Privacy Policy – phsly Data Protection for Filipino Players

1 Introduction

phsly ("we," "our," "us") is committed to protecting the privacy of every person who uses our platform at phsly.com. This Privacy Policy ("Policy") describes how phsly collects, uses, discloses, stores, and protects personal data relating to our members and visitors in the Philippines and beyond.

This Policy applies to all services operated under the phsly brand, including sports betting, PBA and basketball markets, football betting, fishing games, promotional offers, and any customer support interactions conducted through the phsly platform.

phsly operates in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (DPA), and its implementing rules and regulations. By registering and using phsly, you acknowledge that you have read and understood this Policy and consent to the practices described herein.

2 What Personal Data We Collect

phsly collects personal data from you in order to provide a safe, compliant, and personalised betting and gaming experience. The categories of personal data we collect include the following:

2.1 Data You Provide Directly

• Identity data: Full name, date of birth, nationality, and a copy of a government-issued identification document (such as a Philippine passport, SSS ID, driver's licence, or PhilSys National ID) provided during the Know Your Customer (KYC) verification process.
• Contact data: Email address, mobile phone number, and home address in the Philippines.
• Account credentials: Username and encrypted password. phsly does not store your password in plain text.
• Financial data: GCash account reference, Maya wallet reference, bank account details (BDO, BPI, UnionBank), and Visa or Mastercard details provided during deposit or withdrawal transactions. Full card numbers are never stored on phsly servers.
• Communications: Messages exchanged with the phsly customer support team via chat, email, or any other communication channel.

2.2 Data Collected Automatically

• Usage data: Pages visited on phsly, features used, bets placed, games played, time and duration of sessions, and actions taken within the platform.
• Device and technical data: IP address, browser type, operating system, device type, screen resolution, and language settings.
• Location data: General geographic location derived from your IP address to support compliance with regional gaming regulations. phsly does not collect precise GPS location data.
• Cookie and tracking data: Data collected through cookies and similar technologies as described in Section 9 of this Policy.

3 How We Use Your Personal Data

phsly uses the personal data it collects only for specific, legitimate purposes. We do not process your data in ways that are incompatible with those purposes. The main reasons we use your personal data are:

• Account registration and management: Setting up and maintaining your phsly account, verifying your identity, and managing your account preferences.
• Service delivery: Processing your bets, settling winnings, crediting bonus offers, running promotions, and providing access to all phsly game and betting products.
• Payment processing: Handling deposits and withdrawals through GCash, Maya, GrabPay, Coins.ph, InstaPay, PESONet, BDO, BPI, UnionBank, and Visa/Mastercard in Philippine Peso.
• Identity verification and KYC compliance: Verifying that you are who you say you are and that you meet the age and eligibility requirements to use phsly.
• Fraud prevention and security: Detecting and preventing fraudulent activity, money laundering, and abuse of the phsly platform, including bonus abuse and account duplication.
• Legal and regulatory compliance: Meeting phsly's obligations under applicable Philippine law, including the Data Privacy Act of 2012, anti-money laundering regulations, and gaming regulations.
• Customer support: Responding to your queries, complaints, and requests for assistance submitted through phsly's support channels.
• Responsible gaming: Monitoring betting patterns to identify potential problem gambling behaviour, applying deposit limits or self-exclusion measures where requested or required, and directing members to appropriate support resources.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the phsly platform, fix technical issues, and develop new features and products for Filipino members.
• Communications: Sending transactional messages (deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about phsly offers and events.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its implementing rules, phsly processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to fulfil our obligations to you under the phsly Terms and Conditions, including account management, bet settlement, and payment processing.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including KYC requirements, anti-money laundering reporting, and data retention obligations imposed by relevant regulators.
• Legitimate interests: Processing is necessary for phsly's legitimate interests in operating a secure, fraud-free, and compliant platform, provided those interests do not unfairly override your rights and interests.
• Consent: For specific processing activities that are not strictly necessary – such as sending you promotional emails about phsly offers – we rely on your consent, which you may withdraw at any time.

5 Sharing Your Personal Data

phsly does not sell your personal data to any third party. We do not share your personal information with advertisers or marketing agencies for their own commercial use. phsly shares personal data only in the following limited circumstances:

• Payment processors: Financial data is shared with your chosen payment provider (such as GCash, Maya, GrabPay, or your bank) only to the extent necessary to process your deposit or withdrawal in Philippine Peso.
• Identity verification providers: Your identity documents and personal details may be shared with licensed KYC verification service providers engaged by phsly to complete account verification checks.
• Technology and platform service providers: Third-party companies that provide phsly with hosting, security, customer support tools, and analytics services may have access to personal data strictly for the purpose of delivering those services and are contractually bound to protect that data.
• Regulatory and law enforcement authorities: phsly may disclose personal data to Philippine government authorities, regulators, or law enforcement bodies where required by applicable law, court order, or regulatory requirement.
• Fraud prevention services: Anonymised or aggregated data may be shared with industry fraud prevention networks to protect the broader online gaming ecosystem from coordinated abuse.

6 Data Retention

phsly retains personal data only for as long as it is necessary for the purposes it was collected or as required by applicable law. The following general retention guidelines apply:

• Account data: Retained for the duration of your membership with phsly and for a minimum of five years following account closure, as required under Philippine anti-money laundering and gaming regulations.
• Transaction and betting records: Retained for a minimum of five years from the date of each transaction, in line with financial record-keeping requirements under Philippine law.
• KYC and identity documents: Retained for the period required by applicable law following account closure, generally a minimum of five years.
• Customer support communications: Retained for up to three years following the resolution of a query or complaint, unless a longer period is required for legal or compliance purposes.
• Marketing consent records: Retained for as long as your marketing consent is active and for up to two years following withdrawal of consent, to demonstrate compliance with consent obligations.

When personal data is no longer required, phsly will securely delete or anonymise it in accordance with our internal data disposal procedures.

7 Your Data Rights

As a data subject under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by phsly. You may exercise any of these rights by contacting the phsly support team using the contact information provided in Section 11 of this Policy.

phsly will respond to all verified data subject rights requests within thirty calendar days of receipt, in accordance with the Data Privacy Act of 2012. Where a request is complex or numerous, we may extend this period and will notify you accordingly.

8 Data Security

phsly takes the security of your personal data seriously. We have put in place appropriate technical and organisational measures to protect your data against unauthorised access, accidental loss, disclosure, or destruction.

Security measures implemented by phsly include:

• SSL/TLS encryption for all data transmitted between your browser and phsly servers.
• Encryption at rest for sensitive personal and financial data stored on phsly systems.
• Strict access controls limiting which phsly employees and systems can access personal data, on a need-to-know basis only.
• Regular security audits, penetration testing, and vulnerability assessments of phsly's platform infrastructure.
• Secure disposal processes for data that is no longer required.
• Staff training on data privacy obligations and secure data handling practices.

Despite these measures, no online platform can guarantee absolute security. You also have a responsibility to protect your own account by using a strong password, keeping your login credentials confidential, and notifying phsly immediately if you suspect any unauthorised activity on your account.

9 Cookies and Tracking Technologies

phsly uses cookies and similar tracking technologies on its platform. Cookies are small text files stored on your device when you visit phsly.com. They help phsly deliver a better, more personalised experience and allow us to understand how members use the platform.

The types of cookies used by phsly include:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in while you navigate phsly. You cannot opt out of these without preventing the platform from working.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and display options to personalise your phsly experience.
• Analytics cookies: Collect aggregated, anonymised data on how members use phsly to help us identify issues and improve the platform. phsly uses privacy-respecting analytics tools that do not share data with advertising networks.
• Security cookies: Support fraud detection and security monitoring to protect phsly members from account compromise and platform abuse.

You can control cookie settings through your browser preferences. Note that disabling certain cookies may affect the functionality of the phsly platform. phsly does not use third-party advertising or behavioural targeting cookies.

10 Children's Privacy

phsly is strictly for adults. The platform is not intended for anyone under the age of 21. phsly does not knowingly collect personal data from individuals under 21 years of age. Age verification is conducted as part of the registration and KYC process to enforce this requirement.

If phsly becomes aware that personal data has been collected from a person under 21, that data will be deleted and the associated account will be permanently closed. If you believe a minor has registered with phsly, please contact our support team immediately.

11 Contact and Data Protection Enquiries

If you have any questions about this Privacy Policy, how phsly handles your personal data, or wish to exercise any of your data subject rights, please contact the phsly team using the following channel:

• Email: support@phsly.com

Please include your phsly account username and the nature of your request in your message. phsly will acknowledge your enquiry within three business days and respond in full within thirty calendar days.

If you are not satisfied with phsly's response to your privacy enquiry or believe your data rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.

12 Changes to This Privacy Policy

phsly may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable law. When we make significant changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify members by email or in-platform notification.

We encourage you to review this Policy periodically to stay informed about how phsly protects your personal data. Continued use of phsly following an update to this Policy constitutes your acceptance of the revised terms.