Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how phdeam ("phdeam," "we," "us," "our") collects, uses, stores, discloses, and protects the personal information of users ("you," "Player," "User") who access or use the phdeam website, mobile platform, and all associated services (collectively, the "Platform").

phdeam is committed to protecting the privacy and personal data of all its users in accordance with the Philippine 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.

By registering an account, accessing the Platform, or using any phdeam service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the phdeam Platform immediately.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, phdeam acts as the Personal Information Controller (PIC) with respect to the personal data of its registered users and website visitors.

phdeam is responsible for determining the purposes and means of processing your personal data. Where phdeam engages third-party service providers to process data on its behalf, those providers act as Personal Information Processors (PIPs) and are contractually bound to process data only in accordance with phdeam's instructions and this Policy.

For all privacy-related inquiries, you may contact our Data Protection Officer (DPO) at [email protected].

3. Data We Collect

phdeam collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

3.1 Identity & Contact Data

• Full legal name
• Date of birth (for age verification — must be 21 or older)
• Nationality and country of residence
• Residential address (including barangay, city/municipality, province)
• Email address
• Mobile number

3.2 Identity Verification (KYC) Data

• Government-issued photo ID (e.g., Philippine passport, PhilSys National ID, SSS ID, driver's license, UMID)
• Proof of address documents
• Selfie or live photo for identity matching
• Source of funds documentation (where required by AML regulations)

3.3 Financial Data

• Payment method details (e.g., GCash mobile number, PayMaya account, BPI/BDO/Metrobank account reference)
• Transaction history (deposits, withdrawals, bonuses)
• Account balance information

3.4 Gaming & Behavioral Data

• Game history, session duration, and wagering activity
• Responsible gaming tool usage (deposit limits, self-exclusion requests)
• Bonus and promotion participation records

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Login timestamps and session logs
• Cookie identifiers and analytics data

3.6 Communications Data

• Records of your communications with phdeam customer support
• Feedback, survey responses, and complaint records

4. How We Collect Data

phdeam collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions.
• Automatically — through cookies, web beacons, and similar tracking technologies when you browse or use the phdeam Platform.
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud prevention services, and analytics providers, where permitted by law.

5. Purpose of Processing

phdeam processes your personal data for the following specific, legitimate purposes:

6. Legal Basis for Processing

phdeam processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent — where you have given clear, informed consent to the processing of your data for a specific purpose (e.g., marketing communications).
• Contractual necessity — where processing is necessary to perform the contract between you and phdeam (e.g., processing your deposit or withdrawal).
• Legal obligation — where processing is required to comply with applicable Philippine law, including AML regulations, PAGCOR requirements, and NPC directives.
• Legitimate interests — where processing is necessary for phdeam's legitimate business interests, such as fraud prevention and platform security, provided those interests are not overridden by your rights and freedoms.

7. Data Sharing

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

7.1 Service Providers

phdeam engages trusted third-party service providers who process data on our behalf, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, and customer support platforms. All such providers are contractually bound to process data solely in accordance with phdeam's instructions and applicable data protection law.

7.2 Legal and Regulatory Authorities

phdeam may disclose personal data to Philippine government authorities, including the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), PAGCOR, and law enforcement agencies, where required by law, court order, or regulatory directive.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of phdeam's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

8. Data Retention

phdeam 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. Specific retention periods include:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML regulations.
• Transaction records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent or for three (3) years from the last interaction, whichever is earlier.
• Technical and analytics data: Retained in anonymized or aggregated form for up to two (2) years.

Upon expiry of the applicable retention period, phdeam will securely delete or anonymize your personal data in accordance with its data disposal procedures.

9. Data Security

phdeam implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and phdeam's servers.
• Encryption of sensitive data at rest, including financial and identity information.
• Role-based access controls ensuring that only authorized phdeam personnel can access personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication (MFA) for internal system access.
• Incident response procedures to detect, report, and address personal data breaches in accordance with NPC notification requirements.

10. Cookies & Tracking Technologies

phdeam uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. The types of cookies we use include:

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling essential cookies may affect the functionality of the phdeam Platform.

11. Your Rights

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

• Right to be Informed — You have the right to know what personal data phdeam collects about you and how it is processed.
• Right of Access — You may request a copy of the personal data phdeam holds about you at any time.
• Right to Rectification — You may request correction of any inaccurate or incomplete personal data.
• Right to Erasure or Blocking — You may request deletion or blocking of your personal data where it is no longer necessary for the purpose it was collected, subject to phdeam's legal retention obligations.
• Right to Object — You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability — You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint — You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact phdeam's Data Protection Officer at [email protected]. phdeam will respond to all verified requests within thirty (30) days in accordance with NPC guidelines.

12. Minors

phdeam does not knowingly collect personal data from individuals under the age of 21. If phdeam becomes aware that personal data has been collected from a minor, that data will be immediately deleted and the associated account will be permanently closed. If you believe a minor has registered on phdeam, please notify us immediately at [email protected].

13. International Data Transfers

phdeam primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines, phdeam ensures that such transfers are conducted in compliance with the Data Privacy Act of 2012 and NPC regulations, including the implementation of appropriate safeguards such as data processing agreements and standard contractual clauses.

phdeam will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or without implementing appropriate protective measures.

14. Changes to This Policy

phdeam reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, phdeam will notify registered users via email or a prominent notice on the Platform. The "Last Updated" date at the top of this page will always reflect the most recent revision.

Your continued use of the phdeam Platform following the posting of any revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how phdeam protects your personal data.

15. Contact & Data Protection Officer

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

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 not been adequately addressed by phdeam.