phdre Privacy Policy

phdre is committed to protecting the privacy and personal information of all users of the platform. This Privacy Policy applies to all personal data collected by phdre through:

• The phdre website and mobile-optimised platform accessible at phdre.cam;
• Account registration, KYC verification, and ongoing account management processes;
• Deposit, withdrawal, and payment processing transactions;
• Gameplay, betting, and other gaming activities on the platform;
• Customer support interactions via live chat, email, or other communication channels;
• Marketing communications, promotional offers, and newsletters where you have consented to receive them.

This Policy should be read in conjunction with the phdre Terms & Conditions. Defined terms used in this Policy have the same meaning as in the Terms & Conditions unless otherwise stated. phdre is the data controller for all personal information collected through the platform.

phdre collects the following categories of personal information in connection with the operation of the platform:

• Identity Information: Full legal name, date of birth, nationality, gender.
• Contact Information: Philippine mobile number, email address (if provided), residential address.
• Account Credentials: Username (if applicable), password (stored in hashed form only), security questions and answers.

• Copies of government-issued identification documents including Philippine Identification System (PhilSys) card, passport, driver's licence issued by the Land Transportation Office, or other acceptable ID as specified by PAGCOR regulations;
• Proof of address documents such as utility bills, bank statements, or government correspondence;
• Source of funds documentation where required under anti-money laundering (AML) procedures;
• Facial verification photographs or selfies submitted as part of identity verification processes.

• GCash, PayMaya, BPI, BDO, Metrobank account details or card numbers (stored in tokenised form through secure payment processors);
• Deposit and withdrawal transaction records including amounts, dates, times, payment methods, and transaction reference numbers;
• Wallet balance and transaction history on the phdre platform;
• Betting and gaming activity including stakes, wins, losses, game selections, and bet timestamps.

• IP address, device type, operating system, browser type, and screen resolution;
• Login timestamps, session duration, and geolocation data (to the extent permitted by your device settings and required for regulatory compliance);
• Pages visited, games played, features accessed, and click-stream data;
• Cookies and similar tracking technologies (see Section 6 for details).

• Transcripts of live chat conversations with phdre support agents;
• Email correspondence, complaint submissions, and feedback provided to phdre;
• Records of marketing preferences and consent for promotional communications.

phdre processes your personal information for the following purposes, all of which are necessary for the operation of the platform and compliance with applicable legal obligations:

• Account Management: To create, maintain, and administer your phdre account, verify your identity, and authenticate your access to the platform.
• KYC & Regulatory Compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations under the Anti-Money Laundering Act (Republic Act No. 9160 as amended), and counter-terrorist financing regulations.
• Payment Processing: To process deposits, withdrawals, and other financial transactions; to verify payment method ownership; and to prevent payment fraud.
• Game Provision & Platform Operation: To enable your participation in casino games, sports betting, bingo, and other gaming activities; to calculate and credit winnings; to apply bonus terms; and to maintain game integrity.
• Customer Support: To respond to your enquiries, resolve technical issues, investigate complaints, and improve the quality of support services.
• Responsible Gaming: To administer deposit limits, loss limits, self-exclusion requests, and other responsible gaming tools; to identify patterns of problem gambling where appropriate.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, collusion, multi-accounting, bonus abuse, and other violations of the phdre Terms & Conditions.
• Marketing & Promotions: Where you have provided consent, to send promotional offers, bonus notifications, newsletters, and other marketing communications via SMS or email. You may withdraw consent at any time through your account settings.
• Legal Obligations: To comply with court orders, regulatory requests from PAGCOR or the National Privacy Commission, law enforcement enquiries, and other legal obligations under Philippine law.
• Platform Improvement: To analyse usage patterns, improve platform performance, develop new features, and enhance the overall player experience through anonymised and aggregated data analysis.

Under the Philippine Data Privacy Act of 2012, phdre relies on the following legal bases for processing your personal information:

• Consent: You have provided explicit consent to the processing of your personal data for specific purposes, such as receiving marketing communications or participating in optional promotional offers.
• Contract Performance: Processing is necessary to perform our obligations under the Terms & Conditions that govern your use of the phdre platform, including account management, payment processing, and game provision.
• Legal Obligation: Processing is required to comply with Philippine laws and regulations including PAGCOR licensing requirements, AML/CTF obligations, tax reporting, and data retention mandates.
• Legitimate Interests: Processing is necessary for phdre's legitimate business interests including fraud prevention, platform security, customer support, and service improvement, provided that such interests do not override your fundamental privacy rights.

Where processing is based on consent, you have the right to withdraw that consent at any time by contacting phdre support or adjusting your account settings. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

phdre does not sell, rent, or trade your personal information to third parties for their marketing purposes. Your personal data may be shared with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, and Philippine banks (BPI, BDO, Metrobank) process your financial transactions on behalf of phdre. These processors receive only the information necessary to complete the transaction and are bound by strict data protection obligations.
• Game Providers: Licensed game studios such as Pragmatic Play, Play'n GO, Hacksaw Gaming, Evolution Gaming, and others receive anonymised or pseudonymised gameplay data necessary to operate their games on the phdre platform. They do not receive your identity or contact information.
• KYC Verification Services: Third-party identity verification providers may be used to authenticate government-issued identification documents. These providers operate under strict confidentiality agreements and data protection standards equivalent to or exceeding Philippine law.
• PAGCOR & Regulatory Authorities: Personal data may be disclosed to the Philippine Amusement and Gaming Corporation (PAGCOR), the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), or other Philippine government agencies where required by law or regulatory obligation.
• Legal & Professional Advisors: phdre's legal counsel, auditors, and compliance consultants may access personal data to the extent necessary to provide professional services, all under strict confidentiality obligations.
• Law Enforcement: Personal data may be disclosed to Philippine law enforcement agencies pursuant to a valid court order, subpoena, or lawful request in connection with criminal investigations or legal proceedings.

All third-party service providers processing personal data on behalf of phdre are contractually obligated to maintain the confidentiality and security of that data and to process it only in accordance with phdre's instructions and applicable Philippine data protection laws.

phdre uses cookies and similar tracking technologies to enhance platform functionality, analyse usage patterns, and improve the player experience. A cookie is a small text file stored on your device that allows the platform to recognise your browser and remember certain information.

• Essential Cookies: Required for basic platform functionality including login authentication, session management, and security features. These cookies cannot be disabled without impairing platform operation.
• Performance Cookies: Collect anonymised data on how players use the platform, which pages are visited most frequently, and where errors occur. This information helps phdre optimise platform performance.
• Functional Cookies: Remember your preferences such as language settings, display options, and game filters to provide a more personalised experience.
• Analytical Cookies: Used to understand player behaviour, measure the effectiveness of marketing campaigns, and improve platform features through aggregated data analysis.

You may configure your browser to reject cookies or to notify you when a cookie is being set. However, disabling cookies may impair your ability to access certain platform features or may require you to re-enter your login credentials more frequently. Most browsers provide instructions on managing cookie settings in their help documentation.

phdre implements industry-standard technical and organisational security measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption: All personal data transmitted between your device and phdre's servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data stored in phdre's databases is encrypted at rest.
• Access Controls: Personal data is accessible only to authorised phdre personnel on a need-to-know basis. All access is logged and subject to regular audit.
• Password Security: Player passwords are stored using one-way cryptographic hashing algorithms and are never stored in plain text or reversible encrypted form.
• Firewall Protection: phdre's servers are protected by enterprise-grade firewalls and intrusion detection systems that monitor for suspicious activity 24/7.
• Regular Security Audits: phdre's information security practices are reviewed regularly by internal compliance teams and external security auditors to ensure ongoing compliance with PAGCOR and NPC standards.
• Incident Response: phdre maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in a risk to your rights, phdre will notify the National Privacy Commission and affected individuals in accordance with Philippine law.

While phdre takes all reasonable precautions to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying phdre immediately if you suspect unauthorised access to your account.

phdre retains your personal information only for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal and regulatory obligations. The retention periods vary depending on the category of personal data:

• Account & Identity Information: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, as required by PAGCOR regulations and AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with Philippine AML laws and Bureau of Internal Revenue (BIR) record-keeping requirements.
• KYC Documentation: Retained for five (5) years following account closure or the last transaction, whichever is later, as mandated by PAGCOR and AMLC guidelines.
• Gameplay Records: Retained for one (1) year from the date of the gaming activity for dispute resolution purposes, unless a longer retention period is required by ongoing regulatory investigation or legal proceedings.
• Marketing Consent Records: Retained for three (3) years following withdrawal of consent, as evidence of your consent preferences.
• Support Communications: Retained for two (2) years from the date of the interaction for quality assurance and dispute resolution purposes.

Following the expiry of the applicable retention period, personal data is securely deleted from phdre's active systems and backup archives in accordance with documented data disposal procedures. Where immediate deletion is not technically feasible, the data is isolated and marked for deletion at the earliest opportunity.

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

• Right to be Informed: You have the right to be informed whether your personal data is being processed by phdre, and if so, to receive details of the categories of data held, the purposes of processing, and the recipients of that data. This Privacy Policy serves as the primary mechanism for fulfilling this obligation.
• Right to Access: You may request a copy of the personal information phdre holds about you. phdre will provide this information in a commonly used electronic format within thirty (30) days of your verified request.
• Right to Rectification: If you believe that any personal information phdre holds about you is inaccurate, incomplete, or out of date, you may request that phdre correct or update it. You can update most account information directly through your account settings.
• Right to Erasure: You may request deletion of your personal data where: (a) the data is no longer necessary for the purposes for which it was collected; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on legitimate interests and no overriding grounds exist; or (d) the data has been unlawfully processed. This right is subject to phdre's legal obligations to retain certain data under PAGCOR and AML regulations.
• Right to Object: You have the right to object to processing of your personal data where that processing is based on phdre's legitimate interests. phdre will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: If you believe that phdre has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact phdre's Data Protection Officer through the contact details provided in Section 12. phdre will respond to verified data subject requests within thirty (30) days. phdre may request additional information to verify your identity before processing your request.

Registration on the phdre platform requires an affirmative declaration that you are at least 21 years of age. phdre verifies age through mandatory KYC procedures that require submission of government-issued identification documents prior to withdrawal processing. If phdre discovers that personal information has been collected from an individual under 21 years of age, that information will be deleted immediately and the account will be permanently closed in accordance with PAGCOR regulations.

Parents and guardians are encouraged to monitor their children's internet usage and to use parental control tools to prevent minors from accessing age-restricted content including online gaming platforms. If you have reason to believe that a minor has accessed the phdre platform, please contact phdre support immediately.

phdre reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in phdre's data processing practices, changes in applicable law, or changes in industry best practices. Any material changes to this Policy will be communicated to registered players via:

• A prominent notice displayed on the phdre platform home page;
• An SMS notification to your registered Philippine mobile number;
• An email notification to your registered email address (if provided).

The updated Privacy Policy will be effective from the date specified in the amendment notice. Your continued use of the phdre platform following the effective date of the updated Policy constitutes your acceptance of the changes. If you do not agree with the updated Privacy Policy, you may request account closure and data deletion in accordance with Section 9.

phdre recommends that you review this Privacy Policy periodically to stay informed of how your personal information is being protected. The effective date of the current Policy is displayed at the top of this document.

If you have questions, concerns, or complaints regarding this Privacy Policy or phdre's data processing practices, or if you wish to exercise any of your privacy rights described in Section 9, please contact phdre's Data Protection Officer through the following channels:

• Email: [email protected] with subject line "Data Privacy Enquiry"
• Live Chat: Available 24/7 through the phdre platform — select "Privacy & Data Protection" as your enquiry category

phdre will acknowledge all privacy-related enquiries within 48 hours and will provide a substantive response within thirty (30) days as required by the Philippine Data Privacy Act.

If you are not satisfied with phdre's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines: