phdreem Privacy Policy

1.1 phdreem is a Philippines-focused online gaming platform offering slots, live casino, sports betting, sabong, and bingo to registered Filipino players. References to "phdreem," "we," "us," or "our" in this Privacy Policy refer to the phdreem platform and its operating entity.

1.2 phdreem acts as the data controller in respect of the personal data it collects from players and visitors. As data controller, phdreem determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 and its implementing rules and regulations.

1.3 If you have any questions about how phdreem handles your personal data, you may contact our Data Protection Officer at the email address provided in Section 12 of this policy.

2.1 Registration Data. When you create a phdreem account, we collect the information you provide during the registration process, including your full name, date of birth, email address, mobile number, and residential address. This information is required to create and maintain your account.

2.2 Identity Verification Data. To comply with our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, phdreem may request copies of government-issued identification documents such as a PhilSys card, passport, driver's license, SSS ID, or GSIS ID. We may also request proof of address and, in some cases, proof of source of funds.

2.3 Financial Data. When you make deposits or withdrawals, phdreem collects transaction data including payment method details (such as GCash account numbers, PayMaya account details, BPI, BDO, or Metrobank account information), transaction amounts in Philippine Peso (PHP / ₱), and transaction timestamps. phdreem does not store full card numbers or banking credentials.

2.4 Gaming Activity Data. phdreem records your gaming activity on the platform, including games played, bets placed, outcomes, session durations, and bonus usage. This data is used to provide our services, detect fraud, and support responsible gaming initiatives.

2.5 Technical Data. When you access phdreem, we automatically collect certain technical information, including your IP address, device type, operating system, browser type and version, and referring URLs. This data helps us maintain platform security and improve user experience.

2.6 Communications Data. If you contact phdreem's customer support team via live chat, email, or any other channel, we retain records of those communications, including the content of your messages and any attachments you provide.

2.7 Responsible Gaming Data. If you use phdreem's responsible gaming tools — such as deposit limits, session reminders, cooling-off periods, or self-exclusion — we record your preferences and the dates on which these tools were activated or modified.

3.1 phdreem uses the personal data it collects for the following purposes:

• Account Management: To create, maintain, and administer your phdreem account, including processing your registration, verifying your identity, and managing your account settings;
• Service Delivery: To provide you with access to phdreem's games, process your deposits and withdrawals, and deliver the gaming experience you expect from the platform;
• KYC and AML Compliance: To verify your identity, assess the source of your funds, and comply with our obligations under Philippine anti-money laundering laws and PAGCOR-aligned regulatory requirements;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the phdreem platform and its players;
• Responsible Gaming: To monitor gaming patterns that may indicate problem gambling behavior, to administer responsible gaming tools you have activated, and to enforce self-exclusion requests;
• Customer Support: To respond to your enquiries, 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 withdraw this consent at any time through your account settings;
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, content, and user experience of the phdreem platform;
• Legal Compliance: To comply with applicable Philippine laws, regulations, and court orders, and to respond to requests from regulatory authorities including PAGCOR.

4.1 phdreem processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and phdreem — specifically, to provide you with access to the platform and its services;
• Legal Obligation: Processing is necessary to comply with phdreem's legal obligations under Philippine law, including KYC, AML, and data retention requirements;
• Legitimate Interests: Processing is necessary for phdreem's legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided those interests are not overridden by your rights and interests;
• Consent: For marketing communications and certain non-essential cookies, phdreem relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

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

• Payment Processors: We share financial data with payment service providers such as GCash, PayMaya, BPI, BDO, and Metrobank to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations;
• Identity Verification Providers: We may share identity documents with third-party KYC verification services to confirm your identity and comply with our regulatory obligations;
• Game Providers: Where phdreem offers games developed by third-party providers, limited gaming activity data may be shared with those providers for the purpose of delivering the game and detecting cheating or fraud;
• Regulatory Authorities: phdreem may disclose your personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory bodies where required by law or regulation;
• Law Enforcement: phdreem will disclose personal data to Philippine law enforcement authorities where required by a valid court order, subpoena, or other legal process;
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of phdreem's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

5.2 All third parties with whom phdreem shares personal data are required to handle that data in accordance with applicable Philippine data protection law and phdreem's data processing standards.

6.1 phdreem uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and deliver relevant content. Cookies are small text files stored on your device when you visit phdreem.

6.2 phdreem uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings and responsible gaming tool configurations;
• Analytics Cookies: Help phdreem understand how players use the platform so we can improve it. These are only set with your consent;
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

6.3 You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the phdreem platform.

7.1 phdreem retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law. Specifically:

• Account and identity verification data is retained for a minimum of five (5) years following account closure, in accordance with AMLC record-keeping requirements;
• Transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Customer support communications are retained for two (2) years from the date of the last communication;
• Marketing consent records are retained for the duration of your account and for two (2) years following account closure.

7.2 Where phdreem is required to retain data for longer periods by law or regulation, the longer retention period will apply. Upon expiry of the applicable retention period, phdreem will securely delete or anonymize your personal data.

8.1 As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phdreem:

• Right to be Informed: The right to know what personal data phdreem collects about you and how it is used;
• Right of Access: The right to request a copy of the personal data phdreem holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: 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 phdreem's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phdreem has violated your data privacy rights.

8.2 To exercise any of these rights, please contact phdreem's Data Protection Officer using the contact details in Section 12. phdreem will respond to all data subject requests within thirty (30) days of receipt.

9.1 phdreem implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phdreem platform;
• Encryption of sensitive data at rest, including identity documents and financial records;
• Access controls limiting phdreem staff access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of the phdreem platform;
• Two-factor authentication options for player accounts.

9.2 While phdreem takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phdreem will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act.

10.1 phdreem is strictly an adult gaming platform. We do not knowingly collect personal data from persons under 21 years of age. The minimum age to register and use phdreem is 21 years, in accordance with Philippine law governing online casino gaming.

10.2 If phdreem becomes aware that it has inadvertently collected personal data from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any winnings accrued by an underage player will be forfeited in accordance with phdreem's Terms and Conditions.

10.3 If you believe that a minor has registered a phdreem account, please contact us immediately at the email address in Section 12.

11.1 phdreem may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

11.2 Where changes to this Privacy Policy are material, phdreem will notify registered players by email or via an in-platform notification prior to the changes taking effect. Your continued use of phdreem following the effective date of any update constitutes your acceptance of the revised Privacy Policy.

11.3 We encourage you to review this Privacy Policy periodically to stay informed about how phdreem protects your personal data.

12.1 If you have any questions, concerns, or requests relating to this Privacy Policy or phdreem's handling of your personal data, please contact our Data Protection Officer:

Email: [email protected]

12.2 phdreem's Data Protection Officer will acknowledge your enquiry within five (5) business days and will endeavour to resolve all data privacy matters within thirty (30) days of receipt.

12.3 If you are not satisfied with phdreem's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.