phpun Privacy Policy — How We Handle Your Data

This Privacy Policy ("Policy") describes how phpun ("we," "us," "our") collects, uses, stores, discloses, and otherwise processes personal data relating to individuals ("you," "Player," "User") who access or use the phpun platform available at phpun.cam and all associated services.

This Policy applies to all phpun players and visitors regardless of their location, and is specifically designed with Filipino players in mind, reflecting the applicable data protection and privacy standards relevant to online gaming operations serving the Philippine market.

By registering a phpun account or accessing any service on the platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. This Policy should be read alongside the phpun Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

phpun is the data controller responsible for personal data collected through the phpun platform. As data controller, phpun determines the purposes for which and the means by which your personal data is processed. All data protection enquiries, requests to exercise your rights, and privacy-related complaints should be directed to phpun through the contact details provided in Section 13 of this Policy.

Where phpun engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification services, or customer support platforms), those parties act as data processors operating under contractual data processing agreements that require them to maintain appropriate confidentiality and security standards consistent with this Policy.

phpun collects personal data through several channels. The categories of data collected and the circumstances in which each arises are described below.

3.1 Registration Data

When you create a phpun account, we collect the information you provide during the registration process, which includes:

• Full legal name as it appears on your government-issued identification
• Date of birth (used to verify the mandatory 21+ age requirement)
• Email address and mobile number
• Residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati)
• Username and encrypted password

3.2 Identity Verification (KYC) Data

To comply with applicable regulatory requirements and to process withdrawals, phpun is required to verify your identity. KYC documentation may include:

• Government-issued Philippine identification — such as a PhilSys ID, UMID, driver's licence, or passport
• Proof of current residential address (utility bill, bank statement, or similar document dated within 90 days)
• Payment method verification documentation (e.g., screenshot of registered GCash or PayMaya account)
• Source of funds documentation where required by regulatory standards or risk assessment

3.3 Transaction & Gaming Data

The phpun platform automatically records transaction and gaming activity data in connection with your Account, including deposit and withdrawal records, game participation history, wagering records, bonus usage, and win/loss data. This data is used for account management, regulatory reporting, responsible gaming monitoring, and dispute resolution purposes.

3.4 Technical & Device Data

When you access the phpun platform, our systems automatically collect certain technical information, including your IP address, browser type and version, device type, operating system, and session data such as pages visited, time spent, and navigation patterns. This data is used for security monitoring, fraud detection, platform optimization, and regulatory compliance purposes.

3.5 Communications Data

When you contact phpun support via live chat or email, we retain records of those communications for quality assurance, training, and dispute resolution purposes. Communications records are treated as personal data and handled in accordance with this Policy.

phpun uses your personal data only for clearly defined, legitimate purposes. The following table sets out the primary uses of personal data collected on the phpun platform:

phpun does not use your personal data for purposes that are incompatible with those listed above. Should we wish to use your data for a materially different purpose, we will seek your consent or otherwise ensure that such use is lawfully permitted before proceeding.

phpun processes your personal data on the following legal bases:

• Contract Performance: Processing necessary to fulfil our contractual obligations to you under the phpun Terms & Conditions — including account management, game provision, payment processing, and customer support.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML requirements, regulatory reporting obligations, and responsible gaming mandates.
• Legitimate Interests: Processing carried out for phpun's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, security monitoring, and platform improvement.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily applicable to direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

phpun does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the following circumstances and only to the extent necessary for the stated purpose:

6.1 Service Providers & Data Processors

phpun engages trusted third-party service providers who process data on our behalf under binding contractual data processing agreements. These include:

• Payment processors — GCash, PayMaya (Maya), card payment gateways, and Philippine banking partners (BPI, BDO, Metrobank) — for transaction processing
• KYC/AML verification service providers for identity and age verification
• Customer support platform providers who facilitate our live chat services
• Cloud infrastructure and hosting providers for secure data storage
• Game software providers where game-level data logging is required for RNG certification or audit purposes

6.2 Regulatory & Legal Disclosure

phpun may be required by law, regulation, court order, or regulatory directive to disclose personal data to competent authorities, including gaming regulators and law enforcement agencies. Such disclosures will be made only to the extent required and will be carried out in compliance with applicable legal procedures.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a material portion of phpun's business assets, personal data held by phpun may be transferred to the acquiring entity as part of that transaction. Affected players will be notified of any such transfer and the data protection terms applicable to them will be maintained.

The phpun platform uses cookies and similar tracking technologies to operate effectively, maintain session security, and improve player experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function — including session management, login authentication, and security tokens. These cookies cannot be disabled without breaking core platform functionality.
• Performance & Analytics Cookies: Used to understand how players interact with the phpun platform — which pages are visited most frequently, how long sessions last, and where players encounter difficulties. This data is collected in aggregate and used to guide platform improvements.
• Functional Cookies: Remember your preferences such as language settings, game view preferences, and previously selected deposit methods, providing a more personalized and convenient phpun experience.
• Security Cookies: Support fraud detection and login monitoring functions, helping phpun identify and block suspicious access attempts and protect your account from unauthorized access.

You may configure your browser settings to block or delete cookies; however, please note that disabling strictly necessary cookies will impair the functionality of the phpun platform, including your ability to log in and play games.

phpun retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy applicable legal, regulatory, accounting, and reporting requirements. The following general retention guidelines apply:

• Active Account Data: Retained for the duration of your phpun account registration and for a period thereafter as required by applicable regulations — typically a minimum of five (5) years following account closure under standard AML/KYC retention requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with applicable financial record-keeping obligations.
• KYC Documents: Retained for the duration required by applicable Philippine regulatory standards from the date of collection or date of account closure, whichever is later.
• Support Communications: Retained for up to three (3) years from the date of the interaction, unless the communication relates to an active dispute or regulatory matter in which case retention continues until full resolution.
• Technical & Session Logs: Retained for up to twelve (12) months from collection unless required for an ongoing security investigation or regulatory matter.

Upon the expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymized. Anonymized data may be retained beyond these periods for aggregated statistical analysis without restriction, as it no longer constitutes personal data capable of identifying an individual.

As an individual whose personal data is processed by phpun, you hold the following rights with respect to your personal information. You may exercise any of these rights by contacting phpun via the contact details in Section 13:

phpun will respond to valid data rights requests within thirty (30) calendar days of receipt. Where requests are complex or numerous, this period may be extended by up to a further sixty (60) days with prior notice. phpun reserves the right to verify your identity before processing any data rights request to protect against unauthorized access to your personal information by third parties.

phpun implements technical and organizational security measures proportionate to the risk presented by the data we hold and the processing activities we conduct. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between player devices and phpun servers
• Encryption of sensitive data fields — including passwords and payment information — at rest in phpun databases
• Role-based access controls limiting internal access to personal data to authorized personnel with a documented operational need
• Real-time intrusion detection and automated anomaly monitoring systems
• Regular third-party security audits and penetration testing of the phpun platform
• Multi-factor authentication requirements for all internal administrative access to player data systems
• Documented incident response procedures for data breaches, including notification protocols consistent with applicable regulatory requirements

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. phpun will notify affected players promptly in the event of a data breach that is likely to result in a risk to their rights and freedoms, in accordance with applicable notification obligations.

The phpun platform is strictly restricted to individuals aged 21 years and above. phpun does not knowingly collect personal data from individuals under the age of 21, nor does it permit such individuals to register accounts or access any real-money gaming service.

phpun implements age verification measures at the point of registration and during KYC procedures to enforce this restriction. If phpun becomes aware that personal data has been collected from an individual under 21 years of age, such data will be deleted promptly and the associated account closed. Any person who becomes aware that a minor has accessed the phpun platform is encouraged to contact phpun support immediately.

phpun reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform operations. The current effective version of this Policy will always be available on this page, with the effective date and version number clearly indicated.

Where changes are material — meaning they significantly alter how we process your personal data or affect your rights as a data subject — phpun will provide advance notice via your registered email address at least fourteen (14) days prior to the updated Policy taking effect. For minor or administrative changes, the updated Policy will be posted to this page with an updated effective date.

Continued use of the phpun platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with a revised Policy, you should cease using the platform and may request account closure by contacting phpun support.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phpun, please contact our Data Protection team through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line for data rights requests
• Live Chat: Available 24 hours a day, 7 days a week through the phpun platform — our Filipino support agents can direct privacy enquiries to the appropriate team
• Response Times: Privacy enquiries are acknowledged within 5 business days. Formal data rights requests are responded to within 30 calendar days as required by applicable standards

phpun takes all privacy enquiries and complaints seriously. If you are not satisfied with our handling of a privacy matter, you may also seek guidance from the relevant data protection or gaming regulatory authority applicable to your jurisdiction.