phtaya1 Privacy Policy

This Privacy Policy ("Policy") explains how phtaya1 ("phtaya1," "we," "us," "the Company") collects, uses, stores, discloses, and protects personal information in connection with your access to and use of the phtaya1 Platform at phtaya1.club, including all casino games, sports betting, payment services, customer support, and promotional activities offered therein.

This Policy applies to all registered players, prospective registrants, and any individual whose personal data is processed by phtaya1 in connection with the Platform, regardless of whether they are located in Metro Manila, Cebu, Davao, Quezon City, Makati, or any other part of the Philippines.

By registering an account on phtaya1 or continuing to use the Platform, you confirm that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. This Policy is incorporated into and forms part of the phtaya1 Terms & Conditions.

For the purposes of the Data Privacy Act of 2012 and this Policy, phtaya1 is the personal information controller (PIC) with respect to all personal data collected through the Platform. As a PAGCOR-licensed operator, phtaya1 maintains a registered Data Protection Officer (DPO) responsible for overseeing data protection compliance.

All data protection inquiries, access requests, correction requests, and complaints may be directed to the phtaya1 Data Protection Officer at the contact details provided in Section 13 of this Policy.

phtaya1 collects personal data through the following channels: account registration, identity verification (KYC), payment processing, gameplay activity, customer support interactions, and automated technical collection via the Platform.

phtaya1 processes your personal data only where it has a lawful basis to do so under the Data Privacy Act of 2012. The following table sets out the purposes for which we process your data and the corresponding lawful basis:

• Account creation and management — Contractual necessity; processing is required to provide the Platform services you have requested.
• Identity and age verification (KYC) — Legal obligation under PAGCOR licensing conditions and Philippine AML law; legitimate interest in preventing underage gambling.
• Payment processing (deposits and withdrawals) — Contractual necessity; required to fulfill the financial transaction you have initiated.
• Anti-money laundering (AML) and fraud prevention — Legal obligation under the Anti-Money Laundering Act (AMLA) of the Philippines and PAGCOR regulatory requirements.
• Responsible gaming monitoring — Legal obligation under PAGCOR licensing; legitimate interest in player welfare and harm minimization.
• Customer support and dispute resolution — Legitimate interest; required to respond to your inquiries and resolve complaints effectively.
• Platform security and fraud detection — Legitimate interest; necessary to protect the integrity of the Platform and all user accounts.
• Marketing and promotional communications — Consent; you may opt out of marketing communications at any time via account settings or by contacting support.
• Regulatory reporting — Legal obligation under PAGCOR licensing conditions and applicable Philippine financial regulations.

phtaya1 does not sell or commercially transfer your personal data to any third party. Data is shared with third parties only in the following strictly limited circumstances:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay require transaction data to process deposits and withdrawals. These providers operate under their own data protection frameworks and applicable Philippine financial regulations.
• Game software suppliers: Third-party game developers whose games are hosted on the phtaya1 Platform may receive anonymized or aggregated gameplay data for game performance and certification purposes.
• KYC/AML verification providers: Third-party identity verification services may receive identity documents and supporting data for KYC processing. All such providers are contractually bound to handle data securely and in compliance with Philippine law.
• PAGCOR and regulatory authorities: phtaya1 is legally obligated to report certain player data and gameplay statistics to PAGCOR as a condition of its license. phtaya1 will comply with lawful orders and requests from PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies.
• Law enforcement: Where required by a valid court order, subpoena, or other lawful legal process under Philippine law, phtaya1 may disclose personal data to law enforcement agencies.

phtaya1 uses cookies and similar tracking technologies on the Platform to support core site functions, improve user experience, and analyze usage patterns. Cookies are small text files stored on your device by your web browser.

phtaya1 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during a play session. They cannot be disabled without impairing Platform functionality.
• Performance Cookies: Collect anonymized information about how players navigate the Platform (e.g., pages visited, time spent). Used solely to improve Platform performance and layout.
• Functional Cookies: Remember your preferences such as language settings and preferred game category to enhance your experience.
• Analytics Cookies: Used by phtaya1's internal analytics tools to understand aggregate player behavior patterns. Data is aggregated and not attributed to individual players for these purposes.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform, including the ability to log in and maintain an active session.

phtaya1 retains personal data only for as long as is necessary for the purpose it was collected and as required by applicable law. The following retention guidelines apply:

• Active account data: Retained for the duration of the account's active status and for a period of five (5) years following account closure, as required by PAGCOR and AMLC regulations.
• Financial transaction records: Retained for a minimum of five (5) years in compliance with Philippine AML regulations.
• KYC/Identity verification documents: Retained for a minimum of five (5) years following the end of the customer relationship.
• Customer support records: Retained for two (2) years from the date of the last interaction.
• Marketing communications data: Retained until you withdraw consent or for two years following your last Platform activity, whichever comes first.

phtaya1 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and phtaya1 servers
• AES-256 encryption at rest for stored sensitive personal and financial data
• Multi-factor authentication (SMS OTP) available on all player accounts
• Anomaly detection systems that identify and flag unusual login patterns or access attempts
• Role-based access controls limiting internal access to personal data to authorized personnel only
• Regular penetration testing and security audits conducted by third-party security firms
• Segregated player fund accounts to ensure financial data is ring-fenced from operational systems
• Data breach response protocols including NPC notification procedures within 72 hours of a confirmed breach affecting Philippine residents

Notwithstanding these measures, no internet transmission or electronic storage system is completely secure. If you suspect unauthorized access to your phtaya1 account, contact support immediately at support@phtaya1.club or via live chat.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phtaya1. To exercise any of these rights, contact the phtaya1 Data Protection Officer as described in Section 13.

phtaya1 will respond to valid data rights requests within 30 calendar days of receipt. We may request proof of identity before processing any data rights request to protect against unauthorized access to your information.

phtaya1 strictly prohibits the registration and use of the Platform by any person under the age of 21 years. The minimum age requirement of 21 is mandated by PAGCOR and is rigorously enforced through age verification procedures at registration.

If you are a parent or guardian and believe a minor has registered an account on phtaya1, please contact us immediately at support@phtaya1.club. We will investigate promptly and take appropriate action.

Some of phtaya1's technology and service providers operate infrastructure or data processing facilities outside of the Philippines. Where personal data is transferred outside Philippine territory, phtaya1 will ensure that:

• The receiving country provides adequate data protection under the NPC's assessment, or
• Appropriate contractual safeguards are in place (e.g., standard contractual clauses approved by the NPC), or
• The transfer falls within a recognized exception under the Data Privacy Act of 2012 (e.g., necessary for the performance of a contract with the data subject)

phtaya1 maintains a register of all third-party service providers involved in cross-border data transfers, which is available for review upon written request to the Data Protection Officer.

phtaya1 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes to this Policy will be communicated to registered players via email and/or a prominent notice on the Platform at least seven (7) calendar days before taking effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy. If you do not accept the updated Policy, you should close your account before the effective date.

For any questions, concerns, or requests relating to this Privacy Policy or phtaya1's handling of your personal data, please contact the phtaya1 Data Protection Officer:

• Email: support@phtaya1.club — please include "Data Privacy" in your subject line
• Live Chat: Available 24/7 via the phtaya1 Platform (after login)
• Response Time: Initial response within 72 hours; formal data rights responses within 30 calendar days

If you are not satisfied with phtaya1's handling of your data privacy complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC accepts complaints via its official government portal and offices in Manila. Information about the NPC's complaint process is available through official Philippine government channels.