Privacy Policy

1. Overview

This Privacy Policy applies to all services offered by phmoderm (referred to as "phmoderm," "we," "us," or "our") through the website phmoderm.com and any related mobile or web applications (collectively, the "Platform"). It governs the collection, use, storage, and disclosure of personal information provided by users ("you," "your," or "Player") when accessing or using the Platform.

phmoderm is committed to protecting the privacy and personal data of all players in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its implementing rules and regulations. By registering an account or using the Platform, you consent to the practices described in this Privacy Policy.

If you do not agree with any part of this Privacy Policy, you must discontinue use of the Platform immediately. We encourage you to read this document carefully and contact us if you have any questions.

2. Data We Collect

2.1 Information You Provide Directly

When you register an account, use our services, or contact our support team, phmoderm may collect the following categories of personal information:

• Identity Information: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., Philippine National ID, passport, driver's license, SSS/GSIS number).
• Contact Information: Email address, mobile number, and residential address (including city, province, and postal code).
• Financial Information: Bank account details (BPI, BDO, Metrobank, UnionBank), e-wallet account information (GCash, PayMaya), and transaction history on the Platform.
• Account Credentials: Username and encrypted password. We do not store passwords in plain text.
• Verification Documents: Copies of government-issued IDs, proof of address, and proof of payment method ownership submitted during the KYC (Know Your Customer) process.

2.2 Information Collected Automatically

When you access the Platform, we automatically collect certain technical and behavioral data, including:

• Device Information: IP address, device type, operating system, browser type and version, and unique device identifiers.
• Usage Data: Pages visited, games played, session duration, click patterns, and navigation paths within the Platform.
• Location Data: General geographic location derived from your IP address. We do not collect precise GPS location data unless explicitly permitted by you.
• Log Data: Server logs including access times, error reports, and referral URLs.

2.3 Information from Third Parties

phmoderm may receive information about you from third-party sources, including:

• Payment processors and e-wallet providers for transaction verification.
• Identity verification service providers for KYC compliance.
• Fraud detection and anti-money laundering (AML) screening services.
• Analytics providers that help us understand Platform usage patterns.

3. How We Use Your Data

phmoderm uses the personal information we collect for the following purposes:

Purpose	Description
Account Management	Creating and maintaining your player account, verifying your identity, and processing your registration.
Service Delivery	Providing access to games, processing deposits and withdrawals, and delivering customer support.
Legal Compliance	Meeting obligations under Philippine law, including AML regulations, PAGCOR licensing requirements, and the Data Privacy Act of 2012.
Fraud Prevention	Detecting and preventing fraudulent activity, money laundering, and unauthorized account access.
Responsible Gaming	Monitoring gameplay patterns to identify problem gambling behavior and enforcing self-exclusion requests.
Communications	Sending transactional notifications, account alerts, and — with your consent — promotional offers and updates.
Platform Improvement	Analyzing usage data to improve the Platform's features, performance, and user experience.

4. Legal Basis for Processing

phmoderm processes your personal data on the following legal grounds under the Data Privacy Act of 2012 and applicable regulations:

• Contractual Necessity: Processing is necessary to fulfill our obligations under the Terms and Conditions you agreed to upon registration, including account management and payment processing.
• Legal Obligation: Processing is required to comply with applicable laws, including AML regulations, tax reporting requirements, and PAGCOR licensing conditions.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests do not override your fundamental rights.
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

5. Sharing Your Information

5.1 Third-Party Service Providers

phmoderm may share your personal information with trusted third-party service providers who assist us in operating the Platform. These include payment processors, identity verification providers, game software providers, cloud hosting services, and customer support tools. All third-party providers are contractually obligated to handle your data securely and only for the purposes specified by phmoderm.

5.2 Regulatory and Legal Authorities

We may disclose your personal information to government agencies, law enforcement bodies, or regulatory authorities (including PAGCOR and the National Privacy Commission) when required by law, court order, or regulatory directive. We will notify you of such disclosures where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of phmoderm's business, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and ensure that your data continues to be protected under terms no less protective than this Privacy Policy.

5.4 No Sale of Personal Data

phmoderm does not sell, rent, or trade your personal information to third parties for their own marketing purposes. Your data is used solely to provide and improve the services you have requested from us.

6. Cookies and Tracking Technologies

6.1 What Are Cookies

Cookies are small text files stored on your device when you visit the Platform. phmoderm uses cookies and similar tracking technologies (such as web beacons and local storage) to enhance your experience, maintain session security, and analyze Platform usage.

6.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that prevent fraudulent use. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and game history, to personalize your experience.
• Analytics Cookies: Help us understand how players use the Platform so we can improve performance and features. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your explicit consent.

6.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For detailed instructions on managing cookies in your browser, refer to your browser's help documentation.

7. Data Retention

phmoderm retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

• Active Accounts: Personal data is retained for the duration of your account's active status.
• Closed Accounts: Following account closure, we retain your data for a minimum of five (5) years to comply with AML regulations, tax obligations, and potential legal proceedings.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years as required by Philippine financial regulations.
• Marketing Data: Data used for marketing purposes is retained until you withdraw your consent or request deletion, whichever comes first.

When your data is no longer required, phmoderm will securely delete or anonymize it in accordance with our data disposal procedures.

8. Data Security

phmoderm implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest is also encrypted.
• Access Controls: Access to personal data is restricted to authorized personnel only, based on the principle of least privilege. All employees undergo data protection training.
• Monitoring: We continuously monitor our systems for suspicious activity and potential security breaches.
• Regular Audits: Our security practices are regularly reviewed and updated to address emerging threats.

While phmoderm takes all reasonable precautions to protect your data, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and notifying us immediately if you suspect unauthorized access.

9. Your Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal data:

• Right to Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data, subject to legal retention requirements.
• Right to Object: You may object to processing of your data for direct marketing purposes or based on legitimate interests.
• Right to Data Portability: You may request a copy of your data in a structured, commonly used format.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time.
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the email address provided in Section 12 below. We will respond to your request within thirty (30) days.

10. Minors and Age Restriction

phmoderm's services are strictly intended for individuals aged 21 years or older. We do not knowingly collect personal information from minors. If you are under 21, you must not register an account or use the Platform.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that information from our systems. Parents or guardians who believe their child has provided personal information to phmoderm should contact us immediately.

11. Changes to This Policy

phmoderm reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. When we make material changes, we will update the "Last Updated" date at the top of this page and notify you via email or through a prominent notice on the Platform.

Your continued use of the Platform following any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how phmoderm handles your personal data, please contact our Data Protection Officer:

Data Protection Officer
phmoderm
Email: [email protected]
Support Email: [email protected]

We are committed to addressing your privacy concerns promptly and transparently. All inquiries will be handled in accordance with the Data Privacy Act of 2012 and applicable regulations.