Your Privacy at phcssh

1 Overview

phcssh ("phcssh," "we," "us," "our") is committed to protecting the privacy and security of every player who uses our platform. We understand that trust is the foundation of any good relationship — and that trust starts with being transparent about how we handle your personal information.

This Privacy Policy applies to all personal data collected through the phcssh website, mobile interface, customer support channels, and any other services we provide. It covers data collected from registered account holders, visitors who browse the platform without registering, and any individual who interacts with phcssh in any capacity.

We encourage you to read this policy carefully. If you have questions at any point, our Data Protection Officer (DPO) is available to assist — contact details are provided in Section 14.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, phcssh is the personal information controller responsible for your data collected through the phcssh platform. phcssh operates in accordance with PAGCOR regulations and Philippine law.

Where phcssh engages third-party service providers to process personal data on its behalf (for example, payment processors or identity verification providers), those parties act as personal information processors under written agreements that require them to handle your data in accordance with this Privacy Policy and applicable law.

3 Personal Data We Collect

phcssh collects personal data through several channels. The categories of data we collect include:

3.1 Registration & Identity Data

• Full legal name, date of birth, and gender;
• Government-issued identification number (e.g., Philippine passport, driver's license, SSS/UMID);
• Residential address (including barangay, city/municipality, province);
• Email address and mobile phone number;
• Username and encrypted password.

3.2 Financial & Payment Data

• GCash or PayMaya/Maya account details (mobile number associated with the account);
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank);
• Debit card details (card number, expiry — stored in tokenised form only);
• Transaction history, deposit and withdrawal records.

3.3 Gaming & Activity Data

• Game participation history, wager amounts, wins and losses;
• Session duration, login timestamps, and platform activity logs;
• Responsible gaming tool usage (deposit limits set, self-exclusion requests);
• Bonus and promotion redemption history.

3.4 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Cookie identifiers and session tokens (see Section 9);
• Referring URL and pages visited on the phcssh platform.

3.5 Communications Data

• Records of communications with phcssh customer support (live chat transcripts, email correspondence);
• Feedback, survey responses, and complaints submitted to phcssh.

4 How We Use Your Personal Data

phcssh processes your personal data for the following purposes:

phcssh will not use your personal data for any purpose incompatible with those listed above without first obtaining your consent or establishing another lawful basis for processing.

5 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you — including account management, game provision, and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine law, including AML regulations, PAGCOR requirements, and tax obligations;
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

phcssh does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

6.1 Payment Service Providers

We share financial data with regulated Philippine payment processors — including GCash, PayMaya/Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) — solely to facilitate deposits and withdrawals on your behalf. These providers are bound by their own privacy obligations under Philippine law.

6.2 Identity Verification Providers

To fulfil our KYC obligations, phcssh may share identity documents and personal details with accredited identity verification service providers. These processors act under written data processing agreements and are prohibited from using your data for any purpose other than verification.

6.3 Regulatory Authorities

phcssh is required by law to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other competent Philippine government authorities upon lawful request or as mandated by applicable regulations.

6.4 Technology & Platform Partners

We work with game software providers, cloud hosting services, and cybersecurity partners who may process technical and activity data on our behalf. All such partners are contractually required to maintain data confidentiality and implement appropriate security measures.

6.5 Professional Advisers

phcssh may share data with legal counsel, auditors, and compliance consultants where necessary for the conduct of our business, subject to professional confidentiality obligations.

7 Data Retention

phcssh retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations;
• Gaming activity logs: Retained for three (3) years from the date of the activity, or longer if required for dispute resolution or regulatory purposes;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year for audit purposes;
• Technical and device data: Retained for up to twelve (12) months from collection, unless required for ongoing security investigations.

Upon expiry of the applicable retention period, phcssh will securely delete or anonymise your personal data in accordance with our data disposal procedures.

8 Data Security

phcssh implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the phcssh platform;
• Encryption of sensitive data at rest, including payment credentials and government ID details;
• Role-based access controls ensuring that only authorised phcssh personnel can access personal data, and only to the extent required for their role;
• Regular security assessments, penetration testing, and vulnerability scanning of phcssh systems;
• Multi-factor authentication requirements for administrative access to systems holding personal data;
• Staff training on data privacy obligations and secure data handling practices.

In the event of a personal data breach that is likely to result in harm to affected individuals, phcssh will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA and NPC Circular No. 16-03.

9 Cookies & Tracking Technologies

phcssh uses cookies and similar tracking technologies to operate the platform, remember your preferences, and understand how players use our services. The types of cookies we use are:

9.1 Strictly Necessary Cookies

These cookies are essential for the phcssh platform to function. They enable core features such as session management, login authentication, and security. These cookies cannot be disabled without affecting platform functionality.

9.2 Functional Cookies

Functional cookies remember your preferences — such as your preferred language, display settings, and responsible gaming limits — so you do not have to re-enter them each time you visit phcssh.

9.3 Analytics Cookies

With your consent, phcssh uses analytics cookies to collect aggregated, anonymised data about how players navigate the platform. This information helps us improve the phcssh experience for all Filipino players. You may opt out of analytics cookies at any time through your account settings or browser controls.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phcssh platform. For a full list of cookies used by phcssh, please contact our DPO using the details in Section 14.

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phcssh. You may exercise any of these rights by contacting our Data Protection Officer (see Section 14).

phcssh will respond to all data privacy rights requests within thirty (30) calendar days of receipt. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Minors and Age Restriction

The phcssh platform is strictly intended for persons who are at least 21 years of age, in accordance with Philippine gaming regulations. phcssh does not knowingly collect personal data from individuals under the age of 21.

If phcssh becomes 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 believe that a minor has registered on phcssh, please contact our support team immediately so we can investigate and take appropriate action.

Age verification is conducted as part of the KYC process for all registered accounts. phcssh reserves the right to request proof of age at any time and to suspend accounts pending age verification.

12 Cross-Border Data Transfers

In some cases, phcssh may transfer your personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or international game software suppliers. Where such transfers occur, phcssh ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under the DPA;
• Transfers only to countries or organisations that the National Privacy Commission has recognised as providing adequate data protection;
• Your explicit consent, where required by applicable law.

phcssh will not transfer your personal data internationally in a manner that undermines the protections afforded to you under Philippine law.

13 Changes to This Privacy Policy

phcssh may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes, we will update the "Last Updated" date at the top of this page and notify registered users via email or a prominent in-platform notice.

We encourage you to review this Privacy Policy periodically. Your continued use of the phcssh platform following the posting of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree to the updated policy, you should stop using phcssh and may request account closure in accordance with our Terms & Conditions.

14 Contact & Data Protection Officer

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

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC is the independent authority responsible for administering and implementing the Data Privacy Act of 2012.