Privacy Policy

This Privacy Policy ("Policy") describes how phlw ("phlw," "we," "us," or "our"), the operator of the online gaming platform at phlw.app, collects, uses, stores, shares, and protects the personal data of its registered players and website visitors ("you" or "your"). This Policy applies to all personal data collected through the phlw website, mobile platform, customer support channels, and any other touchpoints through which you interact with phlw.

phlw is committed to protecting your privacy and processing your personal data in a lawful, fair, and transparent manner. This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC"). phlw is also subject to the data-related requirements of PAGCOR, under whose regulatory framework phlw operates.

This Policy applies to all players registered on phlw, regardless of whether they are located in Metro Manila, Cebu, Davao, Quezon City, Makati, or any other part of the Philippines. It also applies to visitors who browse the phlw website without registering an account.

phlw collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

phlw does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by applicable law or PAGCOR regulations (for example, responsible gaming assessments).

phlw collects your personal data through the following means:

• Direct collection: Data you provide when registering a phlw account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the phlw platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from third-party KYC (Know Your Customer) service providers; fraud prevention data from anti-fraud partners; payment data from GCash, PayMaya, and banking partners.
• Regulatory sources: Data received from PAGCOR or other Philippine government authorities in connection with regulatory compliance obligations.

phlw processes your personal data only for legitimate, specified purposes. The legal bases and corresponding purposes for which phlw processes your data are set out below:

phlw will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

phlw does not sell, rent, or trade your personal data to third parties for their own commercial 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:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and anti-money laundering service providers engaged to verify your identity and comply with PAGCOR and AMLC requirements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or regulation.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and platform technology vendors who process data on phlw's behalf under strict data processing agreements.
• Fraud prevention partners: Third-party fraud detection services used to protect phlw and its players from fraudulent activity.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third parties with whom phlw shares personal data are required to handle that data in accordance with applicable Philippine data privacy laws and are prohibited from using it for any purpose beyond what is strictly necessary.

phlw retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your phlw account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine anti-money laundering regulations.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymised or deleted.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, phlw will securely delete or anonymise your personal data in a manner that prevents reconstruction or identification.

phlw implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the phlw platform.
• Encryption of sensitive data at rest, including financial data and identity verification documents.
• Role-based access controls limiting access to personal data to authorised phlw personnel on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the phlw platform.
• Multi-factor authentication requirements for phlw staff accessing systems that contain personal data.
• Incident response procedures to detect, report, and address personal data breaches in accordance with NPC notification requirements.

While phlw takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your phlw login credentials confidential and for notifying phlw immediately if you suspect any unauthorised access to your account.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by phlw:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data phlw 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 phlw holds about you.
• 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 phlw's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interest.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phlw has violated your data privacy rights.

To exercise any of the above rights, please contact phlw's Data Protection Officer at [email protected]. phlw will respond to all verified requests within thirty (30) days, as required by the Data Privacy Act. phlw may request proof of identity before processing any data subject request.

phlw uses cookies and similar tracking technologies on its platform to enhance your experience, remember your preferences, and analyse how the platform is used. A cookie is a small text file placed on your device when you visit the phlw website.

You can manage or disable cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the phlw platform. For more information on managing cookies, refer to your browser's help documentation.

phlw strictly prohibits the use of its platform by individuals under 21 years of age, in accordance with PAGCOR regulations. phlw does not knowingly collect or process personal data from minors. If phlw becomes aware that personal data has been collected from an individual under 21, that account will be immediately closed and the personal data will be deleted or returned to the appropriate guardian, subject to any legal retention obligations.

If you believe that a minor has registered on the phlw platform or that phlw has inadvertently collected personal data from a minor, please contact phlw support immediately at [email protected] so that appropriate action can be taken without delay.

phlw reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulations, or phlw's data processing practices. Where material changes are made, phlw will notify registered players via the email address or mobile number on file at least fourteen (14) days before the changes take effect.

The effective date at the top of this Policy indicates when it was last updated. Your continued use of the phlw platform following notification of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how phlw protects your personal data.

phlw has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact the phlw DPO using the details below.

If you are not satisfied with phlw's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines, which can be reached through its official government channels.