Privacy Policy – phsky.ph

01 Introduction

phsky.ph ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all users who access or use our website, mobile application, and associated gaming services (collectively, the "Services"). This Privacy Policy has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as well as applicable guidelines issued by the National Privacy Commission (NPC).

This Privacy Policy applies to all personal information collected by phsky.ph in connection with your use of the Services, whether you are a registered player, a visitor browsing the platform, or a person who contacts us for support. By accessing or using the Services, 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 have any questions about this Privacy Policy or how phsky.ph handles your personal data, please contact our Data Protection Officer (DPO) using the contact details provided in Section 12 of this document.

02 Personal Data We Collect

phsky.ph collects personal data that is necessary for the operation of the platform, the provision of gaming services, and compliance with applicable legal and regulatory obligations. The categories of personal data we collect include:

We collect personal data directly from you when you register an account, make a deposit or withdrawal, contact our support team, or interact with the platform. We may also collect technical data automatically through cookies and similar tracking technologies, as described in Section 6.

03 How We Use Your Personal Data

phsky.ph uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your player account, including verifying your identity and age (21+ requirement) in accordance with PAGCOR regulations.
• Service Delivery: To provide you with access to our gaming services, process your deposits and withdrawals, and deliver the features and functionality of the phsky.ph platform.
• KYC & AML Compliance: To fulfill our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Philippine law, including verification of identity, source of funds, and source of wealth where required.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal or prohibited conduct on the platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and apply deposit and session limits set by players.
• Customer Support: To respond to your inquiries, resolve complaints, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time.
• Legal & Regulatory Compliance: To comply with applicable laws, regulations, court orders, and requests from regulatory authorities including PAGCOR and the Anti-Money Laundering Council (AMLC).
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the phsky.ph platform.

phsky.ph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

04 Legal Basis for Processing

Under the Data Privacy Act of 2012, phsky.ph processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and phsky.ph — specifically, to provide you with access to the gaming platform and associated services.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including KYC/AML obligations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for the legitimate interests of phsky.ph, including fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

05 Data Sharing & Disclosure

phsky.ph does not sell, rent, or trade your personal data to third parties for commercial purposes. We may, however, share your personal data with the following categories of recipients where necessary and lawful:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulation.
• Payment Service Providers: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals. These providers are bound by their own privacy policies and applicable data protection obligations.
• Identity Verification Providers: Third-party KYC service providers engaged to assist with identity verification and fraud prevention. All such providers are contractually bound to process data only on our instructions and in accordance with applicable data protection law.
• Technology & Infrastructure Providers: Cloud hosting, cybersecurity, and platform technology providers who process data on our behalf under strict data processing agreements.
• Game Content Providers: Licensed game studios and software providers whose games are available on the phsky.ph platform may receive limited technical data necessary for game delivery and integrity monitoring.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors engaged by phsky.ph, subject to professional confidentiality obligations.

06 Cookies & Tracking Technologies

phsky.ph uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support our security and fraud prevention measures. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the operation of the platform, including session management, authentication, and security. These cookies cannot be disabled without affecting core platform functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymized data about how players use the platform — such as pages visited, time spent, and error messages encountered — to help us improve the Services.
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming limits, to provide a more personalized experience.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phsky.ph platform. For more information on managing cookies, refer to your browser's help documentation.

07 Data Retention

phsky.ph retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. Our general data retention principles are as follows:

• Active Accounts: Personal data associated with active player accounts is retained for the duration of the account relationship and for a period of at least five (5) years following account closure, in accordance with AML record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority.
• Support Communications: Customer support records are retained for a period of three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing Data: Data used for marketing purposes is retained until you withdraw consent or opt out of marketing communications, after which it is deleted or anonymized within a reasonable timeframe.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with phsky.ph's data disposal procedures.

08 Your Privacy Rights

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

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data phsky.ph holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request the deletion of your personal data, subject to applicable legal and regulatory retention requirements. We may be unable to delete certain data where retention is required by law.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our demonstrating compelling legitimate grounds.
• 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 Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that phsky.ph has processed your personal data in violation of the Data Privacy Act of 2012.

09 Data Security

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

• SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls ensuring that personal data is accessible only to authorized personnel with a legitimate business need.
• Regular security assessments, penetration testing, and vulnerability scanning of our platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Employee training on data protection obligations and information security best practices.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

10 Children's Privacy & Age Restriction

The Services provided by phsky.ph are strictly intended for individuals who are at least 21 years of age, in accordance with PAGCOR regulations and applicable Philippine law governing online gambling activities.

phsky.ph does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds held in an underage account will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that a minor has registered an account on phsky.ph, please contact our support team immediately so that we can investigate and take appropriate action.

11 Changes to This Privacy Policy

phsky.ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, we will provide reasonable advance notice to registered users via email or an in-platform notification prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Services following the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how phsky.ph protects your personal data.

12 Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phsky.ph, please contact our Data Protection Officer (DPO):

You may also reach our general support team at [email protected] for account-related queries. Our team is available 24 hours a day, 7 days a week.

phsky.ph aims to acknowledge all privacy-related correspondence within five (5) business days and to resolve requests within thirty (30) days, or within the timeframe required by the Data Privacy Act of 2012 and NPC guidelines.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.