phtsys Privacy Policy

1. Who We Are

phtsys ("phtsys," "we," "us," or "our") operates the online casino and sportsbook platform accessible at phtsys.com. phtsys is a PAGCOR-regulated online gaming operator serving players across the Philippines, including Manila, Cebu, Davao, Makati, and Quezon City.

For the purposes of this Privacy Policy, phtsys is the data controller responsible for the personal information collected through the phtsys Platform. This Privacy Policy applies to all users of the phtsys website, mobile platform, and related services.

If you have any questions about this Privacy Policy or how phtsys handles your personal data, please contact our Data Privacy Officer using the contact details provided in Section 14 of this Policy.

2. Personal Data We Collect

2.1 Registration & Identity Data

When you create a phtsys account, we collect the information necessary to verify your identity and comply with PAGCOR's Know Your Customer (KYC) requirements. This includes:

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including city, province, and postal code)
• Email address and mobile phone number
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license)
• Copies of identity documents submitted for KYC verification

2.2 Financial & Transaction Data

To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and Instapay, phtsys collects:

• Payment method details (e.g., GCash mobile number, bank account name)
• Transaction history, including deposit amounts, withdrawal amounts, dates, and reference numbers
• Wallet balance and bonus balance information

phtsys does not store full bank account numbers or card numbers on its servers. Payment processing is handled through secure, PCI-DSS compliant payment gateways.

2.3 Gaming Activity Data

phtsys records your gaming activity on the Platform, including:

• Games played, bet amounts, and outcomes
• Sports bets placed, including event, market, odds, and result
• Session duration and frequency of play
• Bonus usage and wagering progress

2.4 Technical & Device Data

When you access the phtsys Platform, we automatically collect certain technical information, including:

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Pages visited, features used, and time spent on the Platform
• Referring URL and exit pages

2.5 Communications Data

If you contact phtsys support via live chat or email, we retain records of those communications, including the content of your messages and our responses, for quality assurance and dispute resolution purposes.

3. How We Collect Your Data

phtsys collects your personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, place a bet, contact support, or update your account settings.
• Automatically: Through cookies, web beacons, and similar tracking technologies when you access and use the phtsys Platform.
• From third parties: From identity verification service providers, payment processors, and fraud prevention partners where necessary to comply with our regulatory obligations.

4. How We Use Your Personal Data

phtsys uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phtsys account, including processing your registration and verifying your identity.
• Service delivery: To provide access to casino games, sports betting, bingo, and all other Platform features.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and Instapay.
• Regulatory compliance: To comply with PAGCOR licensing requirements, Anti-Money Laundering (AML) obligations, and other applicable Philippine laws and regulations.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the Platform.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• 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.
• Platform improvement: To analyze usage patterns and improve the phtsys Platform's features, performance, and user experience.

5. Legal Basis for Processing

phtsys processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations:

• Contractual necessity: Processing is necessary to perform the contract between you and phtsys (i.e., to provide the gaming services you have registered for).
• Legal obligation: Processing is necessary to comply with phtsys's legal and regulatory obligations, including PAGCOR licensing requirements and AML laws.
• Legitimate interests: Processing is necessary for phtsys's legitimate interests in fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests.
• Consent: For marketing communications and non-essential cookies, phtsys relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. Data Sharing & Disclosure

phtsys does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• PAGCOR and Philippine regulatory authorities: phtsys is required to share certain player data with PAGCOR and other relevant Philippine government agencies as part of its licensing obligations.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and Instapay receive the minimum data necessary to process your transactions.
• Identity verification providers: Third-party KYC and AML service providers assist phtsys in verifying player identities and screening for financial crime risks.
• Technology and hosting providers: Cloud infrastructure and software providers that host and operate the phtsys Platform under strict data processing agreements.
• Law enforcement: Where required by applicable Philippine law, court order, or regulatory directive, phtsys may disclose your personal data to law enforcement or government authorities.

All third-party service providers engaged by phtsys are contractually required to process your personal data only for the specified purpose and to maintain appropriate security measures.

7. Cookies & Tracking Technologies

phtsys uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use include:

• Essential cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming limits you have set.
• Analytics cookies: Help phtsys understand how players use the Platform so we can improve features and performance. Analytics data is aggregated and anonymized where possible.
• Marketing cookies: Used to deliver relevant promotional content to you on the phtsys Platform, based on your gaming preferences and activity. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phtsys Platform.

8. Data Retention

phtsys retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, and accounting requirements. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and Philippine AML laws.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity logs: Retained for a minimum of three (3) years.
• Support communications: Retained for two (2) years from the date of the communication.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation purposes.

When personal data is no longer required, phtsys securely deletes or anonymizes it in accordance with our data disposal procedures.

9. Data Security

phtsys implements comprehensive technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the phtsys Platform
• Encryption of sensitive data at rest, including identity documents and payment information
• Two-factor authentication (2FA) available for all phtsys accounts
• Regular security audits and penetration testing of the Platform
• Strict access controls limiting employee access to personal data on a need-to-know basis
• Automated fraud detection and anomaly monitoring systems

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by phtsys:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, which this Privacy Policy fulfills.
• Right to access: You may request a copy of the personal data phtsys holds about you at any time. We will respond to verified access requests within fifteen (15) business days.
• Right to correction: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic account information directly through your phtsys account settings.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phtsys's legal and regulatory 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 where your individual circumstances warrant it.
• Right to data portability: You may request that phtsys provide your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: If you believe phtsys has not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Privacy Officer via live chat on the phtsys Platform or by email at the address listed in Section 14. We may require you to verify your identity before processing your request.

11. Children's Privacy

The phtsys Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations and applicable Philippine law. phtsys does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the phtsys Platform, please contact our support team immediately via live chat so we can investigate and take appropriate action.

12. International Data Transfers

phtsys primarily stores and processes your personal data within the Philippines. In certain circumstances, your data may be transferred to and processed in other countries where our technology service providers or data processors operate. Where such transfers occur, phtsys ensures that appropriate safeguards are in place to protect your personal data, including contractual data processing agreements that require the recipient to maintain data protection standards equivalent to those required under Philippine law.

By using the phtsys Platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject always to the protections described in this Privacy Policy.

13. Updates to This Privacy Policy

phtsys reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or Platform features. When material changes are made, phtsys will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how phtsys protects your personal data. Your continued use of the phtsys Platform following the posting of any changes constitutes your acceptance of the updated Privacy Policy.

14. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by phtsys, please contact our Data Privacy Officer:

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

We are committed to resolving all data privacy inquiries promptly and transparently. If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission of the Philippines through their official channels.