Privacy Policy — phtala.ph Online Casino & Betting Platform

1 Data Controller

phtala.ph operates as the data controller for all personal information collected through the Platform at phtalaph.app. As data controller, phtala.ph determines the purposes and means of processing your personal data and is responsible for ensuring that all processing activities comply with the Philippine Data Privacy Act of 2012 (RA 10173) and the implementing rules and regulations issued by the National Privacy Commission (NPC).

phtala.ph operates under PAGCOR authorization and is subject to PAGCOR's data governance requirements in addition to those imposed by the NPC. Where PAGCOR requirements impose a higher standard of data protection, that standard applies.

2 Personal Data We Collect

phtala.ph collects the following categories of personal data from Players:

3 How We Collect Your Data

phtala.ph collects personal data through the following means:

• Direct collection: Information you provide when registering a phtala.ph account, completing KYC verification, submitting deposit or withdrawal requests, or contacting customer support;
• Automated collection: Technical and usage data collected automatically through cookies, log files, and analytics tools when you access and use the Platform;
• Third-party sources: Identity verification data from KYC service providers; transaction data from payment processors including GCash, Maya, BPI, BDO, and Metrobank; and fraud detection signals from anti-fraud service providers.

4 Purposes of Processing

phtala.ph processes your personal data for the following purposes:

• Account registration and management: Creating and maintaining your phtala.ph account, verifying your identity, and managing your login credentials;
• KYC and age verification: Confirming that you are at least 21 years of age and verifying your identity as required by PAGCOR and Philippine anti-money laundering laws;
• Payment processing: Processing deposits and withdrawals via GCash, Maya, bank transfer, and other accepted Philippine payment channels;
• Game operation: Delivering gaming services, maintaining game history, calculating winnings, and resolving disputes;
• Legal and regulatory compliance: Meeting PAGCOR reporting obligations, complying with the Anti-Money Laundering Act (AMLA), and responding to lawful requests from Philippine authorities including AMLC;
• Security and fraud prevention: Detecting and preventing unauthorized access, fraudulent transactions, bonus abuse, and other prohibited conduct;
• Customer support: Responding to inquiries, resolving complaints, and providing technical assistance;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering self-exclusion, deposit limits, and cooling-off periods;
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates — only to Players who have opted in to receive such communications.

5 Legal Bases for Processing

phtala.ph processes personal data on the following legal bases under RA 10173:

• Contractual necessity: Processing required to perform our obligations under the phtala.ph Terms & Conditions, including account management, payment processing, and game operation;
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA, RA 9160 as amended, and other applicable Philippine laws;
• Legitimate interest: Processing for fraud detection, platform security, and responsible gaming monitoring, where these interests do not override your fundamental rights;
• Consent: Processing for marketing communications, where you have explicitly opted in. You may withdraw consent for marketing at any time by updating your Account Settings or by contacting [email protected].

6 Data Sharing and Disclosure

phtala.ph does not sell, rent, or trade your personal data. We share data only in the following limited circumstances:

6.1 Service Providers

phtala.ph shares necessary personal data with third-party service providers who process data on our behalf under written data processing agreements. These include KYC verification providers, payment processors (GCash, Maya, BPI, BDO, Metrobank, 7-Eleven CLiQQ), anti-fraud platforms, cloud infrastructure providers, and customer support tool providers. All service providers are contractually bound to process data only on phtala.ph's instructions and to maintain appropriate security measures.

6.2 Regulatory Authorities

phtala.ph discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where required by law, regulation, or lawful order.

6.3 Game Providers

Certain game providers (such as Evolution Gaming, Pragmatic Play, and JILI) receive limited technical data (such as Player session tokens) necessary to deliver their games within the phtala.ph platform. These providers are contractually prohibited from using this data for purposes beyond game delivery.

7 International Data Transfers

Some of phtala.ph's service providers and game technology partners are based outside the Philippines. Where personal data is transferred internationally, phtala.ph ensures that appropriate safeguards are in place consistent with RA 10173, including data processing agreements incorporating the NPC's standard contractual clauses or equivalent protections. phtala.ph will not transfer personal data to a jurisdiction that does not provide an adequate level of data protection without implementing appropriate safeguards.

8 Data Retention

phtala.ph retains personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods:

• Account and KYC data: Retained for a minimum of 5 years following account closure, as required by PAGCOR regulations and AMLA record-keeping obligations;
• Transaction and gaming records: Retained for a minimum of 5 years from the date of each transaction, consistent with Philippine financial record-keeping requirements;
• Customer support records: Retained for 3 years from the date of the last interaction, unless a longer period is required for pending dispute resolution;
• Marketing data: Retained until you withdraw consent or request deletion, subject to any overriding legal obligation to retain.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized.

9 Security Measures

phtala.ph implements the following technical and organizational security measures to protect your personal data:

• 256-bit SSL/TLS encryption on all data transmitted between your device and phtala.ph;
• Encryption at rest for all stored personal and financial data;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication for internal administrative systems;
• Regular penetration testing and security audits of the Platform;
• Incident response procedures compliant with RA 10173 notification requirements — including breach notification to the NPC and affected Players within 72 hours of discovering a breach that poses a real risk of serious harm.

No data transmission over the internet is completely secure. While phtala.ph takes all reasonable precautions, we cannot guarantee absolute security. Players are advised to maintain strong, unique passwords and to enable two-factor authentication on their phtala.ph accounts.

10 Cookies and Tracking Technologies

phtala.ph uses cookies and similar technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function, including session management and login authentication. These cannot be disabled;
• Functional cookies: Remember your preferences (such as language settings and preferred payment method) to improve your experience on phtala.ph;
• Analytics cookies: Collect aggregated, anonymized data about how Players navigate phtala.ph, enabling us to improve Platform performance and user experience;
• Security cookies: Used for fraud detection and to ensure the integrity of phtala.ph login sessions.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use core phtala.ph features including the login portal.

11 Your Data Rights

Under the Philippine Data Privacy Act of 2012, phtala.ph Players have the following rights regarding their personal data:

• Right to be informed: You have the right to know what personal data phtala.ph holds about you and how it is processed — which is what this Policy describes;
• Right of access: You may request a copy of the personal data phtala.ph holds about you at any time;
• Right to correction: You may request correction of inaccurate or incomplete personal data. Many details can be updated directly through Account Settings;
• Right to erasure: You may request deletion of your personal data, subject to overriding legal retention obligations (such as AMLA record-keeping requirements);
• Right to data portability: You may request your personal data in a structured, commonly used format;
• Right to object: You may object to processing of your data for direct marketing purposes at any time by updating your marketing preferences or contacting support;
• Right to file a complaint: If you believe phtala.ph has processed your data in breach of RA 10173, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, contact phtala.ph's Data Protection Officer at [email protected]. We will respond within 15 days of receiving a valid request, consistent with NPC guidelines.

12 Minors

phtala.ph does not knowingly collect personal data from individuals under 21 years of age. All phtala.ph services are strictly restricted to players aged 21 and above in compliance with PAGCOR regulations. If phtala.ph discovers that personal data has been collected from a minor, the account will be immediately closed, all data securely deleted, and the matter reported to PAGCOR. If you believe a minor has registered on phtala.ph, please report this to us immediately at [email protected].

13 Changes to This Privacy Policy

phtala.ph may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or PAGCOR regulatory requirements. Material changes will be communicated to registered Players via the email address on file at least 7 days before the changes take effect. The effective date at the top of this Policy will be updated accordingly. Continued use of phtala.ph after the effective date of any revised Policy constitutes acceptance of the changes. If you do not agree with the revised Policy, you may request account closure by contacting support.

14 Contact & Data Protection Officer

phtala.ph has designated a Data Protection Officer (DPO) in compliance with RA 10173. For all privacy-related inquiries, data subject rights requests, or complaints, please contact:

Data Protection Officer — phtala.ph
Email: [email protected]
Response time: Within 15 business days of receiving a valid request.

For general customer support, platform questions, and account issues, our support team is available 24/7 via the same email address. For regulatory complaints not resolved through our internal process, you may contact the National Privacy Commission (NPC) of the Philippines.