phsuper Privacy Policy

This Privacy Policy ("Policy") describes how phsuper ("phsuper," "we," "us," or "our"), the operator of the online gaming platform accessible at https://phsuper.app, collects, uses, stores, shares, and protects the personal information of players and visitors ("you" or "your") in connection with your use of the phsuper platform.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. It also reflects phsuper's obligations under applicable gaming regulations administered by PAGCOR.

This Policy applies to all personal data collected through:

• The phsuper website at https://phsuper.app and all subdomains.
• The phsuper mobile platform and any associated applications.
• Communications between you and phsuper via email, live chat, or other channels.
• Any other interaction you have with phsuper in connection with your Account or use of our services.

This Policy should be read together with phsuper's Terms & Conditions, which govern your use of the phsuper platform as a whole.

phsuper collects the following categories of personal data from players and platform visitors. We only collect data that is necessary for the purposes described in this Policy.

phsuper does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by applicable law (for example, information related to responsible gaming self-exclusion requests).

phsuper collects personal data through the following methods:

• Direct Collection: Information you provide when registering a phsuper Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the phsuper platform, including IP address, device identifiers, browser information, and session activity, via cookies and similar tracking technologies (see Section 7).
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud and anti-money laundering screening services; payment data from payment processors such as GCash, PayMaya, and banking partners.
• Publicly Available Sources: In limited circumstances, phsuper may verify information against publicly available records, such as PAGCOR self-exclusion registers or court records, where required by law or for fraud prevention purposes.

phsuper does not purchase personal data lists from third-party data brokers or marketing companies for the purpose of unsolicited outreach to non-players.

phsuper uses the personal data we collect for the following specific purposes:

• Account Registration & Management: To create and maintain your phsuper Account, verify your identity, and manage your Account settings and preferences.
• Service Delivery: To provide access to phsuper's games, process your bets, calculate and credit winnings, and deliver the full range of phsuper platform features.
• Financial Transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods; to maintain accurate financial records; and to comply with financial reporting obligations.
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine anti-money laundering laws, including the Anti-Money Laundering Act (AMLA) as amended.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized Account access, and other illegal or prohibited conduct on the phsuper platform.
• Regulatory Compliance: To comply with our legal obligations under Philippine law, including reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC).
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through phsuper's 24/7 support channels.
• Responsible Gaming: To administer responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods; and to identify players who may be exhibiting signs of problem gambling.
• Platform Improvement: To analyze usage patterns, conduct A/B testing, and improve the phsuper platform's features, performance, and user experience for Filipino players.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may withdraw your consent at any time.
• Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the phsuper platform.

Under the Philippine Data Privacy Act of 2012, phsuper processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and phsuper — specifically, to operate your Account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with phsuper's legal obligations under Philippine law, including KYC requirements, AMLA reporting obligations, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for phsuper's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and business analytics — provided these interests are not overridden by your rights and interests.
• Consent: For marketing communications and certain non-essential cookies, phsuper relies on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

phsuper does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services that assist phsuper in verifying your identity and age in compliance with PAGCOR and AMLA requirements.
• Fraud Prevention & AML Screening Services: Third-party providers that assist phsuper in detecting and preventing fraudulent activity and money laundering.
• Game Software Providers: Licensed game developers and live dealer studios whose games are made available on the phsuper platform. These providers may receive limited technical data (such as session tokens) necessary to deliver their games.
• IT & Cloud Service Providers: Hosting, infrastructure, and cybersecurity service providers that support the operation of the phsuper platform.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or court order.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors engaged by phsuper, subject to professional confidentiality obligations.

All third-party service providers engaged by phsuper are required to process your personal data only in accordance with phsuper's instructions and applicable data protection law. phsuper does not permit third-party service providers to use your personal data for their own independent purposes.

phsuper uses cookies and similar tracking technologies to operate the platform, enhance your experience, and analyze usage patterns. The following types of cookies are used on the phsuper platform:

• Strictly Necessary Cookies: Essential for the phsuper platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the phsuper platform, including which games are most popular and how players navigate the site. This data helps phsuper improve the platform experience.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your gaming activity and preferences, where you have consented to receive marketing communications from phsuper.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies may impair your ability to use the phsuper platform.

phsuper retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account Data: Retained for the duration of your active phsuper Account, plus a minimum of five (5) years following Account closure, in compliance with PAGCOR record-keeping requirements and Philippine tax regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years following Account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the relevant interaction, or longer where the interaction relates to an unresolved dispute or legal claim.
• Marketing Preferences: Retained until you withdraw your consent or close your Account, plus a reasonable period to process the withdrawal.
• Technical & Log Data: Retained for up to twelve (12) months from the date of collection, unless required for longer retention in connection with a security investigation or legal proceeding.

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

phsuper implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL Encryption: All data transmitted between your device and phsuper's servers is encrypted using Transport Layer Security (TLS) protocols.
• Data Encryption at Rest: Sensitive personal data stored on phsuper's servers — including financial data and identity documents — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized phsuper personnel on a strict need-to-know basis. All internal access is logged and audited.
• Two-Factor Authentication: phsuper's internal systems require multi-factor authentication for all personnel accessing player data.
• Regular Security Audits: phsuper conducts regular penetration testing and security audits of its platform and infrastructure.
• Incident Response: phsuper maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, phsuper will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay.

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

• Right to Be Informed: The right to be informed of how your personal data is being collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phsuper holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data phsuper holds about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phsuper's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on phsuper's legitimate interests.
• Right to Data Portability: 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: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phsuper has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact phsuper's Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy. phsuper will respond to all data rights requests within thirty (30) calendar days of receipt. Where a request is complex or involves a large volume of data, phsuper may extend this period by a further thirty (30) days, with prior notice to you.

The phsuper platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations and Philippine law governing online gaming. phsuper does not knowingly collect personal data from persons under the age of 21.

If phsuper becomes aware that personal data has been collected from a person under 21 years of age, phsuper will:

• Immediately suspend the relevant Account pending investigation.
• Delete all personal data associated with the underage Account as soon as practicable.
• Return any deposits made to the Account via the original payment method, subject to verification.
• Forfeit any winnings associated with the underage Account.

phsuper employs age verification measures during the registration process and as part of its KYC procedures to prevent underage access to the platform. These measures include verification of government-issued identification documents.

The phsuper platform may contain links to third-party websites or services, such as payment provider portals (GCash, PayMaya) or game developer information pages. This Privacy Policy applies solely to the phsuper platform and does not extend to any third-party websites or services.

phsuper is not responsible for the privacy practices of any third-party websites linked from the phsuper platform. We encourage you to review the privacy policies of any third-party services you access in connection with your use of phsuper.

The inclusion of a link to a third-party website on the phsuper platform does not constitute an endorsement of that website or its privacy practices by phsuper.

phsuper primarily stores and processes player data within the Philippines. In certain circumstances, your personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or game software developers operating internationally.

Where personal data is transferred outside the Philippines, phsuper ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law.
• Transfers only to countries or organizations that the National Privacy Commission has determined provide an adequate level of data protection.
• Where required, obtaining your explicit consent to the international transfer of your personal data.

You may request further information about the safeguards phsuper has in place for international data transfers by contacting our Data Protection Officer at the details provided in Section 15.

phsuper 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. The most current version of this Policy will always be available on the phsuper platform at https://phsuper.app/privacy-policy, with the "Last Updated" date at the top of the page reflecting the date of the most recent revision.

Where phsuper makes material changes to this Policy — for example, changes that significantly affect how we use your personal data or your rights — phsuper will notify registered players via the email address associated with their Account at least seven (7) days before the changes take effect.

Your continued use of the phsuper platform after the effective date of any amendment to this Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Privacy Policy, you must discontinue use of the phsuper platform and may request closure of your Account by contacting our support team.

phsuper has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to this Policy or the processing of your personal data by phsuper, please contact our DPO using the details below.

All data privacy inquiries, data rights requests, and complaints should be directed to:

For general customer support inquiries unrelated to data privacy, please contact the phsuper support team at [email protected] or via the 24/7 live chat feature on the phsuper platform.

If you are not satisfied with phsuper's response to your data privacy inquiry or complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

phsuper is committed to working constructively with the NPC and with affected players to resolve any data privacy concerns promptly and fairly. We take all data privacy complaints seriously and will investigate each matter thoroughly before providing a substantive response.