phmalad Privacy Policy

1. Introduction

1.1 phmalad is committed to protecting the privacy and personal data of all players and visitors to the phmalad platform. This Privacy Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC).

1.2 This Privacy Policy applies to all personal data collected through the phmalad website, mobile platform, customer support channels, and any other services operated by phmalad. It should be read together with our Terms & Conditions, which are incorporated herein by reference.

1.3 phmalad acts as the personal information controller in respect of the personal data it collects from players and visitors. Our designated Data Protection Officer (DPO) oversees compliance with this Privacy Policy and applicable data protection law.

2. Personal Data We Collect

2.1 phmalad collects the following categories of personal data:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — players must be 21 or older);
• Nationality and country of residence;
• Registered email address and Philippine mobile number;
• Residential address (barangay, city/municipality, province).

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo ID (Philippine passport, driver's license, SSS ID, UMID, or PhilSys National ID);
• Proof of address documents (utility bills, bank statements);
• Selfie or liveness check images used for identity verification;
• Source of funds declarations where required by PAGCOR regulations.

2.3 Financial Data

• GCash or PayMaya account details (registered name and mobile number);
• Bank account details for BPI, BDO, or Metrobank transfers (account name and number);
• Transaction history including deposits, withdrawals, and bonus credits;
• Account balance information.

2.4 Gaming & Behavioral Data

• Game history, bet amounts, win/loss records, and session durations;
• Responsible gaming tool usage (deposit limits set, cooling-off periods activated, self-exclusion requests);
• Bonus and promotion participation history;
• Customer support interaction records.

2.5 Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Login timestamps and session activity logs;
• Cookie identifiers and platform usage analytics.

3. How We Collect Your Data

3.1 phmalad collects personal data 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 data collected automatically when you access the phmalad platform, including through cookies, log files, and analytics tools;
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment verification data from GCash, PayMaya, and banking partners.

3.2 phmalad does not collect personal data from social media platforms or purchase data from data brokers.

4. How We Use Your Personal Data

4.1 phmalad uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phmalad account, including verifying your identity and age;
• Service delivery: To process deposits and withdrawals, credit bonuses, and provide access to games and betting markets;
• Regulatory compliance: To comply with PAGCOR licensing requirements, Philippine anti-money laundering (AMLA) obligations, and NPC data protection requirements;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and unauthorized account access;
• Responsible gaming: To monitor gaming behavior for signs of problem gambling and to administer responsible gaming tools including deposit limits, cooling-off periods, and self-exclusion;
• Customer support: To respond to your inquiries, complaints, and support requests;
• Platform improvement: To analyze usage patterns and improve the performance, features, and user experience of the phmalad platform;
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided consent and subject to your right to opt out at any time.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you (i.e., to operate your account and provide gaming services);
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, 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 provided explicit consent.

6. Data Sharing & Disclosure

6.1 phmalad does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where required by law;
• KYC and identity verification providers: Third-party service providers that assist phmalad in verifying player identities and ages in compliance with PAGCOR requirements;
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and their respective processing partners, solely for the purpose of processing your deposits and withdrawals;
• Fraud prevention and AML screening providers: Third-party compliance service providers that assist phmalad in detecting and preventing money laundering and fraudulent activity;
• IT and platform service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on phmalad's behalf under strict data processing agreements;
• Legal and professional advisors: Lawyers, auditors, and other professional advisors where necessary for legal proceedings or compliance purposes.

6.2 All third-party service providers who process personal data on phmalad's behalf are required to implement appropriate technical and organizational security measures and to process data only in accordance with phmalad's instructions and applicable Philippine data protection law.

6.3 phmalad may disclose your personal data if required to do so by a court order, subpoena, or other legal process, or if phmalad believes in good faith that such disclosure is necessary to protect the rights, property, or safety of phmalad, its players, or the public.

7. Data Retention

7.1 phmalad retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements;
• Transaction and gaming records: Retained for a minimum of five (5) years from the date of each transaction, as required by AMLA regulations;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given.

7.2 Upon expiry of the applicable retention period, phmalad will securely delete or anonymize your personal data in accordance with NPC guidelines. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

8. Data Security

8.1 phmalad 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 transmitted between your device and phmalad's servers;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls ensuring that only authorized phmalad personnel can access personal data, and only to the extent necessary for their role;
• Regular security audits, vulnerability assessments, and penetration testing of the phmalad platform;
• Two-factor authentication (2FA) available to all players and mandatory for phmalad staff accessing internal systems;
• Secure data centers with physical access controls, redundant power, and disaster recovery capabilities.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phmalad will notify the NPC 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. Cookies & Tracking Technologies

9.1 phmalad uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device that help us recognize you, maintain your session, and understand how you use the platform.

9.2 phmalad uses the following categories of cookies:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymized data about how players use the platform, which pages are visited most, and where errors occur. This data helps phmalad improve platform performance and user experience.

9.3 phmalad does not use third-party advertising or tracking cookies. You will not be tracked across other websites for advertising purposes.

9.4 You can manage or disable non-essential cookies through your browser settings. Please note that disabling functional cookies may affect your experience on the phmalad platform, including the loss of saved preferences.

10. Your Data Subject Rights

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phmalad:

• Right to be informed: The right to know what personal data phmalad collects about you and how it is used — as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data phmalad 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, subject to phmalad's legal and regulatory retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• 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 (NPC) if you believe phmalad has violated your data privacy rights.

10.2 To exercise any of the above rights, please contact phmalad's Data Protection Officer using the contact details provided in Section 14 of this Privacy Policy. phmalad will respond to all data subject requests within thirty (30) calendar days of receipt, in accordance with NPC guidelines.

10.3 phmalad 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

11.1 The phmalad platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR regulations. phmalad does not knowingly collect personal data from individuals under the age of 21.

11.2 If phmalad discovers that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all data will be securely deleted, and any deposited funds will be returned to the payment source after deducting amounts already wagered, in accordance with our Terms & Conditions.

11.3 If you are a parent or guardian and believe that your child has registered on the phmalad platform, please contact our support team immediately so that we can take appropriate action.

12. Third-Party Links

12.1 The phmalad platform may contain links to third-party websites or services, such as payment provider portals. phmalad is not responsible for the privacy practices of these third-party sites and this Privacy Policy does not apply to them.

12.2 We encourage you to review the privacy policies of any third-party sites you visit. phmalad has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party websites or services.

13. Changes to This Privacy Policy

13.1 phmalad 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. The date of the most recent revision is displayed at the top of this page.

13.2 Where changes are material, phmalad will notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the phmalad platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

13.3 If you do not agree to the revised Privacy Policy, you must cease using the phmalad platform and may request account closure by contacting our support team.

14. Contact & Data Protection Officer

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact phmalad's Data Protection Officer through the following channels:

• Email: [email protected] — please include "Data Privacy Request" in the subject line;
• Live Chat: Available 24/7 directly on the phmalad platform — for general privacy inquiries;
• Response time: phmalad will acknowledge all privacy-related inquiries within three (3) business days and provide a full response within thirty (30) calendar days.

14.2 If you are not satisfied with phmalad's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.