pphsky Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") is issued by pphsky ("pphsky," "the Platform," "We," "Us," "Our") and applies to all personal data collected, processed, stored, or transmitted in connection with your use of pphsky.cam and all associated services, features, games, promotions, and communications (collectively, the "Services").

This Policy should be read together with pphsky's Terms and Conditions and Responsible Gaming Policy, all of which are published at pphsky.cam. By registering an account, making a deposit, or otherwise using any component of the Services, you acknowledge that you have read this Policy and that you consent to the collection and processing of your personal data as described herein.

pphsky is committed to protecting the privacy and security of all players using the platform. We process personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission ("NPC") of the Philippines.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information is pphsky, operating the online platform accessible at pphsky.cam.

pphsky has appointed a Data Protection Officer ("DPO") who is responsible for overseeing the platform's data protection practices, ensuring compliance with the DPA and NPC issuances, and serving as the primary point of contact for data subjects exercising their rights under applicable law.

If you have any questions, concerns, or requests regarding this Policy or the processing of your personal data, you may contact the pphsky Data Protection Officer at:

pphsky will acknowledge all data privacy requests within two (2) business days and will aim to resolve substantive requests within the timeframes prescribed by the NPC under its applicable circulars.

3. Data We Collect

pphsky collects personal data that is necessary to provide the Services, comply with regulatory obligations, and maintain a safe and fair gaming environment. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (collected to verify the 21+ age requirement);
• Residential address (province, city, barangay, postal code);
• Email address and mobile number;
• Username and encrypted password;
• Nationality and preferred language.

3.2 Identity Verification (KYC) Data

• Scanned or photographed copies of government-issued identification documents (Philippine National ID, passport, driver's license, SSS/GSIS ID, or equivalent);
• Proof of address documents (utility bills, bank statements, barangay clearance);
• Live selfie photographs or video verification clips submitted during the Know Your Customer (KYC) process.

3.3 Financial & Transaction Data

• GCash account number and registered mobile number (collected for deposit and withdrawal processing);
• Maya, BPI, BDO, Metrobank, and other linked payment account reference information;
• Deposit amounts, timestamps, and payment method references;
• Withdrawal requests, amounts, processing status, and disbursement records;
• Wagering history, game session records, and win/loss data.

3.4 Technical & Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, browser type and version;
• Mobile device identifiers (where applicable);
• Session logs, page interaction data, and clickstream data;
• Cookie identifiers and similar tracking technologies (see Section 7).

3.5 Communications Data

• Live chat transcripts between you and pphsky support agents;
• Email correspondence sent to and received from [email protected];
• Feedback, survey responses, and complaint records.

4. How We Use Your Data

pphsky uses the personal data it collects for the following purposes:

pphsky will not use your personal data for any purpose that is incompatible with the purposes listed above without obtaining your prior consent or as otherwise required by applicable Philippine law.

5. Legal Bases for Processing

pphsky processes your personal data on the basis of one or more of the following legal grounds, as set out under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Consent: Where you have freely given, specific, informed, and unambiguous consent to the processing of your personal data for a defined purpose (e.g., receipt of marketing communications). You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Contractual Necessity: Processing is necessary for the performance of the contract between you and pphsky (i.e., the Terms and Conditions you accepted at registration), including account management, payment processing, and access to games.
• Legal Obligation: Processing is required to comply with a legal obligation to which pphsky is subject, including obligations under Philippine anti-money laundering laws, PAGCOR regulatory requirements, and NPC data protection directives.
• Legitimate Interests: Processing is necessary for the purposes of pphsky's legitimate interests, including platform security, fraud prevention, responsible gaming enforcement, and service improvement, provided those interests are not overridden by your rights and freedoms under the DPA.

6. Sharing Your Data

pphsky does not sell, rent, or trade your personal information. We share your data only in the following limited circumstances:

6.1 Service Providers & Processors

pphsky shares personal data with carefully selected third-party service providers who process data on our behalf under written data processing agreements that require them to maintain the same level of data protection as pphsky. These include: payment processing partners (GCash operator Globe Fintech Innovations, Maya Philippines, GrabPay Philippines, and partner banks including BPI and BDO); identity verification and KYC solution providers; game software suppliers (including Evolution Gaming, JILI, PG Soft, and Pragmatic Play); IT infrastructure and cloud hosting providers; and customer relationship management platform operators.

6.2 Regulatory & Law Enforcement Authorities

pphsky is required by Philippine law to disclose personal data to regulatory bodies including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies where required by a valid legal process, court order, or regulatory directive. pphsky will notify affected players of such disclosures where it is legally permitted to do so.

6.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or a substantial portion of pphsky's assets, personal data held by pphsky may be transferred to the acquiring or successor entity as part of that transaction, subject to the same data protection obligations contained in this Policy. Affected players will be notified prior to any such transfer where practicable.

7. Cookies & Tracking Technologies

pphsky uses cookies and similar tracking technologies on pphsky.cam to operate the platform, enhance user experience, and gather analytics data. A cookie is a small text file placed on your device by a web server. The following categories of cookies are used by pphsky:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method display, and responsible gaming tool configurations. Disabling these may reduce personalisation features.
• Analytics Cookies: Collect aggregated, anonymised data about how players use pphsky.cam, including pages visited, session duration, and device types. This data is used to improve the platform. Individual players are not identified through analytics data.
• Marketing Cookies (with consent only): Used to deliver relevant promotional content based on your activity on pphsky.cam. These are only activated where you have given explicit consent via the cookie preference centre.

You can manage your cookie preferences at any time through the cookie preference centre accessible from the footer of pphsky.cam, or by configuring your browser settings to block or delete cookies. Note that blocking strictly necessary cookies will prevent you from logging in to your pphsky account.

8. Data Security

pphsky implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes:

• TLS 1.2 or higher encryption for all data in transit between your device and pphsky servers;
• AES-256 encryption for all sensitive personal data and financial records stored at rest;
• Multi-factor authentication requirements for administrative access to data processing systems;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments of pphsky's technical infrastructure conducted by independent security professionals;
• Intrusion detection systems and 24/7 security monitoring of platform servers and databases;
• Secure deletion procedures for data that has reached the end of its retention period;
• Staff data privacy training programmes conducted at onboarding and on an annual basis.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pphsky will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach and will notify affected data subjects without undue delay, in accordance with Section 20(f) of the DPA and the NPC's breach notification guidelines.

While pphsky takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is entirely secure. You are responsible for maintaining the confidentiality of your pphsky account credentials. Notify us immediately at [email protected] if you suspect any unauthorised access to your account.

9. Data Retention

pphsky retains personal data for the period necessary to fulfil the purposes for which it was collected, subject to applicable Philippine legal and regulatory retention requirements. The following retention periods apply as general guidance:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure or last transaction, as required under Philippine AML legislation and PAGCOR-aligned record-keeping obligations;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications: Retained for a minimum of two (2) years from the date of the last interaction;
• Session and technical logs: Retained for a maximum of ninety (90) days unless a specific security, compliance, or dispute investigation requires extended retention;
• Marketing consent records: Retained for the duration of the player's account plus two (2) years after closure, to demonstrate the legal basis for any marketing communications sent.

At the end of the applicable retention period, personal data is securely deleted using methods appropriate to the sensitivity of the data, including cryptographic erasure for encrypted data stores and certified physical destruction for any physical media containing personal information.

10. Your Rights Under the DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pphsky:

• Right to be Informed: You have the right to be informed that your personal data is being or will be processed, including the purposes and legal bases for that processing. This Policy fulfils pphsky's obligation to inform you.
• Right of Access: You have the right to obtain confirmation of whether pphsky holds personal data about you and, if so, to receive a copy of that data together with information about how it is processed.
• Right to Rectification: You have the right to have inaccurate or incomplete personal data corrected without undue delay. You can update basic account information directly through your account dashboard, or contact our DPO for corrections to KYC documents.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal or regulatory retention obligations that require pphsky to retain certain data.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time, and to object to processing based on legitimate interests where your rights and freedoms override those interests.
• Right to Data Portability: Where technically feasible, you may request a copy of the personal data you have provided to pphsky in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that pphsky has processed your personal data in violation of the DPA.

To exercise any of the above rights, please contact the pphsky Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will verify your identity before processing your request and will respond within the timeframes required by the NPC.

11. Children's Privacy

pphsky's Services are strictly intended for adults aged twenty-one (21) years and above. pphsky does not knowingly collect, process, or retain personal data from individuals under the age of 21. This restriction is consistent with the minimum legal age for participation in casino-style gambling under applicable PAGCOR-aligned regulations in the Philippines.

All new account registrations are subject to mandatory age and identity verification. Any account found to belong to a person under the age of 21 will be permanently closed and all associated data will be securely deleted, subject only to any mandatory retention requirements under Philippine anti-money laundering law. Funds held in underage accounts will be returned to the depositing payment method after verification.

12. Policy Updates & Contact

pphsky reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC regulatory guidance. The most current version of this Policy will always be published at pphsky.cam/privacy-policy, together with the date on which it was last updated.

For material changes that significantly affect how we process your personal data, pphsky will provide advance notice via email to the address registered to your account at least fourteen (14) days before the revised Policy takes effect. Continued use of the Services after the effective date of any revision constitutes your acceptance of the updated Policy.

If you have any questions about this Privacy Policy, wish to exercise your rights under the DPA, or wish to make a complaint about pphsky's data processing practices, please contact our Data Protection Officer using the details below. All inquiries will be treated with strict confidentiality.