phdram Casino Privacy Policy

1Who We Are — The Data Controller

phdram Casino ("phdram," "we," "us," or "the Company") is the personal information controller responsible for the personal data collected and processed through phdram.app and all related services. phdram operates as a PAGCOR-licensed online casino and sports betting platform serving players across the Philippines.

As a personal information controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA"), phdram determines the purposes for which, and the means by which, personal data is processed. phdram has appointed a Data Protection Officer (DPO) who may be contacted at the details provided in Section 14 of this Policy.

2Personal Data We Collect

phdram collects personal data in the following categories depending on your relationship with the platform:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — you must be 21 or older to use phdram);
• Email address and/or Philippine mobile number (Globe or Smart);
• Username and encrypted password;
• Nationality and country of residence.

2.2 KYC & Verification Data

• Copies of government-issued Philippine identification documents (PhilSys ID, Driver's License, Passport, UMID, Voter's ID, or PRC ID);
• Selfie photographs submitted for liveness checks;
• Proof of address documents where required for enhanced due diligence;
• Source of funds declarations where required by PAGCOR or AMLA regulations.

2.3 Financial & Transaction Data

• GCash account number or registered mobile number;
• PayMaya account details;
• Bank account details for BDO, BPI, or Metrobank transfers;
• USDT wallet addresses for cryptocurrency transactions;
• Full transaction history including deposit amounts, withdrawal amounts, dates, and reference numbers;
• Wagering history and game session records.

2.4 Technical & Device Data

• IP address and approximate geographic location derived from IP;
• Device type, operating system, and browser version;
• Login timestamps and session duration;
• Pages visited within phdram.app and navigation patterns;
• Cookie identifiers and similar tracking technologies (see Section 7).

2.5 Communications Data

• Content of support chat conversations with phdram agents;
• Email correspondence sent to phdram support;
• Records of any complaints or formal dispute submissions;
• Marketing consent preferences and communication opt-in/opt-out records.

3How We Collect Your Data

phdram collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make deposits or withdrawals, place bets, contact support, or update your account profile;
• Automatically — through cookies, server logs, and session tracking technology when you access phdram.app (see Section 7);
• From payment providers — GCash, PayMaya, BDO, BPI, and Metrobank may share transaction confirmation data with phdram as part of payment processing;
• From identity verification services — third-party KYC and document verification providers used by phdram may share verification results and fraud risk signals;
• From regulatory and government authorities — PAGCOR, the AMLC, or other Philippine government agencies may provide or require disclosure of certain data as part of phdram's regulatory obligations.

4Why We Use Your Personal Data

The table below maps each category of personal data to the specific purpose for which phdram processes it:

5Legal Basis for Processing

Under the Philippine Data Privacy Act, phdram processes personal data only where it has a lawful basis to do so. The legal bases phdram relies on are:

• Performance of a contract — processing necessary to provide the phdram platform, process your deposits and withdrawals, manage your account, and deliver gaming services you have registered to receive;
• Compliance with a legal obligation — processing required by PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), the Tax Code, and other Philippine laws applicable to phdram's operations;
• Legitimate interests — fraud prevention, platform security, and aggregated analytics that do not override your fundamental rights as a data subject;
• Consent — marketing communications and the use of non-essential cookies, where you have given your explicit, freely given, and specific consent. Consent may be withdrawn at any time without detriment to your account.

6Sharing Your Personal Data

phdram does not sell your personal data to third parties. We share data only in the following circumstances and only to the extent necessary for each purpose:

6.1 PAGCOR and Philippine Regulatory Authorities

phdram is required by its PAGCOR license to submit periodic reports and respond to regulatory inquiries that may include player account data, transaction records, and responsible gaming metrics. Disclosure to PAGCOR is a legal obligation that does not require your separate consent.

6.2 Anti-Money Laundering Council (AMLC)

Under the Anti-Money Laundering Act, phdram is required to file Covered Transaction Reports (CTRs) for transactions meeting statutory thresholds, and Suspicious Transaction Reports (STRs) where transactions display characteristics specified in AMLC regulations. These reports are filed without prior notice to the account holder where legally required.

6.3 Payment Service Providers

GCash (Mynt – Globe Fintech Innovations, Inc.), PayMaya (Voyager Innovations), BDO, BPI, Metrobank, and USDT network providers receive only the minimum data necessary to process your specific transaction. These providers operate under their own privacy policies and are bound by data processing agreements with phdram.

6.4 KYC and Fraud Prevention Services

phdram engages third-party identity verification and fraud screening providers to assist with KYC obligations. These providers process identity documents and verification data solely for the purpose of verifying your identity and are not permitted to use your data for any other purpose.

6.5 Game Content Providers

Game studios whose titles are available on phdram Casino (including Pragmatic Play, PG Soft, Jili, Habanero, and others) receive only technical session identifiers required to deliver game content. They do not receive your name, financial information, or contact details unless required for their own regulatory compliance.

6.6 Law Enforcement and Courts

phdram will disclose personal data to Philippine law enforcement agencies, courts, or other government authorities when required to do so by a valid legal order, warrant, or obligation, or where phdram reasonably believes disclosure is necessary to prevent criminal activity, protect user safety, or enforce its Terms and Conditions.

7Cookies & Tracking Technologies

phdram uses cookies and similar technologies on phdram.app to ensure the platform functions correctly, to secure your session after phdram login, and to understand how players interact with the site so we can improve it.

7.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged into your phdram account and security tokens that protect against CSRF attacks. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limit displays, and last-visited game category. Disabling these will not prevent you from using phdram but may reduce convenience.
• Analytics Cookies: Used to understand aggregate user behavior — pages visited, session durations, and error rates — to help phdram improve platform performance. Analytics data is aggregated and not linked to individual accounts. These require your consent.
• Marketing Cookies: Used only with your explicit consent to track interactions with phdram promotions. phdram does not serve third-party advertising on its platform.

7.2 Cookie Management

You may manage non-essential cookies through the cookie preference center accessible via the phdram.app cookie banner on your first visit, or through your browser settings. Note that disabling strictly necessary cookies will prevent your phdram account session from functioning correctly.

8Data Retention

phdram retains personal data for the minimum period necessary to fulfill the purpose for which it was collected, subject to overriding legal retention obligations:

Upon expiry of the applicable retention period, personal data is either securely deleted using industry-standard data destruction methods or irreversibly anonymized so that it can no longer be attributed to any individual.

9Security Measures

phdram implements a layered set of technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. These include:

• TLS 1.3 encryption for all data transmitted between your device and phdram.app;
• AES-256 encryption for personal and financial data stored in phdram's databases;
• Role-based access controls (RBAC) ensuring that phdram staff can only access data necessary for their specific job function;
• Multi-factor authentication required for all phdram administrative access to production systems;
• Regular independent security audits and penetration testing conducted by third-party cybersecurity firms;
• Intrusion detection systems and 24/7 security monitoring of phdram's platform infrastructure;
• Data breach response procedure aligned with NPC notification requirements — affected users will be notified within 72 hours of confirmed breach discovery where the breach poses a significant risk to their rights.

10Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phdram. These rights can be exercised at any time by contacting phdram's Data Protection Officer at the details in Section 14.

To exercise any of the above rights, submit a written request to phdram's Data Protection Officer using the contact details in Section 14. phdram may ask you to verify your identity before processing your request. There is no charge for making a request, though phdram may charge a reasonable administrative fee for manifestly unfounded or excessive requests.

11Children's Privacy — 21+ Requirement

phdram Casino is strictly for adults aged 21 years and above in compliance with PAGCOR's regulations for online gaming in the Philippines. phdram does not knowingly collect, use, or store the personal data of individuals under the age of 21. Age is verified through the KYC process required before withdrawal processing.

If phdram discovers that personal data has been collected from a person who is under 21 years of age, the associated Account will be immediately suspended, any deposits refunded where legally permissible, and all personal data of the minor securely deleted in accordance with the Data Privacy Act. Attempts to misrepresent age during registration will be treated as a material breach of phdram's Terms and Conditions.

12Cross-Border Data Transfers

phdram is a Philippines-focused platform and stores primary account and transaction data on servers located in the Philippines. Certain third-party service providers — including international game content studios and technology infrastructure providers — may be located outside the Philippines. Where personal data is transferred outside the Philippines, phdram ensures that:

• The recipient country or organization provides an adequate level of protection for personal data as recognized by the National Privacy Commission;
• Appropriate contractual safeguards (standard contractual clauses or equivalent) are in place between phdram and the recipient; or
• The transfer falls within a recognized exception under Section 21 of the Data Privacy Act, including where the transfer is necessary for the performance of your contract with phdram.

You may contact phdram's Data Protection Officer to obtain information about the specific safeguards applied to any cross-border data transfer that affects your personal information.

13Changes to This Privacy Policy

phdram may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or the phdram platform. Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — phdram will notify registered users via email (to your registered email address) or via an in-platform notification at least seven (7) days before the updated Policy takes effect.

Non-material updates (such as correcting typographical errors or clarifying existing practices without changing them substantively) may be made without prior notification. The "Effective" date at the top of this page will always reflect when this Policy was last updated. Continued use of the phdram platform after an updated Policy takes effect constitutes acceptance of the revised terms.

Previous versions of this Privacy Policy are available upon request from phdram's Data Protection Officer.

14Contact Our Data Protection Officer

For any queries, concerns, or requests relating to this Privacy Policy or phdram's handling of your personal data, please contact phdram's Data Protection Officer through the following channels: