phfune
Privacy Policy

1 Introduction

phfune takes its obligations under Philippine data privacy law seriously. As a PAGCOR-licensed online gaming platform serving Filipino players, phfune handles significant volumes of personal and financial information on a daily basis — from account registrations and GCash wallet transactions to gameplay session data and KYC identity documents. The integrity of how we handle that information is fundamental to the trust Filipino players place in phfune.

This Policy applies to all personal data processed by phfune in connection with your use of the phfune platform, including the phfune website at phfune.cam, all game environments, the phfune wallet system, customer support channels, and any marketing communications you have opted into. It applies regardless of whether you access phfune from Metro Manila, Cebu, Davao, or any other location in the Philippines.

This Policy should be read alongside phfune's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, phfune is the Personal Information Controller in respect of the personal data processed under this Policy. phfune determines the purposes for which and the means by which personal data is processed.

phfune has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with Philippine data privacy law. Contact details for phfune's DPO are provided in Section 14 of this Policy. The DPO can be reached for all data privacy-related enquiries, requests, and complaints.

3 Personal Data We Collect

phfune collects personal data through several channels — directly from you during registration and account use, automatically through your interaction with the platform, and from third-party sources where permitted by law and necessary for regulatory compliance.

3.1 Data Provided Directly by You

3.2 Data Collected Automatically

When you access phfune, the following data is automatically collected through standard technical means:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited on phfune, games accessed, session duration, login timestamps, and navigation patterns within the platform.
• Gaming Data: Bet history, game session logs, win/loss records, bonus wagering progress, and responsible gaming tool settings.
• Location Data: General geographic location derived from IP address, used to confirm access from within permitted jurisdictions. phfune does not collect precise GPS location data.
• Cookie & Tracking Data: See Section 7 for full details on phfune's use of cookies and similar tracking technologies.

3.3 Data from Third Parties

phfune may receive personal data about you from the following third-party sources:

• Payment Processors: Transaction confirmation data from GCash, Maya, BPI, BDO, and other payment partners, used to verify deposits and process withdrawals.
• Identity Verification Providers: Verification status and fraud-risk signals from certified KYC/AML service providers operating under Philippine data privacy law.
• Regulatory Bodies: PAGCOR may share compliance-related information about players in certain regulatory contexts.

4 How We Use Your Personal Data

phfune uses the personal data it collects for the following specific purposes:

5 Legal Basis for Processing

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

• Performance of Contract: Processing necessary to provide you with phfune's gaming services, manage your account, and process deposits and withdrawals pursuant to our Terms & Conditions.
• Legal Obligation: Processing required to comply with PAGCOR licensing requirements, Philippine AML regulations, KYC obligations, tax reporting requirements, and other applicable Philippine laws.
• Legitimate Interests: Processing necessary for phfune's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your data rights.
• Consent: Processing for marketing communications and optional platform analytics, where you have provided explicit, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

phfune does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your data with the following categories of recipients, strictly for the purposes described in this Policy:

6.1 Regulatory Authorities

phfune is required by law to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine regulatory bodies when lawfully requested or when required by reporting obligations. Such disclosures are made only to the extent required by applicable law.

6.2 Payment Service Providers

Payment data necessary to process deposits and withdrawals is shared with phfune's payment partners (including GCash, Maya, and Philippine banking partners) solely for transaction processing purposes. These providers are bound by their own regulatory obligations under BSP and Philippine data privacy law.

6.3 KYC & Identity Verification Providers

Identity documents and verification data may be shared with certified third-party KYC providers engaged by phfune to perform identity verification and fraud screening. All such providers operate under contractual data processing agreements consistent with the Data Privacy Act of 2012.

6.4 Technology Service Providers

phfune uses third-party technology providers for cloud hosting, platform infrastructure, game provision, customer support tooling, and security monitoring. These providers access personal data only as necessary to provide their contracted services to phfune and are bound by data processing agreements that impose obligations consistent with this Policy.

6.5 Law Enforcement

phfune may disclose personal data to Philippine law enforcement agencies or courts where legally compelled to do so by valid legal process, court order, or applicable law.

7 Cookies & Tracking Technologies

phfune uses cookies and similar tracking technologies on phfune.cam to ensure the platform functions correctly, to maintain your login session, and to analyze platform usage patterns.

7.1 Types of Cookies Used

• Essential Cookies: Required for the phfune platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limit configurations, and game lobby display preferences. Disabling these will not prevent platform access but may reduce personalization.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players navigate phfune, which game categories are most visited, and how platform performance can be improved. phfune uses only privacy-conscious analytics solutions for this purpose.

7.2 Managing Cookies

You may control cookie settings through your browser preferences. Please note that disabling essential cookies will impair your ability to use phfune's core services, including login and account management. phfune's cookie consent banner allows granular control over non-essential cookie categories on first visit to phfune.cam.

8 Data Retention

phfune retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to any overriding legal or regulatory retention requirements.

• Active Account Data: Retained for the duration of your phfune account, plus a minimum of five (5) years following account closure, as required by PAGCOR and Philippine AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR reporting obligations.
• KYC Documents: Retained for a minimum of five (5) years from account closure or the completion of the customer relationship, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the final interaction, unless retention is required for an ongoing dispute or regulatory matter.
• Marketing Consent Records: Retained for the duration of the consent and for three (3) years thereafter, as evidence of consent given.
• Technical & Log Data: Retained for up to twelve (12) months for security and fraud investigation purposes, after which it is deleted or anonymized.

Upon expiry of the applicable retention period, personal data is securely deleted or rendered permanently anonymous using industry-standard data destruction methods. Data retained for legal or regulatory purposes is access-restricted during the retention period.

9 Security Measures

phfune implements a layered set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These include:

• Encryption in Transit: All data transmitted between your device and phfune's servers is encrypted using TLS 1.3, the current industry standard for secure web communications.
• Encryption at Rest: Sensitive personal data stored in phfune's databases — including identity documents and financial data — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within phfune's systems is restricted to authorized personnel on a strictly need-to-know basis. All internal access is logged and audited.
• Password Security: Player passwords are stored as salted cryptographic hashes. phfune staff cannot view your password in plain text at any time.
• Two-Factor Authentication: phfune offers optional SMS-based two-factor authentication (2FA) for all player accounts, providing an additional layer of login security.
• Security Monitoring: phfune's platform is continuously monitored for suspicious activity, unauthorized access attempts, and potential data breaches using automated security tooling.
• Penetration Testing: phfune's platform undergoes periodic third-party security assessments to identify and address vulnerabilities before they can be exploited.

10 Your Data Rights

Under the Data Privacy Act of 2012 (Republic Act 10173), you have the following rights in respect of your personal data held by phfune:

• Right to Be Informed: The right to be informed of how your personal data is being processed. This Privacy Policy fulfils this obligation.
• Right to Access: The right to request a copy of the personal data phfune holds about you, the purposes for which it is being processed, and the recipients to whom it has been disclosed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data phfune 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 phfune's legal and regulatory retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where phfune is relying on legitimate interests as the legal basis.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, machine-readable format and to request its transfer to another data controller where technically feasible.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phfune has processed your data in violation of the Data Privacy Act.

To exercise any of the above rights, contact phfune's Data Protection Officer at the details provided in Section 14. phfune will respond to verifiable requests within thirty (30) days. We may require identity verification before processing access or deletion requests.

11 Minors & Age Restriction

phfune's gaming services are strictly restricted to individuals who are 21 years of age or older, as mandated by PAGCOR regulations. phfune does not knowingly collect personal data from persons under the age of 21.

If phfune becomes aware that personal data has been collected from a person under 21 years old — whether through age falsification during registration or other means — the relevant account will be immediately suspended, all data will be reviewed, and the matter will be handled in accordance with PAGCOR guidelines and Philippine data privacy law. Any funds held in such an account will be processed in accordance with regulatory requirements.

Parents and guardians who believe their minor child may have registered an account with phfune should contact phfune's Data Protection Officer immediately using the details in Section 14.

12 Cross-Border Data Transfers

phfune's primary data processing infrastructure is located within the Philippines. Where phfune engages third-party service providers — such as cloud infrastructure providers or game technology partners — that process data outside the Philippines, phfune ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012.

Such safeguards include contractual clauses that impose data protection obligations on recipient organizations equivalent to those applicable within the Philippines. phfune does not transfer personal data to jurisdictions that do not offer adequate data protection without implementing appropriate contractual safeguards.

13 Changes to This Privacy Policy

phfune may update this Privacy Policy periodically to reflect changes in our data processing practices, legal requirements, or platform services. When material changes are made, phfune will notify registered players via in-platform notification, registered email address, or SMS to the registered mobile number, at least seven (7) days before the updated Policy takes effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of phfune following the effective date of an updated Policy constitutes your acknowledgment of and agreement to the revised terms. If you do not agree with any updates, you may request account closure in accordance with phfune's Terms & Conditions.

14 Contact & Data Protection Officer

For all privacy-related enquiries, data subject rights requests, or complaints, please contact phfune's designated Data Protection Officer (DPO):

• Email (DPO): [email protected] — plain text; please copy and paste into your email client
• Subject Line: Include "Data Privacy Request" and your registered phfune username.
• Response Time: phfune aims to acknowledge all privacy requests within five (5) business days and to provide a substantive response within thirty (30) calendar days.

If you are not satisfied with phfune's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act of 2012.