phhug Privacy Policy

1.1. phhug is committed to protecting the personal data of its players and website visitors in accordance with the Republic Act No. 10173, otherwise known as the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and all relevant issuances by the National Privacy Commission of the Philippines ("NPC").

1.2. This Privacy Policy applies to all personal data collected, processed, stored, or disclosed by phhug in connection with your registration, use of the phhug platform, participation in games, processing of deposits or withdrawals, and any other interaction with the phhug service at phhug.vip.

1.3. This Privacy Policy should be read alongside the phhug Terms & Conditions, which govern your use of the platform. By accepting the Terms & Conditions during registration, you also acknowledge the data practices described in this Privacy Policy.

1.4. This document does not apply to data practices of third-party websites, payment processors, or game providers that you may access through the phhug platform. Those entities operate under their own independent privacy policies, and phhug is not responsible for their data handling practices.

2.1. For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, the personal data controller responsible for your information is phhug, operating the online casino and sports betting platform accessible at phhug.vip.

2.2. phhug is responsible for determining the purposes and means of processing your personal data in connection with the phhug service. Where phhug engages third-party processors to process data on its behalf — such as payment processors and identity verification services — phhug remains the data controller and ensures appropriate contractual safeguards are in place.

2.3. For all privacy-related inquiries, data subject requests, and complaints related to phhug's handling of your personal data, you may contact us at the email address set out in Section 14 of this Privacy Policy.

3.1. phhug collects the following categories of personal data from players and website visitors:

3.2. phhug does not collect sensitive personal information (as defined under the DPA) unless it is strictly necessary to comply with applicable legal obligations, such as anti-money laundering regulations or age and identity verification requirements. Where sensitive information is collected, it is processed under the appropriate legal basis and with heightened security controls.

4.1. phhug collects personal data through the following channels and methods:

• Direct submission by you — when you complete the phhug registration form, submit KYC documents, initiate a deposit or withdrawal, complete responsible gaming questionnaires, or contact the phhug support team;
• Automated technical collection — through cookies, session tracking, and similar technologies as described in Section 9 of this Privacy Policy, which collect technical data about your device and browsing behaviour on the phhug platform;
• Payment processors — when you make a deposit via GCash, Maya, QR Ph, BPI, BDO, or other supported payment methods, phhug receives transaction confirmation data, including reference numbers and account identifiers, from the relevant payment processor;
• Identity verification services — when your KYC documents are processed through phhug's identity verification partners, those partners may return verified identity data and a verification status to phhug;
• Game providers — game session data and round-by-round gaming records may be transmitted to phhug by certified game providers such as JILI, Pragmatic Play, PG Soft, and Evolution Gaming as part of the game delivery infrastructure.

5.1. phhug processes your personal data for the following specific purposes, each supported by an appropriate legal basis under the Philippine Data Privacy Act of 2012:

5.2. Account Registration and Contract Performance

Processing your identity and contact data is necessary to create and maintain your phhug account, and to fulfil our obligations under the phhug Terms & Conditions to which you agreed upon registration. Legal basis: performance of a contract.

5.3. Identity Verification and KYC Compliance

Processing your identity documents and verifying your age (you must be 21 or older to hold a phhug account) and identity is required by applicable Philippine laws, including PAGCOR regulations and anti-money laundering obligations. Legal basis: compliance with a legal obligation.

5.4. Payment Processing

Processing your financial data is necessary to execute deposit and withdrawal transactions via GCash, Maya, QR Ph, and other supported payment methods. Legal basis: performance of a contract and compliance with financial regulatory obligations.

5.5. Fraud Prevention and Security

Technical and gaming data is processed to detect and prevent fraudulent activity, money laundering, multiple account abuse, and other Prohibited Conduct defined in the phhug Terms & Conditions. Legal basis: legitimate interest of phhug and compliance with legal obligations.

5.6. Responsible Gaming Compliance

Gaming behaviour data and responsible gaming tool settings are processed to fulfil phhug's obligations to identify at-risk players, enforce self-exclusion requests, and comply with responsible gaming standards. Legal basis: compliance with a legal obligation and legitimate interest.

5.7. Customer Support

Communication data is processed to investigate and resolve support requests, complaints, and disputes raised by phhug players. Legal basis: performance of a contract and legitimate interest.

5.8. Platform Improvement

Aggregated and anonymised technical and gaming data is used to improve phhug's platform performance, user experience, and game offering. Where data used for this purpose is genuinely anonymised and cannot be re-identified, it falls outside the scope of data protection law. Legal basis: legitimate interest.

6.1. phhug does not sell, rent, or lease your personal data to any third party for their own commercial purposes. We share your data only in the circumstances described in this section, and always under appropriate contractual or regulatory frameworks.

6.2. phhug shares personal data with the following categories of third parties:

• Payment service providers — including GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), GrabPay, BPI, BDO, and other licensed Philippine payment channels — for the purpose of processing your deposit and withdrawal transactions;
• Identity verification partners — third-party KYC service providers engaged to verify the identity and age of phhug players in compliance with applicable regulations;
• Game providers — including JILI, Pragmatic Play, PG Soft, Evolution Gaming, and other certified game studios, who process game session data as part of the game delivery infrastructure and are bound by strict data protection contractual obligations;
• Regulatory authorities — including PAGCOR and the Anti-Money Laundering Council of the Philippines (AMLC), where disclosure is required by law or regulatory mandate;
• Law enforcement and courts — where disclosure is required by a valid court order, subpoena, or other lawful demand from a Philippine law enforcement agency;
• Professional advisers — including lawyers, auditors, and insurers, on a strictly confidential basis and only to the extent necessary for the provision of professional services to phhug.

6.3. All third-party data processors engaged by phhug are required to process data solely for the purposes instructed by phhug, to implement appropriate security measures, and to comply with their obligations under applicable data protection law.

7.1. phhug retains your personal data only for as long as is necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required by applicable Philippine law or regulatory obligation.

7.2. The following retention periods apply to the main categories of personal data held by phhug:

• Account and identity data: retained for the duration of your active phhug account plus five (5) years following account closure, in compliance with Philippine anti-money laundering record-keeping requirements;
• KYC documentation: retained for five (5) years from the date of verification, or from the date of account closure if later, in accordance with AMLC and PAGCOR requirements;
• Financial transaction records: retained for five (5) years following each transaction, consistent with Philippine financial regulatory requirements;
• Gaming records: retained for three (3) years from the date of each game session, or for the full duration of any related dispute resolution process if longer;
• Support communications: retained for two (2) years from the date of the last communication in the relevant support thread;
• Technical and cookie data: session cookies expire at the end of each browsing session; persistent cookies and analytical data are retained for up to twenty-four (24) months.

7.3. Where personal data is no longer required and no legal obligation requires its continued retention, phhug will securely delete or anonymise it in a manner that prevents reconstruction or re-identification.

8.1. phhug implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures are designed to reflect the risk associated with each category of personal data processed.

8.2. The security measures employed by phhug include, but are not limited to, the following:

• 256-bit SSL/TLS encryption on all pages of the phhug platform, including the phhug login page, deposit and withdrawal interfaces, and any page that transmits personal data;
• Password hashing using industry-standard cryptographic algorithms — phhug does not store plaintext passwords, and phhug employees cannot retrieve your password under any circumstances;
• Access controls restricting access to personal data held by phhug to authorized personnel who have a legitimate operational need to access that data;
• Two-factor authentication available for all phhug player accounts, providing an additional layer of protection against unauthorized account access;
• Regular security testing and audits of the phhug platform infrastructure and data handling processes;
• Incident response procedures enabling phhug to detect, contain, and report personal data breaches in accordance with NPC notification requirements under the DPA.

8.3. While phhug implements robust security measures, no digital platform can guarantee absolute security. Players are encouraged to use strong, unique passwords for their phhug accounts, enable two-factor authentication, and contact phhug immediately at [email protected] if they suspect unauthorized access to their account.

9.1. phhug uses cookies and similar tracking technologies on the phhug platform. A cookie is a small text file placed on your device when you visit a website, enabling the site to recognise your device and remember certain information about your visit.

9.2. phhug uses the following categories of cookies:

• Strictly necessary cookies: Required for the phhug platform to function correctly. These include session cookies that maintain your login state, preference cookies that remember your account settings, and security cookies that help prevent fraudulent use of the platform. These cookies cannot be disabled without significantly impairing your ability to use phhug;
• Analytics and performance cookies: Used to collect aggregated, anonymised information about how visitors use the phhug platform — including which pages are visited most frequently and whether players encounter errors. This information is used to improve phhug's platform performance;
• Functional cookies: Used to remember choices you have made on the phhug platform, such as your preferred language, game category, or display settings, to provide a more personalised experience.

9.3. You may configure your browser to block cookies or delete existing cookies from your device. However, please note that disabling strictly necessary cookies will impair your ability to log in and use the phhug platform. Instructions for managing cookies vary by browser and can typically be found in your browser's settings or help documentation.

9.4. phhug does not use third-party advertising cookies or permit third-party advertisers to place tracking cookies on the phhug platform.

10.1. Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by phhug. To exercise any of these rights, please contact us as described in Section 14.

10.2. Right to be Informed. You have the right to be informed about how phhug processes your personal data. This Privacy Policy is the primary means by which phhug fulfils this obligation.

10.3. Right to Access. You have the right to request a copy of the personal data that phhug holds about you, along with information about how it is processed. phhug will respond to verified access requests within fifteen (15) working days.

10.4. Right to Rectification. If any personal data held by phhug about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update certain account details directly through your phhug account settings.

10.5. Right to Erasure. You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been unlawfully processed. This right is subject to phhug's legal retention obligations — data required to be retained under Philippine law cannot be deleted prior to the expiry of the applicable retention period.

10.6. Right to Object. You have the right to object to processing of your personal data based on phhug's legitimate interests where there are grounds relating to your particular situation. You also have the right to object at any time to processing of your data for direct marketing purposes.

10.7. Right to Data Portability. Where technically feasible and where processing is based on consent or contract, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.

10.8. Right to Lodge a Complaint. If you believe that phhug has processed your personal data in violation of the Philippine Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Contact information for the NPC is available on the NPC's official website.

11.1. The phhug platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with Philippine gaming regulations administered by PAGCOR.

11.2. phhug does not knowingly collect, process, or retain personal data belonging to individuals under the age of 21. If phhug becomes aware that personal data has been submitted by an individual under 21, that data will be immediately deleted, the associated account will be suspended, and any funds associated with the account will be handled in accordance with applicable regulations.

11.3. Age verification is conducted during the KYC process for all phhug accounts. phhug reserves the right to request documentary proof of age at any stage of the account lifecycle.

12.1. Some of phhug's third-party service providers — including game providers such as Evolution Gaming and Pragmatic Play — may be located outside the Philippines and may process player data on servers located in other jurisdictions.

12.2. Where personal data is transferred outside the Philippines, phhug ensures that appropriate safeguards are in place to protect the data to a standard at least equivalent to that required under the Philippine Data Privacy Act of 2012. These safeguards include contractual data protection clauses in phhug's agreements with overseas processors.

12.3. By using the phhug platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines for the purposes described in this Privacy Policy.

13.1. phhug may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable Philippine law, or changes to the phhug platform and services offered.

13.2. Where changes are material — meaning they significantly affect how phhug uses your personal data or your rights as a data subject — phhug will provide at least fourteen (14) days' advance notice to registered players via the email address on record before the changes take effect.

13.3. The "Last Updated" date at the top of this Privacy Policy and in the page header indicates when the most recent version came into effect. We encourage you to review this Privacy Policy periodically to stay informed about how phhug protects your data.

13.4. Continued use of the phhug platform after the effective date of an updated Privacy Policy constitutes acceptance of the revised policy. If you do not agree to a material change, you should contact phhug to discuss your options, including account closure in accordance with the phhug Terms & Conditions.

14.1. If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or have a complaint about phhug's handling of your personal data, please contact the phhug data privacy team using the contact details below.

14.2. phhug has designated a Data Privacy Officer ("DPO") as required under Section 21 of the Philippine Data Privacy Act of 2012. The DPO is responsible for overseeing phhug's compliance with data protection obligations and serves as the primary point of contact for data subject inquiries.

14.3. Contact for data privacy matters:

14.4. If you are not satisfied with phhug's response to your privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines, which serves as the regulatory authority for data protection matters in the Philippines.

14.5. phhug encourages players to raise privacy concerns directly with us in the first instance so that we have the opportunity to investigate and resolve the matter promptly before escalation to the NPC becomes necessary.