NPC Circular No. 16-03 requirements, including notification to affected data subjects and the NPC within 72 hours of discovery of a breach likely to cause serious harm;
• Annual data protection training for all phgun employees who handle personal data.

While phgun maintains robust security measures, no digital platform can guarantee absolute security. You are responsible for maintaining the security of your phgun account credentials and for notifying phgun support immediately if you suspect your account has been compromised.

Data Retention

phgun retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the following mandatory retention obligations:

Following the expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be attributed to an identifiable individual. Where anonymisation is not technically feasible, data will be retained in encrypted form until secure deletion is possible.

International Data Transfers

phgun's primary data processing infrastructure is located within the Philippines. However, certain third-party service providers engaged by phgun (including some game content providers and technical infrastructure partners) may process data in data centres located outside the Philippines.

Where personal data is transferred outside the Philippines, phgun ensures that adequate safeguards are in place in accordance with NPC guidelines on cross-border data transfers, including: contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under RA 10173; verification that the receiving jurisdiction has been assessed as providing an adequate level of data protection; or other mechanisms recognised by the NPC as providing equivalent safeguards.

phgun will not transfer your personal data to jurisdictions where adequate data protection standards cannot be assured without your explicit consent, except where required by applicable Philippine law.

Children's Privacy and Age Restriction

phgun's registration process includes date of birth verification, and all accounts are subject to KYC verification confirming the account holder's age. Where phgun discovers or has reason to believe that personal data has been collected from an individual under 21 years of age, phgun will immediately suspend the relevant account, delete the collected data (subject only to any mandatory legal retention obligations), and notify the relevant authorities where required.

If you are a parent or guardian and believe that a minor under your care has registered a phgun account or provided personal data to phgun, please contact phgun support immediately via live chat or at [email protected].

Exercising Your Data Rights

To exercise any of your rights under RA 10173 as described in this Policy, please submit a written request to phgun's Data Protection Officer. Requests can be submitted in any of the following ways:

• Email: Send your request to [email protected] with the subject line "Data Privacy Request — [Your Right]" (e.g., "Data Privacy Request — Access");
• Live Chat: Initiate a live chat session on the phgun Platform and advise the support agent that you wish to submit a formal data rights request. The agent will guide you through the process;
• Written Correspondence: Addressed to the Data Protection Officer, phgun, via the contact details provided in Section 15 of this Policy.

For security purposes, all data rights requests require identity verification before processing. phgun will acknowledge receipt of your request within 5 business days and will provide a substantive response within 30 calendar days of verification. This period may be extended by a further 15 calendar days where the complexity or volume of requests warrants it, and phgun will notify you of any such extension and the reasons therefor.

If you are dissatisfied with phgun's response to your data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about the NPC's complaint process is available through official NPC channels.

Marketing Communications

phgun may send you promotional emails, SMS messages, and in-platform notifications about phgun bonuses, new game launches, special events, and other offers — but only where you have provided express consent to receive such communications during registration or subsequently through your account settings.

Withdrawing Consent. You may withdraw your consent to receive marketing communications from phgun at any time, free of charge, by: (a) updating your communication preferences in the Account Settings section of your phgun account; (b) clicking the "Unsubscribe" link included at the bottom of every phgun marketing email; or (c) contacting ph gun support via live chat or email and requesting removal from marketing communications.

Withdrawal of marketing consent will not affect phgun's ability to send you transactional and account-related communications (such as deposit confirmations, withdrawal notifications, security alerts, and important account notices), which are sent on the basis of contractual necessity rather than consent and cannot be opted out of while your account remains active.

Changes to This Privacy Policy

phgun reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, phgun's data processing practices, or the features and functionality of the Platform. The "Last Updated" date at the top of this Policy will be revised each time a material change is made.

Where a proposed change materially affects your rights or the way phgun processes your personal data, phgun will provide advance notice of not less than 14 calendar days prior to the change taking effect. Notice will be provided via email to the address registered on your phgun account and via a prominent notice on the Platform. Your continued use of the Platform following the effective date of any amended Policy constitutes your acceptance of the revised terms.

phgun encourages you to review this Policy periodically to stay informed about how your personal data is being handled. If you disagree with any changes to this Policy, you should discontinue use of the Platform and close your account by contacting phgun support.

Contact Us & Data Protection Officer

For all questions, concerns, or requests relating to this Privacy Policy or phgun's data protection practices, please contact the phgun Data Protection Officer using the details below:

phgun is regulated by the Philippine Amusement and Gaming Corporation (PAGCOR). Further details about phgun's regulatory status are available on the About Us page. If you wish to raise a data protection concern with the Philippine regulatory authority, you may contact the National Privacy Commission through official NPC channels.