phlagi Privacy Policy

1. Introduction and Scope

This Privacy Policy describes how phlagi ("we," "us," "our," or "phlagi") collects, uses, discloses, stores, and protects personal information obtained from users ("you," "your," or "User") of the phlagi online gaming platform (the "Platform"). This Privacy Policy applies to all services, products, features, and content offered through the phlagi website and mobile applications.

phlagi is committed to protecting your privacy and complying with all applicable data protection laws in the Republic of the Philippines, including Republic Act No. 10173, also known as the Data Privacy Act of 2012 (the "DPA"), and its implementing rules and regulations issued by the National Privacy Commission (the "NPC"). By registering for, accessing, or using the phlagi Platform, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy.

This Privacy Policy should be read in conjunction with phlagi's Terms and Conditions, which govern your use of the Platform. Where any conflict exists between this Privacy Policy and the Terms and Conditions with respect to data processing matters, the provisions of this Privacy Policy shall prevail.

2. Personal Information We Collect

phlagi collects and processes several categories of personal information necessary to provide gaming services, comply with regulatory obligations under PAGCOR oversight, and maintain the security and integrity of the Platform.

2.1 Information You Provide Directly

When you register for a phlagi account, you voluntarily provide the following personal information:

• Identity Information: Full legal name, date of birth, gender, and nationality
• Contact Information: Email address, Philippine mobile phone number, and residential address within the Philippines
• Account Credentials: Username and encrypted password
• Financial Information: Bank account details, e-wallet account identifiers (GCash, Maya), cryptocurrency wallet addresses, and transaction history
• Verification Documents: Government-issued identification documents (Philippine passport, driver's license, UMID, PRC ID, national ID), proof of address documents (utility bills, bank statements), and selfie photographs holding identification
• Customer Support Communications: Information you provide when contacting phlagi support, including chat transcripts, email correspondence, and complaint details

2.2 Information Collected Automatically

When you access and use the phlagi Platform, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, device identifiers (IMEI, MAC address), and mobile carrier information
• Connection Data: IP address, geolocation data (to verify Philippine jurisdiction), time zone setting, and access times
• Usage Data: Pages viewed, features used, clickstream data, games played, bet history, win/loss records, session duration, and navigation paths through the Platform
• Cookie Data: Information stored in cookies and similar tracking technologies as described in Section 8 of this Privacy Policy

2.3 Information from Third-Party Sources

phlagi may receive personal information from third-party sources to verify your identity, prevent fraud, and comply with legal obligations:

• Payment Processors: Transaction verification data from GCash, Maya, banks, and cryptocurrency networks
• Identity Verification Services: Verification results from third-party KYC service providers used to authenticate government-issued documents
• Fraud Prevention Services: Risk assessment data from specialized anti-fraud and anti-money laundering service providers
• Game Providers: Gameplay data, bet records, and win/loss information from third-party game studio partners whose content is hosted on the phlagi Platform

3. How We Use Your Personal Information

phlagi processes your personal information for specific, legitimate purposes in accordance with the Data Privacy Act. The legal bases for our processing activities include: performance of our contract with you, compliance with legal obligations, protection of vital interests, and legitimate business interests.

3.1 Account Management and Service Delivery

We use your personal information to create and manage your phlagi account, process your deposits and withdrawals, facilitate gameplay, calculate winnings and losses, apply bonuses and promotions, maintain accurate transaction records, and provide customer support services. This processing is necessary for the performance of the contractual relationship between you and phlagi as established in the Terms and Conditions.

3.2 Identity Verification and KYC Compliance

We process identification documents, proof of address, and biometric selfie data to verify your identity, confirm you meet the minimum age requirement of 21 years, prevent duplicate account creation, and comply with PAGCOR's Know Your Customer requirements. This processing is necessary to comply with legal obligations imposed by Philippine gaming regulations and anti-money laundering laws.

3.3 Fraud Prevention and Platform Security

We analyze IP addresses, device identifiers, betting patterns, and account behavior to detect and prevent fraudulent activity, identify collusion and bonus abuse, protect against unauthorized account access, prevent money laundering and terrorist financing, and maintain the integrity of games and betting markets. This processing is necessary for our legitimate interests in operating a secure and trustworthy gaming platform.

3.4 Regulatory Compliance and Reporting

We retain and process personal information as required to comply with PAGCOR reporting obligations, respond to lawful requests from law enforcement and regulatory authorities, maintain records as required by Philippine gaming law, and submit suspicious activity reports to the Anti-Money Laundering Council (AMLC) where required. This processing is necessary to comply with legal obligations.

3.5 Marketing and Communications

With your consent, we may use your contact information to send promotional emails about new games, bonuses, and special offers, deliver SMS notifications about account activity and promotions, provide personalized game recommendations based on your gameplay history, and inform you of changes to phlagi services or policies. You may withdraw your consent to marketing communications at any time by clicking the unsubscribe link in emails or adjusting your account preferences.

3.6 Analytics and Platform Improvement

We analyze aggregated and anonymized usage data to understand how Users interact with the Platform, identify popular games and features, optimize user experience and navigation, diagnose technical issues and improve performance, and develop new products and services. This processing is based on our legitimate interest in continuously improving the phlagi Platform.

4. Legal Basis for Processing Under the Data Privacy Act

Under the Philippine Data Privacy Act, phlagi must have a lawful basis for processing your personal information. We rely on the following legal grounds:

4.1 Consent

Where you have freely given specific, informed, and unambiguous consent for us to process your personal information for particular purposes, such as receiving marketing communications or storing certain optional data.

4.2 Contract Performance

Where processing is necessary to perform our contractual obligations to you under the phlagi Terms and Conditions, including account creation, gameplay facilitation, payment processing, and customer support.

4.3 Legal Obligation

Where processing is necessary to comply with legal obligations imposed on phlagi by Philippine law, including PAGCOR regulations, anti-money laundering requirements, tax laws, and other applicable legislation.

4.4 Legitimate Interests

Where processing is necessary for legitimate interests pursued by phlagi, provided such interests are not overridden by your fundamental rights and freedoms. Legitimate interests include fraud prevention, platform security, business analytics, and defending legal claims.

5. How We Share Your Personal Information

phlagi does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may disclose your personal information to certain categories of recipients in limited circumstances as described below.

5.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who perform services on phlagi's behalf under strict data protection agreements:

• Payment Processors: GCash, Maya, banks, and cryptocurrency payment gateways that process your deposits and withdrawals
• Identity Verification Providers: Third-party KYC services that authenticate your government-issued documents
• Game Content Providers: Licensed game studios whose slots, live dealer games, and other content are hosted on the phlagi Platform
• Cloud Infrastructure Providers: Hosting and data storage providers that maintain the technical infrastructure supporting the Platform
• Customer Support Tools: Live chat, email management, and ticketing system providers used to deliver customer support
• Analytics and Fraud Prevention Services: Specialized providers that help us analyze usage patterns, detect fraudulent activity, and maintain platform security

All service providers are contractually obligated to process your personal information only as instructed by phlagi, to implement appropriate security measures, and to comply with applicable data protection laws.

5.2 Regulatory Authorities and Law Enforcement

We may disclose personal information to Philippine regulatory authorities and law enforcement agencies when required by law or when we believe disclosure is necessary to:

• Comply with PAGCOR audits, investigations, and reporting requirements
• Respond to lawful court orders, subpoenas, or other legal processes
• Submit suspicious activity reports to the Anti-Money Laundering Council (AMLC)
• Cooperate with National Privacy Commission investigations
• Assist law enforcement investigations into suspected criminal activity
• Comply with tax reporting obligations to the Bureau of Internal Revenue (BIR)

5.3 Business Transfers

In the event phlagi undergoes a merger, acquisition, corporate restructuring, bankruptcy, or sale of all or a portion of its assets, your personal information may be transferred to the acquiring entity. You will be notified via email or prominent notice on the Platform of any change in ownership or control of your personal information.

5.4 With Your Consent

We may share your personal information with third parties for purposes not described in this Privacy Policy when we have obtained your explicit consent to do so.

6. International Data Transfers

phlagi primarily stores and processes personal information within the Philippines. However, some of our service providers, including cloud infrastructure operators and game content providers, may be located outside the Philippines. When we transfer personal information internationally, we ensure appropriate safeguards are in place in accordance with the Data Privacy Act and NPC Circular No. 16-03 on Security of Personal Data in Government.

International transfers are conducted using one or more of the following mechanisms: contracts incorporating Standard Contractual Clauses approved by the National Privacy Commission, transfers to countries deemed by the NPC to provide adequate data protection, explicit consent obtained from you for specific transfers, or transfers necessary for the performance of our contract with you.

7. Data Security Measures

phlagi implements comprehensive technical and organizational security measures designed to protect your personal information against unauthorized access, accidental loss, destruction, or damage. Our security measures include:

• Encryption: All data transmitted between your device and phlagi servers is encrypted using industry-standard SSL/TLS protocols. Sensitive personal information stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Personal information is accessible only to authorized phlagi personnel who require access to perform their job functions. All personnel with access to personal data are bound by confidentiality obligations.
• Authentication: Account access is protected by secure password requirements and optional two-factor authentication.
• Monitoring and Auditing: We maintain activity logs and conduct regular security audits to detect and respond to potential security incidents.
• Third-Party Security: All service providers with access to personal information are required to maintain security standards consistent with industry best practices and applicable law.
• Incident Response: phlagi maintains an incident response plan to rapidly detect, contain, and remediate security breaches. In the event of a personal data breach affecting your rights and freedoms, we will notify you and the National Privacy Commission within seventy-two (72) hours as required by the Data Privacy Act.

While we employ robust security measures, no internet-based service can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify phlagi of any unauthorized account access.

8. Cookies and Tracking Technologies

The phlagi Platform uses cookies and similar tracking technologies to enhance user experience, analyze platform usage, and deliver personalized content.

8.1 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function, including session management, authentication, and security features. These cookies cannot be disabled.
• Performance Cookies: Collect anonymous information about how Users interact with the Platform, which pages are visited most frequently, and where error messages are generated. This data helps us improve platform performance.
• Functionality Cookies: Remember your preferences and settings (language selecti on, display preferences) to provide a more personalized experience.
• Analytics Cookies: Used to understand aggregate usage patterns, track the effectiveness of promotions, and measure Platform performance metrics.

8.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, and set preferences for specific websites. Please note that disabling essential cookies may prevent you from accessing certain features of the phlagi Platform, including your account and payment functions. Detailed instructions for managing cookies are available in your browser's help documentation.

9. Data Retention

phlagi retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods are as follows:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and anti-money laundering laws.
• KYC and Identity Documents: Retained for a minimum of five (5) years after the end of the business relationship, in compliance with the Anti-Money Laundering Act (Republic Act No. 9160, as amended).
• Transaction Records: Retained for a minimum of five (5) years as required by PAGCOR and the AMLC.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Data: Retained until you withdraw consent or for a maximum of three (3) years from the date of collection, whichever occurs first.
• Technical Logs: Retained for a maximum of twelve (12) months unless required for a longer period in connection with a security investigation or legal proceeding.

Upon expiry of the applicable retention period, personal information is securely deleted or anonymized so that it can no longer be associated with you.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act, you have the following rights with respect to your personal information held by phlagi:

10.1 Right to Be Informed

You have the right to be informed about the collection and processing of your personal information, including the purposes for which it is processed, the identity of the data controller, and the recipients or categories of recipients of your data. This Privacy Policy serves as the primary vehicle through which phlagi exercises transparency regarding its data processing activities.

10.2 Right to Access

You have the right to request a copy of the personal information phlagi holds about you, including information about how it is being processed, where it was sourced, and the recipients to whom it has been disclosed. Requests for access may be submitted to phlagi's Data Protection Officer at the contact details provided in Section 14 of this Privacy Policy. phlagi will respond to verified access requests within thirty (30) calendar days.

10.3 Right to Rectification

You have the right to request correction of any inaccurate, outdated, or incomplete personal information held by phlagi. Rectification requests must be submitted with supporting documentation confirming the correct information. phlagi will process rectification requests within thirty (30) calendar days of receiving adequate supporting documentation.

10.4 Right to Erasure

You have the right to request the deletion or removal of your personal information where: the information is no longer necessary for the purpose for which it was collected; you withdraw consent and no other legal basis for processing exists; the information has been unlawfully processed; or deletion is required to comply with a legal obligation. Please note that this right is subject to limitations where retention is required to comply with PAGCOR regulations, anti-money laundering laws, or other legal obligations.

10.5 Right to Object

You have the right to object to the processing of your personal information on grounds of legitimate interest or for direct marketing purposes. Where you object to marketing processing, phlagi will cease processing your information for such purposes immediately. Where you object to processing based on legitimate interests, phlagi will review the objection and cease processing unless compelling legitimate grounds that override your interests are established.

10.6 Right to Data Portability

You have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible. This right applies to information you have provided to phlagi and that is processed on the basis of your consent or in performance of our contract with you.

10.7 Right to Lodge a Complaint

If you believe phlagi has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to file a complaint with the NPC is available on the NPC's official website. phlagi encourages you to first contact our Data Protection Officer to attempt resolution before escalating to the NPC.

11. Children's Privacy

The phlagi Platform is strictly intended for individuals aged 21 years and above in compliance with Philippine gaming laws and PAGCOR regulations. phlagi does not knowingly collect personal information from individuals under the age of 21. If we become aware that personal information has been collected from an underage individual, we will immediately close the associated account, forfeit any associated balances in accordance with our Terms and Conditions, delete the personal information collected, and report the incident to relevant regulatory authorities where required.

Parents and guardians who believe their child may have accessed or registered on the phlagi Platform should contact our Data Protection Officer immediately using the contact details in Section 14. We take the protection of children's privacy and safety with the utmost seriousness.

12. Third-Party Links and Services

The phlagi Platform may contain links to third-party websites, payment gateways, or services. This Privacy Policy applies solely to the phlagi Platform and does not cover the privacy practices of third-party websites or services. When you are redirected to a third-party platform, such as your GCash or Maya account for payment processing, that third party's own privacy policy will govern the collection and use of your personal information. phlagi encourages you to review the privacy policies of any third-party services you access through or in connection with the phlagi Platform.

13. Changes to This Privacy Policy

phlagi reserves the right to update and amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Privacy Policy, we will notify you by:

• Posting a prominent notice on the phlagi Platform for at least thirty (30) days before the changes take effect
• Sending a notification to your registered email address
• Updating the "Last Updated" date at the top of this Privacy Policy

Your continued use of the phlagi Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated Privacy Policy, you must discontinue use of the Platform and may request account closure by contacting phlagi customer support.

14. Contact Information and Data Protection Officer

For any questions, concerns, requests to exercise your data privacy rights, or complaints regarding this Privacy Policy or phlagi's data processing activities, please contact our Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly on the phlagi Platform
• Support Hours: 24 hours a day, 7 days a week, including Philippine public holidays

phlagi's Data Protection Officer will acknowledge receipt of all data privacy requests within seventy-two (72) hours and will endeavor to resolve all requests within thirty (30) calendar days. For complex requests that require additional time, phlagi will notify you of the extended timeline and the reasons for the extension.

If you are not satisfied with phlagi's response to your data privacy concern, you may escalate your complaint to the National Privacy Commission of the Philippines.