Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") is issued by phmoder ("phmoder," "we," "us," "our") and applies to all personal data collected from individuals ("you," "Player," "User") who access or use the phmoder website, mobile platform, and all associated services (collectively, the "Platform").

phmoder is committed to protecting the privacy and security of your personal data. This Policy explains in plain language what data we collect, why we collect it, how we use and protect it, with whom we share it, and what rights you have in relation to your data.

By registering an account on phmoder or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact our support team to close your account.

2 Data We Collect

phmoder collects the following categories of personal data in connection with your use of the Platform:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., PhilSys ID number, passport number, driver's licence number, UMID, SSS ID, or voter's ID number).
• Contact Data: Residential address (including barangay, city/municipality, province, and postal code), email address, and Philippine mobile number.
• Account Data: Username, encrypted password, account preferences, communication preferences, and responsible gaming settings.
• Financial Data: Payment method details (e.g., GCash mobile number, PayMaya account details, bank account details for BPI, BDO, or Metrobank transfers, or masked card numbers for Visa/Mastercard transactions), transaction history, deposit and withdrawal records, and wallet balance history.
• Gaming Data: Game history, betting records, wagering activity, session duration, game preferences, and bonus usage history.
• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, time zone, and session logs.
• Usage Data: Pages visited, features used, click patterns, search queries within the Platform, and referral source.
• Communications Data: Records of your interactions with phmoder's support team, including live chat transcripts, email correspondence, and any feedback or complaints submitted.
• KYC Documentation: Copies of government-issued identification documents and proof of address documents submitted as part of the account verification process.

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by applicable law or regulation (for example, where a player discloses a gambling-related health concern in the context of a responsible gaming request).

3 How We Collect Your Data

phmoder collects your personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting our support team, participating in promotions, or updating your account settings.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 8 for more detail on cookies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud and anti-money laundering screening services; payment data from payment processors including GCash, PayMaya, and banking partners.
• Publicly Available Sources: In limited circumstances, phmoder may supplement your data with information from publicly available sources for the purpose of identity verification or fraud prevention.

4 How We Use Your Data

phmoder uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your phmoder account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Service Delivery: To provide you with access to the games, sports betting, live dealer, bingo, sabong, and other services available on the phmoder Platform.
• Payment Processing: To process your deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other supported payment methods.
• KYC & Compliance: To verify your identity and age (21+), comply with anti-money laundering (AML) obligations, and meet our regulatory requirements under applicable Philippine law and PAGCOR guidelines.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit and loss limits, process self-exclusion requests, and provide responsible gaming support.
• Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance through our 24/7 Filipino support team.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other prohibited conduct.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the phmoder Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time from your account settings.
• Legal Obligations: To comply with applicable laws, regulations, court orders, and requests from competent regulatory authorities.

5 Legal Basis for Processing

phmoder processes your personal data on the following legal bases:

• Contractual Necessity: Processing necessary to perform our contract with you — i.e., to provide the phmoder Platform services you have registered for, including account management, game access, and payment processing.
• Legal Obligation: Processing necessary to comply with our legal and regulatory obligations, including KYC verification, AML screening, age verification, and reporting obligations under applicable Philippine law and PAGCOR requirements.
• Legitimate Interests: Processing necessary for phmoder's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improving our services — provided these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Sharing Your Data

phmoder does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances and only to the extent necessary:

• Service Providers: Third-party vendors who provide services on our behalf, including KYC and identity verification providers, payment processors (GCash, PayMaya, banking partners), game software providers (e.g., Evolution, Pragmatic Play), cloud hosting providers, and customer support platform providers. All service providers are contractually bound to process your data only on phmoder's instructions and in accordance with applicable data protection requirements.
• Regulatory Authorities: PAGCOR and other competent Philippine regulatory authorities, law enforcement agencies, and courts where we are legally required to dis close your data.
• Anti-Fraud & AML Partners: Third-party fraud prevention and anti-money laundering screening services that help phmoder detect and prevent financial crime on the Platform.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of phmoder's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.
• With Your Consent: In any other circumstances where you have given your explicit consent to the sharing of your data with a named third party.

7 Data Retention

phmoder retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements.

• Active Accounts: Personal data associated with an active phmoder account is retained for the duration of the account relationship and for a period of at least five (5) years following account closure, in accordance with applicable AML and regulatory record-keeping requirements.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following the end of the account relationship, as required by applicable Philippine AML regulations.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years following the date of each transaction.
• Support Communications: Records of customer support interactions are retained for a period of three (3) years following the date of the interaction.
• Marketing Data: Where you have consented to marketing communications, your marketing preferences are retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.
• Technical & Usage Data: Anonymised or aggregated technical and usage data may be retained indefinitely for analytical and platform improvement purposes, as it no longer constitutes personal data once anonymised.

When personal data is no longer required, phmoder will securely delete or anonymise it in accordance with our internal data retention and disposal procedures.

8 Cookies & Tracking

phmoder uses cookies and similar tracking technologies on the Platform to enhance your experience, analyse usage, and support security functions. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in during your visit and security cookies that help protect your account. These cookies cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymised information about how players use the Platform, including which pages are visited most frequently and how players navigate between sections. This data helps phmoder improve the Platform's performance and usability.
• Functional Cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming configurations, so you do not need to re-enter them on each visit.
• Marketing & Targeting Cookies: Used to deliver relevant promotional content and offers based on your activity on the Platform. These cookies are only set where you have consented to marketing communications.

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

9 Data Security

phmoder takes the security of your personal data seriously and implements a range of technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and the phmoder Platform is encrypted using industry-standard SSL/TLS protocols.
• Secure Data Storage: Personal and financial data is stored on secure, access-controlled servers with restricted access limited to authorised phmoder personnel on a need-to-know basis.
• Two-Factor Authentication: phmoder offers two-factor authentication (2FA) for player accounts to provide an additional layer of security beyond your password.
• Regular Security Audits: phmoder conducts regular internal and third-party security assessments to identify and address potential vulnerabilities in the Platform.
• Staff Training: All phmoder staff who handle personal data receive regular training on data protection obligations and security best practices.
• Incident Response: phmoder maintains a data breach response procedure. In the event of a data breach that poses a risk to your rights, we will notify affected players and relevant authorities in accordance with applicable legal requirements.

10 Your Rights

As a phmoder player, you have the following rights in relation to your personal data, subject to applicable legal limitations and our regulatory obligations:

• Right of Access: You have the right to request a copy of the personal data phmoder holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most account information directly from your account settings.
• 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 our legal retention obligations (e.g., AML record-keeping requirements).
• Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances, for example while a dispute about the accuracy of your data is being resolved.
• Right to Data Portability: You have the right to receive a copy of the personal data you have provided to phmoder in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where phmoder relies on legitimate interests as the legal basis, and where your particular circumstances warrant such an objection.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our support team at [email protected]. We will respond to all verified requests within 30 days. We may need to verify your identity before processing your request.

11 Children's Privacy

The phmoder Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gambling regulations. phmoder does not knowingly collect personal data from individuals under the age of 21.

Parents and guardians are encouraged to use parental control tools and internet filtering software to prevent minors from accessing online gambling platforms. phmoder supports responsible gaming and the protection of vulnerable individuals.

12 Changes to This Policy

phmoder reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email or a prominent notice on the Platform at least 7 days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how phmoder protects your personal data. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

13 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or phmoder's data handling practices, please contact our support team:

• Email: [email protected]
• Live Chat: Available 24/7 via the phmoder Platform
• Support Hours: 24 hours a day, 7 days a week (Philippine Standard Time)

phmoder aims to acknowledge all privacy-related complaints within 2 business days and to provide a substantive response within 30 days. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant Philippine data protection authority.