phttt Privacy Policy

1. Introduction

1.1 phttt is committed to protecting the privacy and security of your personal data. We understand that Filipino players trust us with sensitive information, and we take that responsibility seriously. This Policy has been prepared in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines.

1.2 This Policy applies to all personal data collected through the phttt website at phttt.asia, the phttt mobile platform, customer support interactions, and any other touchpoint through which you interact with phttt.

1.3 Please read this Policy carefully. If you have any questions or concerns about how phttt handles your personal data, you may contact our Data Protection Officer (DPO) using the details set out in Section 15.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012 and this Policy, phttt is the personal information controller (PIC) in respect of the personal data you provide to us or that we collect about you.

2.2 As a personal information controller, phttt determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

2.3 phttt has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws. Contact details for the DPO are provided in Section 15.

3. Personal Data We Collect

3.1 phttt collects the following categories of personal data:

3.2 phttt does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive personal information is collected, it is processed with heightened security measures and only for the specific purpose for which it was provided.

4. How We Collect Your Data

4.1 phttt collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the phttt platform, including cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Data received from payment processors (e.g., GCash, Maya, BPI, BDO), identity verification service providers, fraud prevention agencies, and regulatory authorities where permitted by law.
• Publicly available sources: Information from public records or databases where relevant to fraud prevention or regulatory compliance.

5. How We Use Your Personal Data

5.1 phttt uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phttt account, including processing your registration and verifying your identity.
• Service delivery: To provide you with access to phttt's gaming products, process deposits and withdrawals in Philippine Peso (₱), and deliver customer support.
• Legal and regulatory compliance: To comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws. This includes conducting KYC checks, filing mandatory reports, and responding to lawful requests from regulatory authorities.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the platform.
• Responsible gaming: To monitor gaming behaviour, identify signs of problem gambling, and administer responsible gaming tools such as deposit limits, self-exclusion, and cooling-off periods.
• Platform improvement: To analyse usage patterns, conduct research, and improve the functionality, performance, and user experience of the phttt platform.
• Marketing communications: To send you promotional offers, bonuses, and news about phttt — but only where you have given your explicit consent to receive such communications. You may withdraw consent at any time.
• Dispute resolution: To investigate and resolve complaints, disputes, and legal claims involving your account.

6. Legal Basis for Processing

6.1 phttt processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and phttt (i.e., to provide you with the gaming services you have registered for).
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements and AMLA obligations.
• Legitimate interests: Processing is necessary for phttt's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookies, processing is based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

7.1 phttt 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:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and debit card processors — to facilitate deposits and withdrawals in PHP.
• Identity verification providers: Third-party KYC and age verification service providers engaged to verify your identity and age in compliance with PAGCOR requirements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government agencies, where required by law or regulatory directive.
• Law enforcement: Philippine law enforcement agencies, where phttt is legally required or permitted to disclose data in connection with the investigation or prosecution of criminal offences.
• IT and platform service providers: Cloud hosting, cybersecurity, analytics, and customer support technology providers engaged by phttt under strict data processing agreements that require them to protect your data.
• Professional advisers: Lawyers, auditors, and accountants engaged by phttt, subject to professional confidentiality obligations.

8. Cookies & Tracking Technologies

8.1 phttt uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the platform, analyse usage, and deliver relevant content.

8.2 The following types of cookies are used on phttt:

• Strictly necessary cookies: Essential for the platform to function. These cannot be disabled as they are required for core features such as login sessions, security, and account management.
• Performance and analytics cookies: Used to collect anonymised data about how players use phttt, helping us identify areas for improvement. These are only set with your consent.
• Functional cookies: Used to remember your preferences (e.g., language, display settings) to personalise your experience.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your explicit consent and can be withdrawn at any time.

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

9. Data Retention

9.1 phttt retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law.

9.2 The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLA requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act.
• KYC and verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support communications: Retained for up to three (3) years from the date of the interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing data: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

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

10. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the phttt platform
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and financial information
• Role-based access controls limiting access to personal data to authorised personnel only
• Regular security assessments, penetration testing, and vulnerability scanning
• Multi-factor authentication for administrative access to systems containing personal data
• Incident response procedures for detecting, reporting, and managing personal data breaches

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

11. Your Rights as a Data Subject

11.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phttt:

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which this Policy fulfils.
• Right of access: The right to request a copy of the personal data phttt holds about you, including information about how it is being used.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, or where processing is unlawful — subject to phttt's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to damages: The right to claim compensation for any damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

11.2 To exercise any of the above rights, please submit a written request to phttt's Data Protection Officer using the contact details in Section 15. phttt will respond to your request within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11.3 phttt may need to verify your identity before processing your request to ensure that personal data is not disclosed to an unauthorised person.

12. Children's Privacy

12.1 phttt is strictly an adult gaming platform. Access is limited to individuals aged twenty-one (21) years and above, in accordance with PAGCOR regulations. phttt does not knowingly collect personal data from individuals under the age of 21.

12.2 If phttt becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately closed, the data will be deleted, and any deposits will be returned less amounts already wagered, in accordance with phttt's Terms & Conditions.

12.3 If you believe that a minor has registered on phttt, please contact our support team immediately using the details in Section 15.

13. Cross-Border Data Transfers

13.1 phttt primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data outside the Philippines (for example, to cloud service providers or technology partners with servers in other countries), phttt will ensure that such transfers are carried out in accordance with the Data Privacy Act of 2012 and NPC guidelines.

13.2 Cross-border transfers will only be made to countries or organisations that provide an adequate level of data protection, or where appropriate safeguards are in place (such as contractual clauses approved by the NPC), or where you have given your explicit consent to the transfer.

14. Updates to This Privacy Policy

14.1 phttt reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

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

14.3 We encourage you to review this Policy periodically to stay informed about how phttt protects your personal data.

15. Contact & Data Protection Officer

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or phttt's data processing practices, please contact our Data Protection Officer:

15.2 If you are not satisfied with phttt's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

15.3 For general customer support enquiries, please visit phttt.asia/faq or contact our support team. For responsible gaming support, please visit phttt.asia/responsible-gaming.