phalgo Privacy Policy —
Your Data, Your Rights

1. Introduction

Welcome to the phalgo Privacy Policy. phalgo ("we," "us," "our," "the Company") operates the phalgo platform, including phalgo Casino, all associated games, promotional features, and account services available at phalgo.app.

We understand that your personal data is important to you, and we take our responsibility as a data controller seriously. This Privacy Policy explains in clear terms what personal information phalgo collects from you, the purposes for which we use it, the circumstances under which we may share it, how long we retain it, and the rights you have in relation to your data under Philippine law.

This Privacy Policy applies to all users of the phalgo platform, including registered players, visitors to phalgo.app, and individuals who contact phalgo for support or information. By using phalgo, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy should be read together with the phalgo Terms & Conditions and Responsible Gaming Policy.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, phalgo is the personal information controller in respect of the personal data collected through the phalgo platform.

phalgo has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data protection laws and this Privacy Policy. You may contact the phalgo DPO at any time using the contact details provided in Section 14 of this Policy.

Where phalgo engages third-party service providers to process personal data on our behalf (for example, payment processors or KYC verification providers), those parties act as personal information processors and are contractually bound to process your data only in accordance with phalgo's instructions and applicable law.

3. Personal Data We Collect

phalgo collects personal data through several channels, including account registration, platform use, customer support interactions, and technical systems. The categories of personal data we collect include:

phalgo collects only the personal data that is necessary for the purposes described in this Privacy Policy. We do not collect sensitive personal information beyond what is required for identity verification and regulatory compliance.

4. How We Use Your Personal Data

phalgo uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your phalgo account, including processing your phalgo Login credentials and account settings.
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine anti-money laundering laws.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya / Maya, bank transfers, and debit cards, and to maintain accurate transaction records.
• Game Delivery: To provide access to phalgo Casino games, including slots, bingo, live dealer games, and other gaming products available on the platform.
• Promotions & Bonuses: To administer bonuses, promotions, and loyalty programs, and to communicate relevant offers to eligible players.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct on the phalgo platform.
• Responsible Gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the phalgo platform.
• Marketing Communications: Where you have provided consent, to send you promotional emails, SMS notifications, and platform messages about phalgo offers and new games. You may withdraw this consent at any time.

phalgo 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.

5. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform the contract between you and phalgo — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA obligations, and NPC requirements.
• Legitimate Interests: Processing is necessary for phalgo's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as marketing communications and the use of non-essential cookies — phalgo 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.

6. Data Sharing & Disclosure

phalgo does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya / Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive the financial data necessary to process your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services that assist phalgo in verifying player identities and ages in compliance with PAGCOR and AMLA requirements.
• Game Software Providers: Game developers and studios whose games are available on phalgo Casino may receive anonymized or pseudonymized gaming data necessary to deliver their games.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid legal order, warrant, or court process.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on phalgo's behalf under strict data processing agreements.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third parties with whom phalgo shares personal data are required to implement appropriate technical and organizational security measures and to process your data only in accordance with phalgo's instructions and applicable Philippine law.

7. Cookies & Tracking Technologies

phalgo uses cookies and similar tracking technologies on phalgo.app to enhance your experience, maintain your session, and analyze platform usage. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the operation of the phalgo platform, including maintaining your login session and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and game display options, to personalize your phalgo experience.
• Analytics Cookies: Collect anonymized data about how players use phalgo.app, helping us understand which features are most popular and where improvements can be made.
• Marketing Cookies: Used, with your consent, to deliver relevant promotional content about phalgo offers. You may opt out of marketing cookies at any time via your browser settings or our cookie preference center.

You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phalgo platform. For more information about managing cookies, refer to your browser's help documentation.

8. Data Retention

phalgo retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following retention guidelines:

• Active Account Data: Retained for the duration of your phalgo account and for a minimum of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and AMLA obligations.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by Philippine anti-money laundering regulations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years after account closure or the last transaction, whichever is later.
• Customer Support Records: Support correspondence is retained for three (3) years from the date of the last interaction.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications, after which it is deleted or anonymized within 30 days.

Upon expiry of the applicable retention period, phalgo will securely delete or anonymize your personal data in accordance with our data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected from further processing until deletion is possible.

9. Data Security

phalgo implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and phalgo servers.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls ensuring that phalgo staff can only access personal data necessary for their specific job functions.
• Regular security audits, vulnerability assessments, and penetration testing of phalgo systems.
• Multi-factor authentication requirements for phalgo staff accessing systems containing personal data.
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC notification requirements.
• Regular staff training on data protection obligations and security best practices.

While phalgo takes all reasonable steps to protect your personal data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your phalgo Login credentials and for notifying us immediately if you suspect unauthorized access to your account.

10. Your Data Subject Rights

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

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which this Privacy Policy fulfills.
• Right of Access: The right to request a copy of the personal data phalgo holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your phalgo account settings.
• 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 phalgo'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, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phalgo has violated your data privacy rights.

To exercise any of these rights, please contact the phalgo Data Protection Officer using the contact details in Section 14. phalgo will respond to all data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further 30 days, with prior notification to you.

phalgo may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties.

11. Children's Privacy

The phalgo platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. phalgo does not knowingly collect personal data from individuals under the age of 21.

If phalgo becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on phalgo, please contact us immediately at [email protected].

phalgo employs age verification measures during the registration process and KYC verification to prevent underage access to the platform. Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gambling platforms.

12. Third-Party Links

The phalgo platform may contain links to third-party websites or services for informational purposes. phalgo is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to the phalgo platform at phalgo.app.

We encourage you to review the privacy policies of any third-party websites you visit. phalgo does not endorse or make any representations about third-party websites linked from our platform.

13. Updates to This Privacy Policy

phalgo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, phalgo will notify registered players via email or a prominent notice on the phalgo platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when this Privacy Policy was most recently revised. The current version of this Privacy Policy is always available at phalgo.app/privacy-policy.

Your continued use of the phalgo platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the changes, you may request account closure as described in the phalgo Terms & Conditions.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or phalgo's data processing practices, please contact us:

• Data Protection Officer: [email protected]
• General Support: [email protected]
• Legal & Compliance: [email protected]

phalgo aims to respond to all privacy-related enquiries within fifteen (15) business days. For formal data subject rights requests, the response period is thirty (30) calendar days as described in Section 10.

If you are not satisfied with phalgo's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data protection matters in the Philippines.