phcku Privacy
Policy

1 Introduction and Scope

phcku Casino operates an online gaming platform serving players in the Republic of the Philippines. As part of our service delivery, phcku processes personal data belonging to our registered users and visitors to phcku.cam. This Privacy Policy applies to all personal data collected by phcku through:

• The phcku website at phcku.cam and all associated subdomains.
• The phcku account registration and login process.
• All gameplay, wagering, and transactional activity conducted on the phcku platform.
• Communications between you and phcku via live chat, email, or other support channels.
• Your interactions with phcku promotional materials, whether on-platform or via email/SMS.

This Privacy Policy does not cover personal data collected by third-party service providers that phcku may link to (such as payment processors like GCash or Maya) — those providers operate under their own privacy policies. However, phcku carefully selects service providers who demonstrate appropriate data protection standards.

2 Personal Data We Collect

phcku collects several categories of personal data in order to operate the platform, verify your identity, process transactions, and comply with legal obligations. The specific data we collect includes:

2.1 Account Registration Data

When you create a phcku account, you provide the following information directly to us:

• Full legal name (as it appears on your government-issued ID).
• Date of birth (to verify that you meet the minimum age requirement of 21 years).
• Philippine mobile number (used for account verification and communication).
• Email address (used for account recovery and important account notifications).
• Username and password (self-selected credentials for account access).
• Mailing address or residential address (for verification purposes and as required for KYC compliance).

2.2 Identity Verification (KYC) Data

Before processing your first withdrawal, phcku is legally required to verify your identity through a Know Your Customer (KYC) process. During KYC verification, you submit:

• A clear photograph or scan of a valid Philippine government-issued ID (examples: passport, driver's license, SSS ID, UMID, PhilHealth ID, or Philippine postal ID).
• A recent photograph of yourself (selfie) holding your ID, used to confirm that the ID belongs to you.
• Proof of address document (optional, but may be requested for higher withdrawal limits) such as a utility bill or bank statement showing your name and Philippine address.

2.3 Transaction and Payment Data

When you make deposits or withdrawals, phcku collects and processes:

• Payment method details (GCash mobile number, Maya account identifier, or bank account number for BPI/BDO/Metrobank transfers).
• Transaction amounts, timestamps, and payment processor reference codes.
• Transaction history records showing all deposits, withdrawals, wagers, and account balance adjustments.

phcku does not store your full payment card numbers or CVV codes. Payment processing is handled by third-party payment processors (GCash, Maya, Philippine banks) who operate under their own PCI-DSS compliant security frameworks.

2.4 Gameplay and Platform Usage Data

While you use the phcku platform, phcku automatically collects technical and behavioral data including:

• IP address and approximate geographic location (city/region level only, not precise coordinates).
• Device information: operating system, browser type and version, screen resolution, device model.
• Gameplay activity: games played, bet amounts, win/loss records, session duration, game outcomes.
• Login and authentication logs: timestamps of login/logout events, devices used, and authentication success/failure records.
• Platform navigation: pages visited, features accessed, click patterns (collected via cookies and similar tracking technologies).

2.5 Communications Data

When you contact phcku support via live chat or email, phcku retains:

• Transcripts of chat conversations and copies of email correspondence.
• Support ticket history, issue descriptions, and resolution notes.
• Any files, screenshots, or documents you voluntarily submit as part of a support inquiry.

3 How We Use Your Personal Data

phcku processes your personal data for the following specific purposes, each of which is necessary for the operation of the phcku platform or required by law:

3.1 Account Management and Service Delivery

• To create, maintain, and authenticate your phcku account.
• To provide access to phcku's games, live casino tables, bingo rooms, and other platform features.
• To process deposits and withdrawals to and from your phcku wallet.
• To maintain accurate records of your account balance, transaction history, and gameplay activity.
• To communicate with you regarding account status, transaction confirmations, and platform updates.

3.2 Legal and Regulatory Compliance

• To verify that you meet the minimum age requirement of 21 years as mandated by Philippine gaming regulations.
• To conduct KYC identity verification as required by PAGCOR regulations and Philippine anti-money laundering laws.
• To detect and prevent fraudulent activity, money laundering, and other illegal conduct on the phcku platform.
• To comply with lawful requests from Philippine regulatory authorities, law enforcement, or courts of competent jurisdiction.
• To generate reports and maintain records as required by PAGCOR, the National Privacy Commission, and other Philippine regulatory bodies.

3.3 Platform Security and Fraud Prevention

• To monitor for suspicious account activity, including unauthorized access attempts, bonus abuse, collusion, and coordinated fraud.
• To implement and enforce phcku's Terms & Conditions, including restrictions on duplicate accounts and prohibited conduct.
• To maintain audit logs and transaction records that can be reviewed in the event of a dispute or security incident.

3.4 Customer Support and Issue Resolution

• To respond to your inquiries, complaints, and support requests submitted via live chat or email.
• To investigate and resolve disputes related to gameplay outcomes, payment issues, or account restrictions.
• To improve the quality and responsiveness of phcku's support services based on historical support interaction data.

3.5 Responsible Gaming and Player Protection

• To implement and enforce responsible gaming tools such as deposit limits, session time alerts, cooling-off periods, and self-exclusion.
• To identify patterns of behavior that may indicate problem gambling and to intervene with appropriate responsible gaming resources when necessary.
• To honor your requests for voluntary account restrictions or permanent self-exclusion.

3.6 Marketing and Promotional Communications (Optional)

• To send you information about phcku promotions, bonuses, new game releases, and special events — but only if you have explicitly opted in to receive marketing communications.
• To personalize promotional offers based on your gameplay preferences and account history (where consent has been provided).

4 Legal Basis for Processing

Under the Philippine Data Privacy Act, phcku must have a lawful basis for processing your personal data. phcku relies on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and phcku (the Terms & Conditions) and to deliver the gaming services you have requested. This includes account creation, payment processing, and gameplay functionality.
• Legal Obligation: Processing is necessary for phcku to comply with legal obligations imposed by Philippine law, including KYC verification requirements, anti-money laundering regulations, and age verification mandates under gaming law.
• Legitimate Interests: P rocessing is necessary for phcku's legitimate interests in operating a secure, fraud-free gaming platform, including security monitoring, fraud detection, dispute resolution, and the enforcement of platform rules — provided these interests are not overridden by your fundamental rights and data protection interests.
• Consent: Where phcku relies on your consent as the legal basis for processing (primarily for optional marketing communications and certain cookies), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

5 Sharing Your Personal Data

phcku does not sell, rent, or trade your personal data to third parties for their own commercial purposes. phcku shares your personal data only in the following limited and controlled circumstances:

• Payment Processors: phcku shares necessary transaction data with payment service providers (GCash, Maya, BPI, BDO, Metrobank, GrabPay) to facilitate deposits and withdrawals. These providers receive only the minimum data required to execute your payment instruction.
• Identity Verification Providers: phcku may engage accredited third-party KYC and identity verification service providers to assist in processing and validating your identity documents. These providers process your KYC data solely for verification purposes and are contractually prohibited from using it for any other purpose.
• Technology and Infrastructure Partners: phcku uses cloud hosting, platform infrastructure, and game content providers to operate the phcku platform. These providers access your data only to the extent necessary to deliver their technical services to phcku and are bound by strict data processing agreements.
• Regulatory and Law Enforcement Authorities: phcku is required by Philippine law to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or law enforcement agencies upon receipt of a lawful request, court order, or regulatory directive. phcku will notify affected users of such disclosures where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of phcku's assets, your personal data may be transferred to the successor entity as part of that transaction. phcku will notify you in advance of any such transfer and ensure that the successor entity is bound by privacy obligations no less protective than those set out in this policy.

6 Data Security Measures

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

• Encryption: All data transmitted between your device and the phcku platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest — including identity documents and payment details — is encrypted using AES-256 or equivalent symmetric encryption.
• Access Controls: Access to personal data within phcku's systems is governed by a strict role-based access control framework. Only staff members whose specific job function requires access to particular data categories are authorized to view that data. All access events are logged for audit purposes.
• Two-Factor Authentication: phcku enforces two-factor authentication for all internal staff access to systems containing personal data. Players are also strongly encouraged to enable 2FA on their phcku accounts.
• Security Monitoring: phcku's platform is monitored continuously for suspicious activity patterns, intrusion attempts, and anomalous data access events. Security incidents are escalated to phcku's compliance team for immediate investigation.
• Vendor Security Assessments: Third-party service providers who process personal data on phcku's behalf are required to demonstrate appropriate security certifications and standards before being engaged, and are subject to ongoing security review.
• Data Breach Response: phcku maintains a documented incident response procedure for data breaches. In the event of a breach that poses a risk to your rights and freedoms, phcku will notify the National Privacy Commission within 72 hours of discovery and will notify affected users without undue delay as required by Philippine law.

Notwithstanding these measures, no online platform can guarantee absolute security. phcku cannot warrant that your data will never be accessed, disclosed, or altered by a third party acting in breach of phcku's security framework. You are encouraged to protect your own account security by using a strong unique password and enabling two-factor authentication.

7 Data Retention

phcku retains your personal data for as long as is necessary to fulfill the purposes described in this Privacy Policy and to comply with applicable legal obligations. The following retention periods apply:

• Active Account Data: Personal data associated with your phcku account is retained for the duration of your account's active status plus a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations and gaming record-keeping obligations.
• KYC Identity Documents: Copies of identity documents submitted during KYC verification are retained for a minimum of five (5) years following the closure or termination of your account in accordance with PAGCOR and AMLC regulatory requirements.
• Transaction Records: Financial transaction records (deposits, withdrawals, wager history) are retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and its implementing regulations.
• Support Communications: Chat transcripts and email correspondence are retained for three (3) years from the date of each communication to support dispute resolution and service quality review purposes.
• Marketing Data: Where you have provided consent for marketing communications, phcku retains your marketing preferences and related contact data until you withdraw consent or for a maximum of three (3) years from your last active engagement with a marketing communication, whichever comes first.
• Technical Logs: Server access logs and security event logs are retained for a minimum of twelve (12) months for security monitoring and incident investigation purposes.

Upon expiry of the applicable retention period, phcku will securely delete or anonymize your personal data so that it can no longer be associated with you as an identifiable individual. Anonymized, aggregated data may be retained indefinitely for statistical and analytical purposes.

8 Your Data Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phcku. phcku will respond to all verified data rights requests within thirty (30) days of receipt:

• Right to Be Informed: You have the right to be informed of the fact that your personal data is being processed by phcku, and to receive clear information about the purposes, scope, and methods of that processing — which this Privacy Policy provides.
• Right of Access: You have the right to request a copy of the personal data phcku holds about you, together with information about how that data is being used. You may exercise this right by submitting a written request to [email protected].
• Right to Rectification: If any personal data phcku holds about you is inaccurate or incomplete, you have the right to request correction or completion of that data. For account details, many corrections can be made directly through your phcku account settings; others may require identity verification.
• Right to Erasure or Blocking: You have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and there is no other legal basis for processing. Note that phcku may be legally required to retain certain data even following an erasure request.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that phcku transmit this data to another data controller where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. Upon receipt of a valid objection, phcku will cease processing your data for marketing purposes immediately.
• Right to Lodge a Complaint: If you believe that phcku has not handled your personal data in accordance with the Data Privacy Act, you have the right to file a complaint with the National Privacy Commission of the Philippines.

9 Cookies and Tracking Technologies

phcku uses cookies and similar tracking technologies on phcku.cam to operate the platform, remember your preferences, analyze platform usage, and support security functions. A "cookie" is a small text file placed on your device by your web browser when you visit phcku.cam.

phcku uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the phcku platform to function and cannot be disabled. They include session authentication cookies that keep you logged in during your visit, security tokens that protect against cross-site request forgery, and load-balancing cookies that route your requests to the correct server.
• Functional Cookies: These cookies remember your preferences and settings to improve your experience — for example, your preferred language, game display settings, and lobby layout preferences. They are not used for advertising purposes.
• Analytics Cookies: These cookies collect anonymized information about how players use phcku.cam, which pages are visited most frequently, and where users encounter errors. This data helps phcku improve the platform experience. Analytics cookies do not identify you personally.
• Session Security Cookies: These cookies are used by phcku's fraud detection and responsible gaming systems to identify unusual session patterns, detect automated access attempts, and enforce responsible gaming session limits.

You may configure your browser to reject or delete cookies. However, disabling strictly necessary cookies will prevent the phcku platform from functioning correctly — in particular, you will not be able to stay logged in or complete financial transactions without session cookies enabled.

10 Children's Privacy and Age Restrictions

The phcku platform is strictly intended for adults aged 21 years and above, consistent with Philippine gaming law. phcku does not knowingly collect personal data from individuals under the age of 21.

phcku takes active steps to prevent underage access, including mandatory age declaration during registration and KYC identity verification before processing any withdrawal. If phcku discovers or has reasonable grounds to believe that a registered account belongs to or has been used by a person under the age of 21, phcku will:

• Immediately suspend the account pending investigation.
• Delete all personal data associated with the underage user as soon as practicable following the investigation.
• Permanently close the account and forfeit any remaining balance in accordance with phcku's Terms & Conditions.
• Report the incident to relevant Philippine authorities where required by law.

11 Changes to This Privacy Policy

phcku reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. The "Last Updated" date at the top of this page will be revised whenever a change is made.

Where a change to this Privacy Policy is material — meaning it significantly affects how phcku processes your personal data or materially reduces your privacy rights — phcku will notify registered users via email or prominent notice on the phcku platform at least fourteen (14) days before the change takes effect. For non-material changes (such as clarifications that do not alter the substance of how phcku processes your data), the updated Privacy Policy will take effect upon publication without prior individual notice.

Your continued use of the phcku platform following the effective date of any Privacy Policy update constitutes your acceptance of the revised policy. If you do not agree with a material change to this Privacy Policy, you may request account closure prior to the effective date of the change by contacting phcku support.

12 Contact phcku's Data Protection Officer

phcku has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to this Privacy Policy or phcku's handling of your personal data, you may contact phcku's DPO through the following channels:

• Email: [email protected] — please use the subject line "DATA PRIVACY INQUIRY" for privacy-related matters so your message is routed to the DPO team.
• Live Chat: Available 24/7 on phcku.cam. Ask to be connected with the compliance team for data privacy matters.

phcku commits to acknowledging all data privacy inquiries within two (2) business days and providing a substantive response within thirty (30) calendar days. For complex data rights requests requiring additional verification or investigation, phcku may extend this period by a further thirty (30) days with prior notification to you.

If you are not satisfied with phcku's response to your privacy inquiry or data rights request, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines.