phdci Privacy Policy

1. Introduction and Scope

This Privacy Policy (hereinafter "Policy") is issued by phdci (hereinafter "phdci," "we," "us," or "our") and applies to all personal data collected, processed, stored, or otherwise handled by phdci in connection with the operation of the phdci platform at https://phdci.net and all associated online casino, sports betting, and gaming services (collectively, the "Services").

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the data protection guidelines issued by the National Privacy Commission ("NPC"). Where phdci is subject to additional data protection obligations arising from PAGCOR licensing conditions or other applicable Philippine law, those obligations are incorporated into this Policy.

This Policy covers personal data collected from registered Players, prospective Players who browse the phdci website without registering, and any other individuals who interact with the phdci platform in any capacity. By using the Services, you acknowledge that you have read, understood, and accepted the practices described in this Policy.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and applicable PAGCOR regulatory requirements, phdci acts as the personal information controller in respect of the personal data collected and processed through the Services. phdci has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy and applicable data protection law.

If you have any questions about how phdci processes your personal data, wish to exercise your data subject rights, or need to contact the DPO, please use the contact details provided in Section 14 of this Policy. All data-related inquiries will be acknowledged within five (5) business days and addressed within the timelines prescribed by applicable Philippine law.

3. Personal Data We Collect

phdci collects the following categories of personal data in connection with operating the Services and complying with applicable regulatory requirements. The table below sets out the data categories, examples of specific data points within each category, and the primary purpose for which each category is collected.

4. How We Collect Your Data

4.1 Data You Provide Directly

The majority of personal data phdci holds about you is data you provide directly during the registration process, KYC verification, deposit and withdrawal transactions, customer support interactions, and when you update your account profile. You are responsible for ensuring that all data you provide to phdci is accurate, complete, and current.

4.2 Data Collected Automatically

When you access the phdci platform, certain technical and usage data is collected automatically through your browser or device. This includes your IP address, device identifiers, browser configuration, session activity, and interaction data with the platform interface. This automatic collection is necessary for platform security, fraud prevention, and service operation.

4.3 Data from Third Parties

phdci may receive personal data about you from third-party sources in limited circumstances, including:

• Payment service providers (such as GCash, PayMaya, and partner banks) who confirm transaction status and may flag suspicious payment activity.
• Identity verification service providers engaged by phdci to assist with KYC document validation.
• PAGCOR and other regulatory bodies, where they provide information relevant to licensing compliance or player protection obligations.
• Fraud detection and AML screening services that cross-reference account data against watchlists maintained under Philippine law.

Data received from third parties is handled in accordance with this Policy and used only for the purposes consistent with the context in which it was received.

5. How We Use Your Personal Data

phdci processes your personal data for the following purposes. Each purpose is supported by a legal basis as described in Section 6 of this Policy.

• Account registration and management: Creating and maintaining your phdci account, verifying your identity and age (21+), and administering your account wallet.
• Service delivery: Providing access to casino games, sports betting markets, live dealer games, slots, bingo, and all other Services available on the phdci platform.
• Transaction processing: Facilitating deposits via GCash, PayMaya, BPI, BDO, Metrobank, or 7-Eleven, and processing withdrawal requests to your nominated payment method.
• KYC and regulatory compliance: Fulfilling identity verification obligations under PAGCOR licensing conditions and Philippine anti-money laundering law (RA 9160, as amended by RA 10365).
• Fraud prevention and security: Detecting and preventing fraudulent activity, multi-account abuse, bonus misuse, and unauthorised access to player accounts.
• Responsible gaming: Monitoring gaming behaviour to identify potential signs of problem gambling, administering self-exclusion and deposit limit tools, and complying with PAGCOR responsible gaming requirements.
• Customer support: Responding to your enquiries, resolving account disputes, and providing technical assistance.
• Marketing communications: Sending you information about promotions, bonuses, new games, and platform features where you have provided consent. You may withdraw consent at any time.
• Platform improvement: Analysing aggregated and anonymised usage data to improve platform performance, user experience, and game selection.
• Legal compliance and regulatory reporting: Meeting obligations under Philippine law, PAGCOR regulations, and any lawful orders from competent Philippine authorities.

6. Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, phdci relies on the following legal bases to process your personal data:

• Contractual necessity: Processing necessary to enter into and perform the contract between you and phdci — including account registration, game provision, and transaction processing.
• Legal obligation: Processing required to comply with applicable Philippine law, including KYC verification under PAGCOR licensing conditions, AML obligations under RA 9160, and data retention requirements under applicable regulations.
• Legitimate interests: Processing conducted to pursue phdci's legitimate business interests, including fraud detection, platform security, multi-account prevention, and internal analytics — where these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

7.1 Payment Processors

phdci shares financial and identity data with payment service providers (including GCash, PayMaya, and partner banking institutions such as BPI, BDO, and Metrobank) to the extent necessary to process your deposit and withdrawal transactions. These providers process your data as data processors acting on phdci's instructions, subject to data processing agreements that require them to maintain appropriate security standards.

7.2 Game Software Providers

phdci operates games provided by third-party software suppliers. Technical data necessary for game operation (such as session identifiers and bet records) may be shared with these providers in the course of delivering the gaming Services. Game providers are bound by contractual obligations restricting their use of this data to service delivery purposes only.

7.3 Regulatory Authorities

phdci is required to share personal data with PAGCOR and, where applicable, other Philippine government agencies including the Anti-Money Laundering Council ("AMLC") and law enforcement authorities, where disclosure is required by law, court order, or lawful regulatory direction. phdci will notify you of such disclosures where it is legally permitted to do so.

7.4 Identity Verification and Fraud Prevention Services

phdci engages specialist third-party service providers to assist with KYC document verification, sanctions screening, and fraud detection. These providers act as processors under contract and may access identity data solely for the purpose of providing these services to phdci.

7.5 No Sale of Personal Data

phdci does not sell, rent, trade, or otherwise commercially exploit your personal data to any third party. Any sharing of personal data is limited to the categories described in this Section and is conducted for purposes directly related to the operation of the Services or compliance with applicable law.

8. Data Retention

phdci retains your personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods required by applicable Philippine law and PAGCOR regulations:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and AML regulations under RA 9160.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AML reporting obligations.
• Responsible gaming records: Self-exclusion records and responsible gaming tool activation logs are retained for the duration of the exclusion period and for five (5) years thereafter to prevent re-registration during active exclusion periods.
• Customer support communications: Retained for three (3) years from the date of the final interaction, for quality assurance and dispute resolution purposes.
• Marketing consent records: Retained for three (3) years from the date consent was withdrawn, to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, phdci will securely delete or anonymise personal data in accordance with its internal data disposal procedures, unless a longer retention period is required or permitted by applicable law.

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device by the phdci platform when you access the website. phdci uses cookies and similar tracking technologies (including web beacons and session tokens) to operate the platform, maintain your login session, remember your preferences, and collect anonymised usage analytics.

9.2 Types of Cookies Used

• Strictly necessary cookies: Essential for platform operation, including session management, login authentication, and security functions. These cookies cannot be disabled without disrupting service functionality.
• Functional cookies: Used to remember your preferences (such as language and display settings) to improve your experience on the phdci platform.
• Analytics cookies: Collect anonymised data about how Players interact with the platform, which pages are visited most frequently, and how navigation flows are used. This data helps phdci improve the platform experience.
• Security cookies: Used for fraud detection and multi-account identification purposes, including device fingerprinting to detect suspicious login patterns.

9.3 Managing Cookies

You may configure your browser to refuse or delete cookies at any time. However, disabling strictly necessary cookies will impair your ability to use core platform functions, including logging in and conducting transactions. Analytics and functional cookies may be disabled without affecting core platform access.

10. Security Measures

phdci implements a range of technical and organisational security measures to protect your personal data, including:

• Encryption of personal data in transit using industry-standard TLS protocols.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• Role-based access controls ensuring that personal data is accessible only to phdci personnel who require it to perform their job functions.
• Regular internal security reviews and vulnerability assessments.
• Staff training on data protection obligations under Philippine law and phdci's internal policies.
• Incident response procedures for detecting, reporting, and addressing personal data breaches in accordance with NPC notification requirements.

Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, phdci will notify you and the NPC in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by phdci. To exercise any of these rights, please contact phdci using the details in Section 14. phdci will respond to verified requests within the timelines prescribed by the NPC.

• Right to be Informed: The right to know what personal data phdci collects about you, how it is used, and with whom it is shared — as set out in this Policy.
• Right to Access: The right to request a copy of the personal data phdci holds about you and information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your phdci account settings.
• 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 overriding legal retention obligations (see Section 8).
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on phdci's legitimate interests.
• Right to Data Portability: The right to request a copy of personal data you have provided to phdci in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe phdci has processed your personal data in breach of applicable Philippine data protection law. The NPC's contact details are publicly available at the NPC's official website.

12. Children and Minors

The phdci platform is strictly for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gambling in the Philippines. phdci does not knowingly collect personal data from individuals under the age of 21. If phdci becomes aware that it has collected personal data from a person under 21, the account will be closed immediately, all transactions will be voided, and the personal data will be deleted or anonymised in accordance with applicable law and PAGCOR guidelines.

If you believe a minor has registered a phdci account, please contact phdci support immediately using the contact details in Section 14 so that the matter can be investigated and resolved promptly.

13. Updates to This Privacy Policy

phdci reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, or phdci's data processing practices. Material changes to this Policy will be communicated to registered Players via the email address on record or through a prominent notice on the phdci website prior to the change taking effect.

The effective date at the top of this Policy will be updated to reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how phdci handles your personal data. Continued use of the Services after the updated Policy takes effect constitutes your acceptance of the revised terms.

14. Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, want to raise a data protection concern, or need to contact phdci's Data Protection Officer, please reach out through any of the following channels. Our support and compliance team is available 24 hours a day, 7 days a week including Philippine public holidays.

• Live Chat: Available directly on the phdci website — the fastest channel for general account support.
• Email (Data Protection): [email protected] — for data subject requests, please include "Data Privacy Request" in your subject line and your registered account email address.
• Messenger / Viber: Via the official phdci social channels.
• Location: Philippines (PST, UTC+8)

If your concern is not resolved to your satisfaction through phdci's internal process, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines.