phkoy Privacy Policy

1. Introduction

1.1 phkoy is committed to protecting the privacy and personal data of all players using our online casino and sports betting platform. We understand that Filipino players entrust us with sensitive personal and financial information, and we take that responsibility seriously.

1.2 This Policy applies to all personal data collected through the phkoy website, mobile-optimised platform, customer support channels, and any other services operated by phkoy (collectively, the "Platform").

1.3 This Policy should be read alongside phkoy's Terms & Conditions, which govern your use of the Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, phkoy acts as the Personal Information Controller in respect of the personal data it collects from players.

2.2 phkoy has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable Philippine data privacy laws. You may contact the phkoy DPO via the live chat support channel available on the Platform.

3. Data We Collect

3.1 phkoy collects the following categories of personal data from players:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, gender, nationality	Account registration, KYC verification, age verification
Contact Data	Email address, Philippine mobile number, residential address	Account communication, support, regulatory compliance
Identity Documents	PhilSys National ID, passport, driver's licence, UMID	KYC verification, AML compliance
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank)	Deposit and withdrawal processing
Transaction Data	Deposit history, withdrawal history, bet history, game activity	Account management, AML monitoring, responsible gaming
Technical Data	IP address, device type, browser type, operating system, session data	Platform security, fraud prevention, technical support
Usage Data	Pages visited, games played, time spent on Platform, click patterns	Platform improvement, personalisation, marketing analytics
Communications Data	Live chat transcripts, support ticket content, email correspondence	Customer support, dispute resolution, quality assurance

3.2 phkoy does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive information (such as government ID numbers) is collected, it is handled with heightened security measures.

4. How We Collect Data

4.1 phkoy collects personal data through the following means:

• Direct collection: Information you provide when registering a phkoy account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically when you access and use the Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from GCash, PayMaya, BPI, BDO, and Metrobank payment processors.

5. How We Use Your Data

5.1 phkoy uses your personal data for the following purposes:

• To create and manage your phkoy account;
• To verify your identity and age (21+ requirement) in accordance with Philippine regulations;
• To process deposits and withdrawals via your chosen payment method;
• To provide customer support and resolve disputes;
• To detect, prevent, and investigate fraud, money laundering, and other prohibited activities;
• To comply with obligations under Philippine law, including reporting to PAGCOR and the Anti-Money Laundering Council (AMLC);
• To send you transactional communications relating to your account;
• To send you marketing communications about phkoy promotions and offers, where you have consented to receive them;
• To personalise your experience on the Platform;
• To monitor and enforce responsible gaming limits and self-exclusion requests;
• To improve the Platform's functionality, security, and user experience.

6. Legal Basis for Processing

6.1 phkoy 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 phkoy account, process bets, and handle payments);
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act;
• Legitimate interests: Processing for fraud prevention, platform security, and improving our services, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

7. Data Sharing & Disclosure

7.1 phkoy does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phkoy may share your personal data with the following categories of recipients:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing your deposits and withdrawals;
• KYC and identity verification providers: Third-party services engaged to verify your identity documents and age;
• Fraud prevention and AML screening services: Third-party providers engaged to detect and prevent fraudulent activity and money laundering;
• Game software providers: Licensed game studios whose games are available on the phkoy Platform, to the extent necessary to operate those games;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where required by law;
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate a crime;
• Professional advisers: Lawyers, auditors, and accountants engaged by phkoy, subject to professional confidentiality obligations.

7.2 All third parties with whom phkoy shares personal data are required to handle that data in accordance with applicable Philippine data privacy laws and phkoy's data processing standards.

7.3 phkoy does not transfer personal data outside the Philippines except where necessary to operate the Platform and where appropriate safeguards are in place in accordance with the Data Privacy Act of 2012.

8. Cookies & Tracking Technologies

8.1 phkoy uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Essential Cookies required for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional Cookies that remember your preferences, such as language settings and display options.
• Analytics Cookies that collect anonymised data about how players use the Platform, used to improve performance and user experience.
• Marketing Cookies used to deliver relevant phkoy promotions. These are only set with your consent.

8.2 You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect the functionality of the phkoy Platform.

9. Data Retention

9.1 phkoy retains your personal data for as long as your phkoy account is active and for a period thereafter as required by applicable Philippine law and regulatory obligations.

9.2 In accordance with PAGCOR requirements and the Anti-Money Laundering Act, phkoy retains transaction records and KYC documentation for a minimum of five (5) years following the closure of your account or the completion of the relevant transaction, whichever is later.

9.3 Marketing data is retained until you withdraw your consent to receive marketing communications, after which it is deleted or anonymised within a reasonable period.

9.4 Where personal data is no longer required for any lawful purpose, phkoy will securely delete or anonymise it.

10. Data Security

10.1 phkoy implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• AES-256 encryption for data at rest;
• TLS encryption for all data transmitted between your device and the phkoy Platform;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• PCI-DSS compliant payment processing for all financial transactions.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phkoy will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular 16-03.

11. Your Rights

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

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data phkoy 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 phkoy's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phkoy has violated your data privacy rights.

11.2 To exercise any of the above rights, please contact the phkoy support team via 24/7 live chat on the Platform. phkoy will respond to your request within the timeframes prescribed by the Data Privacy Act of 2012.

12. Children & Minors

12.1 The phkoy Platform is strictly for persons aged 21 years and above. phkoy does not knowingly collect personal data from persons under the age of 21. If phkoy becomes aware that personal data has been collected from a person under 21, that data will be immediately deleted and the associated account closed.

12.2 If you believe that a minor has registered a phkoy account, please contact our support team immediately via live chat so that we can take appropriate action.

13. Third-Party Services

13.1 The phkoy Platform may contain references to third-party payment services (GCash, PayMaya, BPI, BDO, Metrobank) and game software providers. These third parties operate under their own privacy policies, and phkoy is not responsible for their data practices.

13.2 phkoy encourages you to review the privacy policies of any third-party services you use in connection with your phkoy account.

14. Changes to This Policy

14.1 phkoy reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, the Platform, or applicable Philippine law. The date of the most recent revision is indicated at the top of this page.

14.2 Material changes to this Policy will be communicated to registered players via email or a prominent notice on the Platform. Your continued use of the phkoy Platform following the effective date of any amendment constitutes your acknowledgement of the revised Policy.

15. Contact & Complaints

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or phkoy's data practices, please contact our Data Protection Officer via the 24/7 live chat support channel available on the Platform.

15.2 phkoy's contact email for formal data privacy correspondence is: support phkoy.com

15.3 If you are not satisfied with phkoy's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.