phbe Privacy Policy

1 Who We Are

1.1 phbe is an online casino and gaming platform operating under PAGCOR oversight, serving Filipino players across the Philippines including Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond.

1.2 For the purposes of the Data Privacy Act of 2012, phbe acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes about registered players and website visitors.

1.3 phbe has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO using the details provided in Section 13 of this Policy.

2 Personal Data We Collect

2.1 phbe collects the following categories of personal data about you:

2.2 phbe does not collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly required for identity verification and regulatory compliance purposes.

3 How We Collect Your Data

3.1 phbe collects personal data through the following means:

• Direct interactions: Information you provide when registering for a phbe account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical data collected automatically when you access the phbe Platform, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 7).
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment data from GCash, PayMaya/Maya, and banking partners as part of transaction processing.

3.2 phbe will always inform you at the point of collection what data is being collected and for what purpose, consistent with the transparency requirements of the Data Privacy Act of 2012.

4 How We Use Your Personal Data

4.1 phbe uses your personal data for the following purposes:

• To create, manage, and maintain your phbe account;
• To verify your identity and age (21+ requirement) in compliance with PAGCOR regulations;
• To process deposits and withdrawals via GCash, PayMaya/Maya, bank transfer, and debit card;
• To deliver the games, live dealer services, and other features of the phbe Platform;
• To administer bonuses, promotions, and loyalty programs;
• To provide customer support and resolve disputes;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity;
• To comply with our legal and regulatory obligations under Philippine law, including reporting to PAGCOR and the Anti-Money Laundering Council (AMLC);
• To monitor responsible gaming indicators and apply responsible gaming tools where appropriate;
• To send you service-related communications, including account notifications and security alerts;
• To send you marketing communications about phbe promotions and offers, where you have consented to receive them;
• To analyze Platform usage and improve our services.

4.2 phbe will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5 Legal Basis for Processing

5.1 phbe processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform the contract between you and phbe, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with Philippine laws and regulations, including PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and National Privacy Commission directives.
• Legitimate interests: Processing necessary for phbe's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing and Disclosure

6.1 phbe does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phbe may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

6.2 Service Providers and Processors

phbe engages trusted third-party service providers who process personal data on phbe's behalf and under phbe's instructions. These include:

• KYC and identity verification providers;
• Payment processing partners (GCash, PayMaya/Maya, banking partners);
• Cloud hosting and data storage providers;
• Customer support platform providers;
• Fraud detection and cybersecurity service providers;
• Game software providers and content licensors.

All service providers are contractually bound to process your data only as instructed by phbe and to maintain appropriate security standards.

6.3 Regulatory and Law Enforcement Authorities

phbe is required by Philippine law to disclose certain personal data to regulatory and law enforcement authorities, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent government agencies, where required by applicable law or a valid legal order.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of phbe's business, your personal data may be transferred to the acquiring entity as part of that transaction. phbe will notify you of any such transfer and the privacy practices of the acquiring entity before your data is transferred.

6.5 phbe does not transfer your personal data outside the Philippines except where necessary to deliver the Platform services and where appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012.

7 Cookies and Tracking Technologies

7.1 phbe uses cookies and similar tracking technologies on the phbe Platform to enhance your experience, maintain your session, and analyze Platform usage. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your phbe account and security cookies that help detect fraudulent activity. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymized data about how players use the phbe Platform, which pages are visited most frequently, and where errors occur. This data helps phbe improve the Platform experience.
• Marketing cookies: Used to deliver relevant phbe promotions and offers. These are only set with your consent.

7.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phbe Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the Platform.

7.3 phbe does not use cookies to track your activity on third-party websites unrelated to the phbe Platform.

8 Data Retention

8.1 phbe retains your personal data for as long as your phbe account is active and for such additional periods as are required by applicable Philippine law and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AMLC requirements.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Gaming data: Retained for a minimum of three (3) years from the date of the gaming session, or longer if required for regulatory reporting or dispute resolution.
• Customer support communications: Retained for two (2) years from the date of the last interaction, or longer if the matter is subject to ongoing dispute or legal proceedings.
• Marketing consent records: Retained for the duration of your consent and for one (1) year after withdrawal of consent.

8.2 When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, phbe will securely delete or anonymize the data.

9 Data Security

9.1 phbe implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and phbe servers;
• Encryption of sensitive data at rest, including financial data and government ID information;
• Multi-factor authentication options for phbe account access;
• Strict role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Intrusion detection and prevention systems;
• Comprehensive employee data protection training and confidentiality obligations.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phbe will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

9.3 While phbe takes all reasonable steps to protect your personal data, no security system is completely impenetrable. You are responsible for maintaining the security of your phbe Login credentials and for notifying phbe immediately if you suspect unauthorized access to your account.

10 Your Data Subject Rights

10.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phbe:

• Right to be informed: The right to be told what personal data phbe collects about you and how it is used, as set out in this Policy.
• Right of access: The right to request a copy of the personal data phbe holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• 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 phbe'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 legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phbe has violated your data privacy rights.

10.2 To exercise any of the above rights, please contact phbe's Data Protection Officer using the contact details in Section 13. phbe will respond to all data subject requests within fifteen (15) business days of receipt, as required by the Data Privacy Act.

10.3 phbe may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties.

11 Children's Privacy and Age Restriction

11.1 phbe employs age verification procedures during the registration and KYC process to prevent underage access to the Platform. If phbe discovers that personal data has been collected from a person under the age of 21, phbe will immediately close the account and delete the associated personal data.

11.2 If you are a parent or guardian and believe that your child has registered on the phbe Platform, please contact phbe's support team immediately using the contact details in Section 13.

12 Updates to This Privacy Policy

12.1 phbe may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. The effective date at the top of this Policy will be updated whenever a material change is made.

12.2 Where changes are material, phbe will notify registered players by email or through an in-platform notification prior to the changes taking effect. Your continued use of the phbe Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms.

12.3 phbe encourages you to review this Privacy Policy periodically to stay informed about how your personal data is being protected.

13 Contact Us and Data Protection Officer

13.1 If you have any questions, concerns, or requests regarding this Privacy Policy or phbe's data processing practices, please contact our Data Protection Officer:

13.2 If you are not satisfied with phbe's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC can be reached through their official government channels.