phsweete Privacy Policy

1.1 This Policy applies to all personal information collected by phsweete through the phsweete.club website, mobile-optimised platform, customer support channels, and any other services operated by phsweete. It applies to all registered players, prospective players who browse the platform, and individuals who contact phsweete for support.

1.2 phsweete is the personal information controller responsible for your data. We determine the purposes and means of processing your personal information and are accountable for ensuring that processing is carried out lawfully, fairly, and transparently in accordance with RA 10173.

1.3 This Policy does not apply to third-party websites or services that may be referenced on the phsweete platform. phsweete is not responsible for the privacy practices of any third party, and we encourage you to review the privacy policies of any third-party services you use.

2.1 phsweete collects the following categories of personal information from players and platform users:

2.2 phsweete does not intentionally collect sensitive personal information as defined under RA 10173 (such as health data, political opinions, or religious beliefs) unless specifically required by law or regulatory obligation. Where such data is incidentally received, it will be handled with the heightened protections required by RA 10173.

3.1 phsweete collects personal information through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and interact with the phsweete platform, including through cookies, server logs, and analytics tools.
• Third-party sources: Identity and fraud-check data received from KYC verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank), and PAGCOR-mandated player protection databases.

3.2 Where phsweete receives personal information about you from a third party, we will handle that information in accordance with this Policy and notify you of the source where required by RA 10173.

4.1 phsweete processes your personal information for the following purposes:

• Account management: To register, verify, maintain, and administer your phsweete player account.
• Identity verification (KYC): To verify your identity and age (21+) as required by PAGCOR regulations and anti-money laundering obligations.
• Payment processing: To process deposits, withdrawals, and refunds through your chosen payment method.
• Platform operation: To deliver games, record bet outcomes, calculate winnings, and maintain the integrity of the phsweete platform.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Regulatory compliance: To comply with PAGCOR licensing requirements, anti-money laundering laws, tax obligations, and NPC data privacy regulations.
• Responsible gaming: To monitor gameplay patterns, identify at-risk players, and administer self-exclusion and deposit limit programs.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and unauthorised account access.
• Platform improvement: To analyse usage patterns and improve the phsweete platform experience for Filipino players.
• Marketing communications: To send you promotional offers and updates about phsweete, where you have provided consent or where permitted by applicable law. You may opt out at any time.

4.2 phsweete will not process your personal information for any purpose incompatible with those listed above without first obtaining your consent or establishing a separate lawful basis for the new processing purpose.

5.1 phsweete processes your personal information on the following legal bases as recognised under RA 10173:

• Contractual necessity: Processing required to perform our contract with you, including account registration, payment processing, and game delivery.
• Legal obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws (AMLA), tax laws, and NPC requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6.1 phsweete does not sell your personal information. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing your transactions.
• KYC and identity verification providers: Third-party services that assist phsweete in verifying your identity and age as required by PAGCOR.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law.
• IT and platform service providers: Cloud hosting, cybersecurity, and analytics providers who process data on phsweete's behalf under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

6.2 All third parties with whom phsweete shares personal data are required to handle that data in accordance with RA 10173 and phsweete's data protection standards. phsweete remains accountable for data shared with processors acting on our behalf.

7.1 phsweete retains your personal information for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by PAGCOR and AMLA regulations.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA and tax record-keeping requirements.
• Customer support communications: Retained for three (3) years from the date of the communication, or longer if related to an ongoing dispute or regulatory investigation.
• Technical and usage logs: Retained for up to twelve (12) months for security and fraud prevention purposes, unless longer retention is required for an active investigation.
• Marketing consent records: Retained for the duration of your consent and for three (3) years thereafter as evidence of consent.

7.2 When personal information is no longer required for its original purpose and no legal retention obligation applies, phsweete will securely delete or anonymise the data in accordance with our data disposal procedures.

8.1 phsweete implements appropriate technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration, loss, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and phsweete servers;
• Encryption of sensitive data at rest, including financial information and government ID copies;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing of the phsweete platform;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Continuous monitoring for suspicious activity and potential data breaches.

8.2 In the event of a personal data breach that is likely to result in harm to affected individuals, phsweete will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with RA 10173 breach notification requirements.

8.3 While phsweete takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phsweete account credentials and for notifying us immediately if you suspect unauthorised access to your account.

9.1 phsweete uses cookies and similar tracking technologies (such as web beacons and local storage) on the phsweete platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game display options to improve your experience on phsweete.
• Analytics cookies: Collect anonymised data about how players use the phsweete platform to help us identify areas for improvement. No personally identifiable information is shared with analytics providers.

9.2 phsweete does not use third-party advertising or retargeting cookies. We do not allow external advertisers to place cookies on the phsweete platform.

9.3 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 phsweete platform. Strictly necessary cookies cannot be disabled as they are required for the platform to operate.

10.1 Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal information held by phsweete:

11.1 phsweete implements age verification controls at the point of registration and during KYC verification to prevent access by individuals under 21 years of age. If phsweete discovers that personal information has been collected from a person under 21, that account will be immediately suspended, the personal information will be deleted, and any funds held in the account will be handled in accordance with PAGCOR guidelines.

11.2 If you are a parent or guardian and believe that your child has registered on the phsweete platform, please contact us immediately at [email protected] so that we can take appropriate action without delay.

12.1 phsweete primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data outside the Philippines — for example, to cloud infrastructure providers or international KYC verification services — phsweete will ensure that such transfers are made only to countries or organisations that provide an adequate level of data protection, or that appropriate safeguards are in place as required by RA 10173 and NPC regulations.

12.2 phsweete will not transfer your personal data to a foreign country or organisation without first ensuring that the transfer complies with the requirements of RA 10173, including obtaining your consent where required or establishing another lawful transfer mechanism.

12.3 Where personal data is transferred to a third-party processor located outside the Philippines, phsweete will enter into a data processing agreement with that processor that imposes data protection obligations equivalent to those required under Philippine law.

13.1 phsweete reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on the phsweete platform at least seven (7) days before the changes take effect.

13.2 The current version of this Privacy Policy is always available at phsweete.club/privacy-policy. The effective date at the top of this page indicates when the current version came into force. We encourage you to review this Policy periodically to stay informed about how phsweete protects your personal information.

13.3 Your continued use of the phsweete platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with any changes, you may close your account in accordance with the phsweete Terms and Conditions.

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or phsweete's handling of your personal information, please contact our Data Protection Officer using the details below. Our DPO is responsible for overseeing phsweete's compliance with RA 10173 and is your primary point of contact for all data privacy matters.

14.2 If you are not satisfied with phsweete's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory authority responsible for enforcing RA 10173 and protecting the data privacy rights of Filipino citizens.

14.3 phsweete takes all privacy complaints seriously and will work in good faith to resolve any concerns you raise. We are committed to maintaining the trust of our Filipino players by handling personal information with the care, transparency, and respect it deserves.