phspi Privacy
Policy

phspi ("phspi," "we," "us," or "our") operates the online gaming platform accessible at phspi.cam, a PAGCOR-licensed gaming service offered to eligible Filipino players aged 21 and above. In the course of providing our services, phspi collects and processes personal information relating to our registered players and website visitors.

We understand that your personal data is important to you. This Privacy Policy ("Policy") is designed to give you a clear and complete picture of how phspi collects, uses, stores, protects, and in limited circumstances shares your personal information. We encourage you to read this Policy in full before creating a phspi account or using our platform.

By registering a phspi account, logging in to an existing account, or continuing to use phspi's services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein, to the extent that consent is the applicable legal basis for such processing.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, phspi is the personal information controller ("PIC") in respect of the personal data collected and processed through the phspi.cam platform.

phspi operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to PAGCOR's data governance requirements as part of its licensing conditions. phspi has designated a Data Protection Officer (DPO) as required under the Data Privacy Act. Contact details for the DPO are provided in Section 15 of this Policy.

phspi collects different categories of personal data depending on how you interact with the platform. The following table describes the categories of personal data we collect and the context in which each category is collected:

phspi does not collect sensitive personal information as defined under the Data Privacy Act (such as health information, political opinions, or religious beliefs) except where specifically required by law or with your express written consent for a specific, defined purpose.

phspi collects personal data through the following channels and mechanisms:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access phspi.cam, including through cookies, web beacons, server logs, and device fingerprinting technologies used to verify your location and detect fraud.
• Third-party sources: Identity verification data from government-issued ID document verification services; geolocation and device integrity data from fraud prevention partners; payment transaction confirmation data from GCash, Maya, and banking partners.
• PAGCOR and law enforcement: Information received in response to lawful requests from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine government authorities exercising their lawful powers.

phspi processes your personal data only for specific, legitimate purposes. The following table sets out the primary purposes for which we process your data and the legal basis for each:

phspi does not use your personal data for automated decision-making that produces legal or similarly significant effects without a human review process, except where automated checks are strictly required by PAGCOR or AMLC compliance systems.

phspi does not sell, rent, or trade your personal information. We share your data only in the following limited and defined circumstances:

• Payment processors: GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment channels receive transaction-specific financial data necessary to process your deposits and withdrawals.
• KYC and identity verification partners: Third-party identity verification service providers receive document images and identity data solely for the purpose of completing PAGCOR-mandated KYC checks.
• Game software providers: Game providers whose titles appear on phspi receive anonymized session and bet data necessary for game functionality and RNG certification. They do not receive your identity or financial data.
• Fraud prevention and security vendors: Specialist fraud detection services receive limited technical data (IP addresses, device identifiers, behavioral signals) to identify and block fraudulent activity on the platform.
• Regulatory and government authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies may receive data in response to lawful requests, orders, or as required by phspi's licensing obligations.
• Professional advisers: Legal counsel, auditors, and compliance consultants bound by professional confidentiality obligations may access data as necessary for advisory services.

phspi uses cookies and similar tracking technologies on phspi.cam to operate the platform effectively, maintain session security, prevent fraud, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for core platform functionality, including maintaining your login session, CSRF protection, and load balancing. These cannot be disabled without breaking core platform features.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limit configurations, and display preferences to personalize your experience.
• Analytical Cookies: Collect anonymized or pseudonymized data about how players use phspi.cam, including pages visited and features used. This data is used to improve the platform and does not identify you personally.
• Security and Fraud Prevention Cookies: Detect suspicious behaviors, verify your geographic location for PAGCOR compliance, and identify device characteristics to prevent account takeover and fraud.

You can manage non-essential cookies through your browser settings. Note that disabling certain cookie categories may affect your ability to use some phspi platform features. Strictly necessary and security cookies cannot be disabled.

phspi retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to longer retention where required by applicable law or PAGCOR regulations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account relationship with phspi and for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and Anti-Money Laundering Act record-keeping obligations.
• Financial transaction records: Retained for a minimum of ten (10) years from the date of each transaction in compliance with AMLC and Bureau of Internal Revenue (BIR) requirements.
• Gaming activity and session logs: Retained for a minimum of five (5) years as required by PAGCOR audit and dispute resolution obligations.
• Customer support communications: Retained for three (3) years from the date of the interaction.
• Marketing consent records: Retained for two (2) years from the date consent was given or last renewed.
• Technical and analytical data (anonymized): May be retained indefinitely in anonymized, aggregated form for platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. phspi does not retain personal data in identifiable form beyond the periods described above.

phspi implements technical and organizational measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data in transit between your device and phspi's systems.
• AES-256 encryption for personally identifiable data stored in phspi's databases.
• Two-factor authentication (2FA) via OTP for player account access and for internal administrative access to player data systems.
• Role-based access controls limiting employee access to personal data strictly to those whose job functions require it.
• Regular penetration testing and vulnerability assessments by qualified security professionals.
• Intrusion detection and prevention systems monitoring for unauthorized access attempts in real time.
• Documented data breach response procedures aligned with NPC breach notification requirements.
• Staff training on data privacy obligations under the Data Privacy Act of 2012 and phspi's internal data protection policies.

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by phspi:

To exercise any of the above rights, please contact phspi's Data Protection Officer via Live Chat or the support email listed in Section 15. phspi will respond to verified data subject rights requests within fifteen (15) calendar days as required by the Data Privacy Act's Implementing Rules and Regulations. Requests will be verified against your registered account identity before processing.

Please note that certain data subject rights may be limited where phspi has a legal obligation to retain or continue processing your data under PAGCOR regulations, the Anti-Money Laundering Act, or other applicable Philippine law.

phspi's gaming services are strictly limited to persons who are at least twenty-one (21) years of age, as required by PAGCOR regulations. phspi does not knowingly collect personal data from persons under the age of 21.

If phspi becomes aware that personal data has been collected from a person under the age of 21 — whether through account registration using false date of birth information or any other means — phspi will immediately suspend and permanently terminate the relevant account, and will delete all personal data associated with that account to the extent permitted by law, subject to any overriding record-keeping obligations.

phspi's primary data storage and processing infrastructure is located within the Philippines or in data centers that meet the security and privacy standards required by phspi's PAGCOR licensing conditions.

In limited circumstances, personal data may be processed by phspi's service providers in other countries — for example, where international game software providers require pseudonymized session data for RNG certification audits, or where a fraud detection vendor's systems are hosted outside the Philippines. In all such cases, phspi:

• Conducts due diligence to ensure the receiving party maintains data protection standards equivalent to those required under the Data Privacy Act of 2012.
• Executes data sharing agreements or equivalent contractual safeguards as required by NPC guidelines on cross-border data flows.
• Minimizes the personal data transferred to the minimum necessary for the specific processing purpose.
• Does not transfer financial data, government ID data, or full identity data internationally without explicit NPC compliance review.

phspi.cam may contain references or links to third-party websites operated by phspi's game software providers, payment partners, or regulatory bodies such as PAGCOR. phspi's Privacy Policy applies only to the phspi.cam platform. phspi has no control over and assumes no responsibility for the privacy practices or content of any third-party websites.

We encourage you to review the privacy policy of any third-party site you visit through a link from phspi.cam. Accessing any third-party site is at your own risk and subject to that site's own terms and privacy practices.

phspi may update this Privacy Policy from time to time to reflect changes in our data processing practices, new regulatory requirements, updates to PAGCOR guidelines, or improvements to our privacy program. When we make material changes — meaning changes that significantly affect how we process your personal data or the rights available to you — we will notify registered players via the mobile number associated with their account, no less than seven (7) days before the updated Policy takes effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. We encourage you to review this Policy periodically. Your continued use of phspi's services after the effective date of any update constitutes your acknowledgment of the updated Policy. If you do not agree with the updated Policy, you should stop using phspi's services and may close your account in accordance with the Terms & Conditions.

phspi has designated a Data Protection Officer (DPO) as required under Section 21 of the Data Privacy Act of 2012 and NPC Circular 17-01. The DPO is responsible for overseeing phspi's compliance with data privacy obligations, responding to data subject rights requests, and acting as the point of contact for the National Privacy Commission.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a concern about phspi's data handling practices, you may contact us through the following channels:

• Live Chat: Available 24/7 via the chat widget on phspi.cam. For urgent data security concerns, Live Chat is the fastest channel.
• Support Email (plain text — not a clickable link): [email protected]
• Subject line for DPO inquiries: Please use "Data Privacy Request" or "DPO Inquiry" in your message subject so your request reaches the correct team promptly.

phspi's DPO will acknowledge receipt of your request within 3 business days and will aim to fully resolve data subject rights requests within 15 calendar days as required by NPC regulations. For particularly complex requests involving large volumes of data or requiring multi-system review, phspi may notify you of an extended resolution period not exceeding 30 calendar days in total.