Privacy Policy – phmery Casino

1. Introduction

phmery ("we," "us," "our") operates the online casino and sports betting platform accessible at phmery.org (the "Platform"). We understand that privacy matters deeply to the Filipino players who trust phmery with their personal information, and we take our data protection obligations seriously.

This Privacy Policy describes how phmery collects, uses, discloses, stores, and protects personal data relating to individuals who register for or use the phmery Platform ("you," "Player"). It is prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an Account or using the phmery Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, you must discontinue use of the Platform immediately.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable Philippine regulations, phmery is the Personal Information Controller in respect of personal data collected through the Platform.

Our designated Data Protection Officer (DPO) can be reached at [email protected] for any privacy-related enquiries, requests, or complaints.

3. Personal Data We Collect

phmery collects the following categories of personal data from Players:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification document details (e.g., Philippine SSS ID, PhilHealth, Passport, Driver's License) required for Know Your Customer (KYC) verification.
• Contact Data: Philippine mobile number, email address, and residential address.
• Financial Data: GCash mobile number, Maya account details, bank account information (BPI, BDO, Metrobank, or other Philippine banks) used for deposits and withdrawals. Full payment credentials are not stored by phmery.
• Account Data: Username, encrypted password, account registration date, account status, and balance history.
• Transaction Data: Records of deposits, withdrawals, game bets, wins, losses, bonus usage, and all financial transactions on the Platform.
• Technical Data: IP address, browser type and version, device type, operating system, time zone, and other technical identifiers generated during Platform access.
• Usage Data: Information about how you use the Platform, including pages visited, games played, session duration, and in-platform navigation patterns.
• Communications Data: Records of your communications with phmery customer support, including live chat logs and email correspondence.
• Responsible Gaming Data: Self-imposed limits, self-exclusion requests, and responsible gaming tool usage history.

4. How We Collect Your Personal Data

phmery collects personal data through the following means:

• Direct Provision: Data you provide when registering an Account, completing KYC verification, making a deposit or withdrawal, contacting support, or filling out any Platform form.
• Automated Technologies: Data collected automatically when you access the Platform, including cookies, web beacons, server logs, and device fingerprinting technologies.
• Third Parties: Identity verification data from KYC service providers; fraud prevention data from risk management partners; payment confirmation data from GCash, Maya, and banking partners.
• PAGCOR and Regulatory Bodies: phmery may receive information from PAGCOR or other Philippine regulatory authorities in the course of licensing, compliance audits, or investigations.

5. How We Use Your Personal Data

phmery uses your personal data for the following purposes:

• To create, verify, and maintain your phmery Account and process your registration.
• To process deposits, withdrawals, and all financial transactions on the Platform, including integration with GCash and Philippine banking partners.
• To verify your identity and age (21+ requirement) in compliance with PAGCOR regulations and applicable Philippine laws.
• To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and other prohibited conduct.
• To comply with our legal and regulatory obligations, including Anti-Money Laundering Act (AMLA) reporting requirements and PAGCOR licence conditions.
• To manage responsible gaming tools, process self-exclusion requests, and fulfil obligations under PAGCOR's responsible gaming framework.
• To personalise your phmery experience, including game recommendations and relevant promotional offers (subject to your communication preferences).
• To send account-related communications, including transaction confirmations, security alerts, and support responses.
• To send promotional communications where you have opted in to receive them from phmery.
• To improve the Platform through analysis of usage patterns, technical performance monitoring, and A/B testing.

6. Legal Basis for Processing

phmery processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to when registering your Account — including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with PAGCOR regulations, AMLA reporting obligations, NPC requirements, and other applicable Philippine laws.
• Legitimate Interests: Processing necessary for phmery's legitimate business interests, including fraud prevention, platform security, responsible gaming enforcement, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing for promotional communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time.

7. Sharing Your Personal Data

phmery does not sell or rent your personal data. We may share it with the following categories of recipients only as necessary:

• Game Providers: Technical data (such as session tokens) shared with JILI, Pragmatic Play, PG Soft, and other licensed game studios to deliver games to you. Game providers do not receive your full identity or financial data.
• Payment Partners: Financial data shared with GCash, Maya, BPI, BDO, Metrobank, and other payment processors as necessary to execute your transactions.
• KYC & Fraud Prevention Providers: Identity data shared with licensed third-party KYC verification and fraud prevention service providers under strict data processing agreements.
• Regulatory Authorities: phmery will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government authorities as required by law or upon lawful request.
• Professional Advisers: Legal counsel, auditors, and other professional advisers under confidentiality obligations where necessary for phmery's business operations.

8. International Data Transfers

Some of phmery's service providers — particularly game studios and technology infrastructure partners — may be located outside the Philippines. Where personal data is transferred internationally, phmery ensures that appropriate safeguards are in place in accordance with NPC requirements, including contractual data protection clauses consistent with Philippine standards.

9. Data Retention

phmery retains your personal data for as long as your Account remains active and for a period thereafter as required by applicable law. Specifically:

• Account and Transaction Data: Retained for a minimum of five (5) years after account closure, as required under Philippine AMLA regulations.
• KYC Documentation: Retained for a minimum of five (5) years after the end of the business relationship.
• Support Communications: Retained for three (3) years from the date of the last communication.
• Technical and Usage Data: Retained for up to twelve (12) months for analytics and security purposes.

Upon expiry of the applicable retention period, phmery will securely delete or anonymise your personal data.

10. Cookies and Tracking Technologies

phmery uses cookies and similar technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function — including session management, login state maintenance, and security tokens. These cannot be disabled.
• Analytics Cookies: Used to understand how Players use the Platform and to improve performance. Anonymised data is used for these purposes.
• Preference Cookies: Used to remember your Platform settings and preferences across sessions.

You can manage non-essential cookie preferences through your browser settings. Disabling analytics or preference cookies will not affect your ability to use the Platform, but may affect personalisation features.

11. Children's Privacy

The phmery Platform is strictly for individuals aged 21 years and above in accordance with Philippine gambling laws and PAGCOR regulations. phmery does not knowingly collect personal data from anyone under 21. If we discover that personal data from a person under 21 has been collected, we will immediately close the associated Account and delete the data. If you believe a minor has accessed the Platform, please notify us immediately at [email protected].

12. Your Data Subject Rights

Under the Data Privacy Act of 2012, as a Filipino data subject, you have the following rights in relation to your personal data held by phmery:

• Right to be Informed: The right to know whether phmery holds your personal data and how it is being used — addressed by this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phmery 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 where there is no compelling legal reason for continued retention, subject to our regulatory data retention obligations.
• Right to Object: The right to object to processing of your personal data for marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format.
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw it at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phmery has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. phmery will respond to verified requests within fifteen (15) business days.

13. Data Security

phmery implements technical and organisational security measures appropriate to the risk of processing, including:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and phmery's servers.
• Encrypted storage of passwords using industry-standard hashing algorithms. phmery never stores passwords in plain text.
• Access controls ensuring that only authorised phmery personnel with a legitimate business need can access Player personal data.
• Regular security assessments and vulnerability testing of the Platform.
• Incident response procedures aligned with NPC breach notification requirements — phmery will notify affected Players and the NPC in the event of a personal data breach within the timeframes required by Philippine law.

14. Third-Party Links

The phmery Platform does not contain links to third-party websites. This Privacy Policy applies solely to data collected through phmery.org. phmery is not responsible for the privacy practices of any external websites you may access independently.

15. Changes to This Privacy Policy

phmery may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. Material changes will be communicated to registered Players via email or a prominent notice on the Platform. The "Last Updated" date at the top of this page indicates the most recent revision. Your continued use of the phmery Platform after any revision constitutes acceptance of the updated Privacy Policy.

16. Contact & Complaints

For any privacy-related questions, data subject rights requests, or complaints, please contact phmery's Data Protection Officer:

• Email: [email protected]

If you are not satisfied with phmery's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which oversees enforcement of the Data Privacy Act of 2012.