phtt Privacy Policy

This Privacy Policy ("Policy") describes how phtt ("phtt," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you," "Player," or "Data Subject") who access or use the phtt online gaming platform available at phtt.app (the "Platform").

phtt is committed to protecting the privacy and personal data of all players in the Philippines. We operate in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an account on phtt, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the phtt Platform.

For the purposes of the Data Privacy Act of 2012 and this Policy, phtt is the Personal Information Controller (PIC) responsible for the personal data collected through the Platform. As PIC, phtt determines the purposes and means of processing your personal data.

phtt has appointed a Data Protection Officer (DPO ) to oversee compliance with the Data Privacy Act and to serve as the primary point of contact for data privacy concerns. The contact details of our DPO are provided in Section 15 of this Policy.

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

phtt does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by law or regulation (for example, problem gambling self-declaration for responsible gaming purposes).

phtt collects personal data through the following means:

• Direct Interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion, you provide personal data directly to phtt.
• Automated Technologies: When you access the phtt Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, and browsing behavior on the Platform.
• Third-Party Sources: phtt may receive personal data about you from third-party identity verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), fraud prevention services, and regulatory authorities where permitted by law.
• KYC and AML Checks: As part of our legal compliance obligations, phtt may obtain data about you from credit reference agencies, sanctions screening databases, and politically exposed persons (PEP) lists.

phtt uses your personal data for the following purposes:

1. Account Management: To create, maintain, and manage your phtt player account, including verifying your identity and age (21+ requirement), processing your registration, and enabling you to log in securely.
2. Service Delivery: To provide you with access to phtt games, process your deposits and withdrawals in Philippine Peso (₱), and deliver the core gaming services you have requested.
3. Legal and Regulatory Compliance: To comply with our obligations under the Data Privacy Act of 2012, anti-money laundering (AML) regulations, and any applicable directives from Philippine regulatory authorities. This includes conducting KYC verification, filing mandatory reports, and responding to lawful requests from government agencies.
4. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the phtt Platform.
5. Customer Support: To respond to your inquiries, resolve disputes, process complaints, and provide technical assistance through our 24/7 support channels.
6. Responsible Gaming: To monitor your gaming activity for signs of problem gambling, enforce self-exclusion requests, apply deposit and session limits, and fulfill our responsible gaming obligations.
7. Marketing and Promotions: To send you information about phtt promotions, bonuses, and new games where you have consented to receive such communications. You may withdraw your marketing consent at any time.
8. Platform Improvement: To analyze usage patterns, conduct research, and improve the performance, features, and user experience of the phtt Platform.

Under the Data Privacy Act of 2012, phtt processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and phtt — specifically, to operate your player account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and regulatory reporting duties.
• Legitimate Interests: Processing is necessary for phtt's legitimate interests in preventing fraud, ensuring platform security, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookies, phtt relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

phtt 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 only to the extent necessary and permitted by law:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, solely for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML service providers who assist phtt in verifying your identity and screening against sanctions and PEP lists.
• Regulatory Authorities: Philippine government agencies, law enforcement bodies, and regulatory authorities where disclosure is required by law, court order, or regulatory directive.
• Technology Service Providers: Cloud hosting providers, cybersecurity firms, and IT service providers who process data on phtt's behalf under strict data processing agreements and confidentiality obligations.
• Game Software Providers: Licensed game developers and live casino operators whose games are available on the phtt Platform, to the extent necessary to deliver the game service and resolve disputes.
• Professional Advisors: Legal counsel, auditors, and accountants who are bound by professional confidentiality obligations.

All third parties with whom phtt shares personal data are required to process that data in accordance with applicable Philippine data privacy laws and phtt's data protection standards. phtt does not authorize any third party to use your personal data for their own independent marketing purposes.

phtt uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and analyze how the Platform is used. The types of cookies we use include:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without affecting Platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymized information about how players use the phtt Platform, such as which pages are visited most frequently and whether error messages are received. This data helps us improve Platform performance.
• Functionality Cookies: These cookies remember your preferences, such as your preferred language and display settings, to provide a more personalized experience.
• Marketing Cookies: With your consent, phtt may use cookies to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These cookies do not track your activity on third-party websites.

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phtt Platform, including your ability to log in and access your account.

phtt retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation. Our standard data retention periods are as follows:

• Account Data: Retained for the duration of your active account relationship with phtt, plus a minimum of five (5) years following account closure, as required by AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with anti-money laundering and financial record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, to support dispute resolution and quality assurance.
• Marketing Data: Retained until you withdraw your marketing consent or request deletion, whichever occurs first.
• Technical and Usage Logs: Retained for up to twelve (12) months for security monitoring and platform performance analysis.

When personal data is no longer required, phtt will securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data that can no longer be linked to an individual may be retained indefinitely for statistical and research purposes.

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

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and the phtt Platform is encrypted using industry-standard 256-bit SSL/TLS protocols.
• Encrypted Data Storage: Sensitive personal data, including financial information and identity documents, is stored in encrypted form on secure servers.
• Access Controls: Access to personal data is restricted to phtt personnel and authorized third parties who have a legitimate need to access it. All access is logged and monitored.
• Two-Factor Authentication: phtt supports two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Regular Security Audits: phtt conducts regular security assessments, penetration testing, and vulnerability scans to identify and address potential security weaknesses.
• Staff Training: All phtt personnel who handle personal data receive regular training on data privacy obligations and security best practices.

While phtt 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, phtt will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

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

• Right to Be Informed: You have the right to be informed about how phtt collects and processes your personal data, as set out in this Policy.
• Right of Access: You have the right to request a copy of the personal data that phtt holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data that phtt holds about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phtt's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to phtt's overriding legal obligations.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that phtt has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact phtt's Data Protection Officer using the contact details provided in Section 15 of this Policy. phtt will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

The phtt Platform is strictly intended for adults aged 21 years and above. phtt does not knowingly collect, process, or store personal data from individuals under the age of 21. The minimum age requirement of 21 years is a mandatory legal requirement under Philippine gambling regulations, and phtt enforces this requirement through mandatory age verification during the registration process.

If phtt becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete all personal data collected from that individual, and void any transactions or winnings associated with the account.

If you are a parent or guardian and believe that your child has registered an account on phtt, please contact our Data Protection Officer immediately using the contact details in Section 15. We will investigate and take appropriate action without delay.

The phtt Platform may contain references to third-party payment providers and game software suppliers. phtt is not responsible for the privacy practices or data handling of any third-party service providers. We encourage you to review the privacy policies of any third-party services you use in connection with your phtt account, including your GCash, PayMaya, or bank account provider.

phtt's Privacy Policy applies solely to personal data collected and processed by phtt through the phtt.app Platform. It does not extend to any third-party websites, applications, or services, even if they are accessible through or referenced on the Platform.

phtt 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. When material changes are made to this Policy, phtt will notify registered players by email and by displaying a prominent notice on the phtt Platform.

The date of the most recent revision is indicated at the top of this page. We encourage you to review this Policy periodically to stay informed about how phtt protects your personal data. Your continued use of the phtt Platform following the publication of a revised Policy constitutes your acceptance of the changes.

If you do not agree with any changes to this Policy, you must cease using the phtt Platform and may request closure of your account by contacting our customer support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phtt, please contact our Data Protection Officer through any of the following channels:

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 directly on the phtt Platform — the fastest way to reach us.

phtt aims to respond to all privacy-related inquiries within fifteen (15) business days. For complex requests, we may require additional time and will notify you of any extension within the initial fifteen-day period.

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