phbey Privacy Policy

1. Introduction

phbey ("phbey," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the phbey online gaming platform, including the website at phbey.com and any associated mobile applications (collectively, the "Platform"). This Privacy Policy explains what personal data phbey collects, why we collect it, how we use and protect it, and the rights available to you as a data subject under Philippine law.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering an account on phbey or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with the phbey Terms & Conditions, which govern your use of the Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

phbey acts as the data controller in respect of the personal data collected through the Platform. As data controller, phbey determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws, including the DPA.

phbey has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection legislation. Contact details for the DPO are provided in Section 15 of this Policy.

3. Data We Collect

phbey collects personal data from you in the following categories:

3.1 Registration & Identity Data

When you create a phbey account, we collect your full legal name, date of birth, nationality, residential address, email address, and mobile number. This information is required to verify your identity, confirm your eligibility to use the Platform (including the 21+ age requirement), and comply with our Know Your Customer (KYC) obligations under Philippine anti-money laundering regulations.

3.2 Identity Verification Documents

To complete KYC verification, phbey may request copies of government-issued identification documents such as your PhilSys National ID, Philippine passport, SSS ID, GSIS ID, PRC ID, or driver's licence. We may also request proof of address documents such as utility bills or bank statements issued within the last three months.

3.3 Financial & Transaction Data

phbey collects records of all deposits, withdrawals, wagers, and bonuses associated with your account. We collect the payment method details necessary to process transactions — for example, your GCash or PayMaya registered mobile number, or your BPI, BDO, or Metrobank account name and number for bank transfers. Full payment credentials are processed by our certified payment processors and are not stored on phbey servers.

3.4 Gaming & Activity Data

phbey collects data about your gaming activity on the Platform, including game history, session duration, wagering patterns, and responsible gaming tool usage. This data is used to operate the Platform, detect fraud, and fulfil our responsible gaming obligations.

3.5 Technical & Device Data

When you access the Platform, phbey automatically collects technical data including your IP address, device type, operating system, browser type and version, screen resolution, and referring URL. This data is used for security monitoring, fraud prevention, and Platform optimisation.

3.6 Communications Data

If you contact phbey customer support via live chat, email, or any other channel, we retain records of those communications, including the content of your messages and any attachments, for quality assurance, dispute resolution, and regulatory compliance purposes.

3.7 Marketing Preferences

Where you have provided consent, phbey collects your marketing preferences, including your opt-in or opt-out status for promotional communications via email, SMS, and push notifications.

The table below summarises the main categories of data phbey collects:

4. How We Use Your Data

phbey uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your phbey account, including processing your registration, verifying your identity, and managing your account settings.
• Platform Operation: To provide you with access to all games, features, and services available on the phbey Platform, including processing deposits, withdrawals, and bonus credits.
• Legal & Regulatory Compliance: To comply with our obligations under the DPA, Philippine anti-money laundering laws (AMLA), PAGCOR regulations, and any other applicable legal requirements, including KYC verification and transaction monitoring.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce responsible gaming tools such as deposit limits and self-exclusion, and fulfil our duty of care obligations to players.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Marketing Communications: Where you have provided consent, to send you promotional offers, bonus notifications, and Platform updates via email, SMS, or push notification. You may withdraw consent at any time.
• Platform Improvement: To analyse usage patterns, conduct performance testing, and improve the features, content, and user experience of the phbey Platform.

5. Legal Basis for Processing

phbey processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given phbey your explicit consent to process your personal data for a specific purpose, such as receiving marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Contractual Necessity: Processing that is necessary for the performance of the contract between you and phbey — specifically, the Terms & Conditions governing your use of the Platform. This includes account registration, payment processing, and game operation.
• Legal Obligation: Processing that is required for phbey to comply with applicable laws and regulations, including KYC obligations under the Anti-Money Laundering Act (AMLA), PAGCOR licensing requirements, and NPC data protection regulations.
• Legitimate Interests: Processing that is necessary for phbey's legitimate business interests, including fraud prevention, Platform security, and responsible gaming monitoring, provided that such interests are not overridden by your rights and interests as a data subject.

6. Data Sharing & Disclosure

phbey does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phbey may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

6.1 Payment Processors

phbey shares necessary financial data with certified payment service providers — including GCash, PayMaya, and partner banks such as BPI, BDO, and Metrobank — to process deposits and withdrawals. These providers are contractually bound to process your data only for payment purposes and in accordance with applicable data protection laws.

6.2 Identity Verification Providers

phbey engages third-party KYC and identity verification service providers to assist with document verification and age confirmation. These providers process your identity documents under strict confidentiality obligations.

6.3 Regulatory Authorities

phbey may be required to disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities where required by law, court order, or regulatory directive.

6.4 Technology & Infrastructure Providers

phbey uses third-party technology providers for cloud hosting, data storage, analytics, and Platform infrastructure. These providers act as data processors on phbey's behalf and are contractually prohibited from using your data for any purpose other than providing services to phbey.

6.5 Professional Advisers

phbey may share personal data with legal counsel, auditors, and other professional advisers where necessary for the conduct of legal proceedings, regulatory investigations, or financial audits, subject to applicable professional confidentiality obligations.

7. International Data Transfers

Some of phbey's technology and service providers may be located outside the Philippines. Where personal data is transferred to recipients in other countries, phbey ensures that appropriate safeguards are in place to protect your data in accordance with the DPA and NPC regulations. Such safeguards may include contractual data processing agreements incorporating standard data protection clauses, or transfers to countries that the NPC has recognised as providing an adequate level of data protection.

By using the phbey Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

8. Data Retention

phbey retains your personal data for as long as your phbey account remains active and for such additional period as is required to comply with our legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine anti-money laundering regulations.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support Communications: Retained for a period of two (2) years from the date of the communication, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, after which your data will be suppressed from marketing lists.

Upon expiry of the applicable retention period, phbey will securely delete or anonymise your personal data in accordance with our data disposal procedures.

9. Cookies & Tracking Technologies

phbey uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain your session, analyse Platform performance, and support fraud prevention measures. The main types of cookies used by phbey are:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These cookies enable core features such as account login, session management, and security. They cannot be disabled without affecting Platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised data about how players use the Platform, including pages visited, time spent, and error messages encountered. This data helps phbey improve Platform performance and user experience.
• Functional Cookies: Used to remember your preferences and settings, such as your preferred language and display options, to provide a more personalised experience.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phbey Platform. phbey does not use cookies to serve third-party advertising.

10. Your Data Subject Rights

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

• Right to Be Informed: The right to be informed of how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phbey holds about you, together with information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data phbey holds about you. You may update most account information directly through your phbey 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 phbey'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 phbey'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) if you believe phbey has processed your personal data in violation of the DPA.

To exercise any of these rights, please contact phbey's Data Protection Officer using the contact details provided in Section 15. phbey will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

11. Children & Minors

The phbey Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. phbey does not knowingly collect personal data from individuals under the age of 21. If phbey becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended and the data will be deleted in accordance with our data disposal procedures.

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

12. Security Measures

phbey implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phbey Platform.
• Encrypted storage of sensitive personal data, including identity documents and financial records.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of Platform infrastructure.
• Two-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Continuous monitoring of Platform systems for suspicious activity and potential security incidents.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phbey will notify the NPC and affected data subjects in accordance with the timeframes and procedures prescribed by the DPA and NPC regulations.

13. Third-Party Links

The phbey Platform may contain links to third-party websites or services for informational purposes. phbey is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to the phbey Platform. We encourage you to review the privacy policies of any third-party websites you visit.

14. Policy Updates

phbey 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. Material changes to this Policy will be communicated to registered players via email or a prominent notice on the Platform prior to the changes taking effect. The "Last updated" date at the top of this Policy will be revised accordingly.

Your continued use of the phbey Platform following the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. We encourage you to review this Policy periodically to stay informed about how phbey protects your personal data.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phbey, please contact our Data Protection Officer:

Data Protection Officer — phbey
Email: [email protected]
General Support: [email protected]

Email addresses above are displayed as plain text for reference only and are not clickable links. phbey's customer support team is also available 24/7 via live chat on the Platform.

If you are not satisfied with phbey's response to your data subject request or believe your data protection rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).