Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how phgreat ("phgreat," "we," "us," or "our") collects, uses, stores, and discloses personal information about individuals ("you" or "Player") who access or use the phgreat website at phgreat.one and all associated services (collectively, the "Platform").

phgreat is committed to protecting the privacy and security of your personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its implementing rules and regulations. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2. Personal Data We Collect

phgreat collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (to verify you are 21 years of age or older);
• Nationality and country of residence;
• Email address and mobile number;
• Username and encrypted password.

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., PhilSys National ID, Philippine Passport, LTO Driver's License, SSS ID, UMID);
• Proof of address documents where required;
• Source of funds documentation for high-value transactions.

2.3 Financial Data

• GCash or Maya account reference (masked);
• Bank account details for withdrawal processing (masked);
• Transaction history, deposit and withdrawal records;
• Wallet balance and bonus balance information.

2.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features used;
• Game history, wagering activity, and betting patterns;
• Login timestamps and access logs.

2.5 Communications Data

• Records of live chat, email, and support ticket interactions;
• Survey responses and feedback submissions;
• Marketing communication preferences.

3. How We Use Your Personal Data

phgreat uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your phgreat account, including verifying your identity and age;
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver bonuses and promotions;
• Legal Compliance: To fulfill our obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and the Data Privacy Act of 2012, including KYC verification and transaction monitoring;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and unauthorized account access;
• Responsible Gaming: To monitor gaming behavior for signs of problem gambling and to administer self-exclusion, deposit limits, and other responsible gaming tools;
• Customer Support: To respond to your enquiries, resolve disputes, and improve our support services;
• Platform Improvement: To analyze usage patterns, conduct A/B testing, and improve the functionality and user experience of the phgreat Platform;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications.

phgreat will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

4. Legal Basis for Processing

phgreat processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide the phgreat gaming service);
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations and PAGCOR licensing requirements;
• Legitimate Interests: Processing is necessary for phgreat's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent, which you may withdraw at any time.

5. Sharing Your Personal Data

phgreat does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

5.1 Service Providers

Third-party vendors who assist phgreat in operating the Platform, including payment processors (GCash, Maya, Philippine banks), identity verification providers, cloud hosting services, and customer support platforms. All service providers are contractually bound to process your data only on phgreat's instructions and in accordance with applicable data protection law.

5.2 Regulatory & Law Enforcement Authorities

phgreat may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities where required by law, court order, or regulatory directive.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of phgreat's assets, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

6. Cookies & Tracking Technologies

phgreat uses cookies and similar tracking technologies to operate the Platform and improve your experience. The types of cookies we use are:

• Essential Cookies: Required for the Platform to function, including session management, login authentication, and security features. These cannot be disabled without affecting Platform functionality;
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping us identify areas for improvement;
• Preference Cookies: Used to remember your settings and preferences, such as language and display options.

phgreat does not use third-party advertising or retargeting cookies. You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling essential cookies may impair your ability to use the Platform.

7. Data Retention

phgreat retains your personal data for as long as your account is active and for a period thereafter as required by applicable Philippine law. Specifically:

• Account and KYC data is retained for a minimum of five (5) years following account closure, in compliance with AML regulations;
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Support and communications records are retained for three (3) years from the date of the interaction;
• Technical and usage logs are retained for twelve (12) months on a rolling basis.

Upon expiry of the applicable retention period, phgreat will securely delete or anonymize your personal data in accordance with its data disposal procedures.

8. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phgreat:

• Right to be Informed: You have the right to know what personal data phgreat collects and how it is processed;
• Right of Access: You may request a copy of the personal data phgreat holds about you;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time;
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact phgreat's Data Protection Officer via live chat or email at [email protected]. phgreat will respond to all verified requests within fifteen (15) business days.

9. Security Measures

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

• 256-bit SSL/TLS encryption for all data in transit;
• Encryption of sensitive data at rest, including financial records and KYC documents;
• Role-based access controls limiting data access to authorized personnel only;
• Regular penetration testing and vulnerability assessments;
• Intrusion detection and real-time security monitoring;
• Staff training on data protection and information security practices.

While phgreat takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phgreat will notify you and the National Privacy Commission in accordance with applicable law.

10. Children's Privacy

The phgreat Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. phgreat does not knowingly collect personal data from individuals under the age of 21.

If phgreat becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all funds will be frozen pending investigation, and the personal data will be deleted in accordance with applicable law. If you believe a minor has registered on the phgreat Platform, please contact us immediately at [email protected].

11. Changes to This Policy

phgreat reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, phgreat will provide reasonable advance notice via email or a prominent notice on the Platform.

The date of the most recent revision is indicated at the top of this Policy. Your continued use of the phgreat Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically.

12. Contact Our Data Protection Officer

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

• Live Chat: Available 24/7 on the phgreat Platform
• Privacy Enquiries: [email protected]
• General Support: [email protected]
• Office Hours (Manila): 8:00 AM – 12:00 MN, Philippine Standard Time (PHT)

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with phgreat's response to your data protection concern.