phmarry Privacy Policy

1. Introduction

phmarry ("phmarry," "we," "us," or "our") operates the online gaming platform accessible at phmarry.net and any associated mobile applications (collectively, the "Platform"). We are committed to protecting the privacy and personal data of every player, visitor, and user who interacts with our Platform.

This Privacy Policy has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). It also reflects applicable guidelines issued by the Philippine Amusement and Gaming Corporation (PAGCOR) regarding the handling of player data.

By registering an account, accessing the Platform, or otherwise providing your personal information to phmarry, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

2. Personal Data We Collect

phmarry collects personal data through various means, including directly from you during registration and account use, automatically through your use of the Platform, and from third parties where permitted by law. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you are at least 21 years of age)
• Nationality and country of residence
• Email address and mobile phone number
• Username and encrypted password
• Residential address (barangay, city/municipality, province, ZIP code)

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., PhilSys National ID, passport, driver's license, SSS ID, GSIS ID, PRC ID, Voter's ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or liveness check images for biometric verification where required
• Source of funds declarations where required by anti-money laundering regulations

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, dates, and payment method references
• GCash or PayMaya account reference numbers (we do not store full wallet credentials)
• Bank account details provided for withdrawal processing (bank name, account name, account number)
• Debit card details (card number is tokenized; we do not store full card numbers)
• Bonus and promotional transaction history

2.4 Gaming Activity Data

• Game session logs, including games played, wager amounts, win/loss records, and session duration
• Responsible gaming settings and limit configurations
• Self-exclusion requests and cooling-off period records
• Customer support interaction history

2.5 Technical & Device Data

• IP address and approximate geolocation (city/region level)
• Device type, operating system, and browser type and version
• Unique device identifiers
• Session timestamps and login history
• Cookies and similar tracking technologies (see Section 5)

2.6 Communications Data

• Records of communications between you and phmarry customer support, including live chat transcripts and email correspondence
• Survey responses and feedback submissions
• Marketing communication preferences

3. How We Use Your Personal Data

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

phmarry will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to provide you with access to the phmarry Platform, process your transactions, and manage your account.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including the Anti-Money Laundering Act, PAGCOR licensing requirements, and NPC data privacy regulations.
• Legitimate Interests: Processing is necessary for phmarry'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, we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Cookies & Tracking Technologies

phmarry uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit our website. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences, such as language settings, responsible gaming limits, and display preferences, to provide a more personalized experience.
• Analytics Cookies: Help us understand how players use the Platform by collecting aggregated, anonymized data about page visits, session duration, and feature usage. This data is used solely to improve the Platform.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and gaming activity. These are only activated with your explicit consent.

You can manage your cookie preferences through your browser settings or through the cookie consent banner displayed on your first visit to the Platform. Please note that disabling certain cookies may affect the functionality of the Platform.

6. Data Sharing & Disclosure

phmarry does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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 agreements:

• PAGCOR and Regulatory Authorities: As required by our gaming license and applicable Philippine law, including mandatory reporting of suspicious transactions to the Anti-Money Laundering Council (AMLC).
• Payment Service Providers: GCash, PayMaya (Maya), and partner banks, solely for the purpose of processing your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• KYC and Identity Verification Providers: Third-party identity verification services used to fulfill our KYC obligations under PAGCOR regulations and the Anti-Money Laundering Act.
• Game Software Providers: Licensed game studios and software providers whose games are available on the phmarry Platform. These providers may receive anonymized session data necessary to operate their games.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and fraud detection service providers who process data on our behalf under strict data processing agreements.
• Legal and Law Enforcement: Courts, law enforcement agencies, and government authorities where disclosure is required by law, court order, or to protect the rights, property, or safety of phmarry, its players, or the public.

All third-party service providers who process personal data on behalf of phmarry are required to implement appropriate technical and organizational security measures and to process data only in accordance with our instructions and applicable Philippine data privacy law.

7. Data Retention

phmarry retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account and KYC Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR requirements and the Anti-Money Laundering Act.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Gaming Activity Logs: Retained for a minimum of three (3) years from the date of the session.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with phmarry's data disposal procedures.

8. Data Security

phmarry implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Transport Layer Security (TLS 1.2 or higher) encryption for all data transmitted between your device and our servers.
• AES -256 encryption for sensitive data stored at rest, including KYC documents and financial records.
• Tokenization of payment instrument details — full card numbers and wallet credentials are never stored on phmarry servers.
• Multi-factor authentication (MFA) for all phmarry administrative systems and staff access.
• Regular penetration testing and vulnerability assessments conducted by independent security firms.
• Role-based access controls ensuring that only authorized personnel can access personal data, strictly on a need-to-know basis.
• 24/7 security monitoring and intrusion detection systems.
• Regular staff training on data privacy obligations under the Data Privacy Act of 2012.

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

9. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phmarry:

• Right to Be Informed: You have the right to be informed of how your personal data is being collected, processed, and used — which is the purpose of this Privacy Policy.
• Right to Access: You may request a copy of the personal data phmarry holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate, incomplete, or outdated personal data we hold about you. You can update most account information directly through your phmarry account dashboard.
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under PAGCOR regulations and the Anti-Money Laundering Act.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to phmarry's overriding legitimate grounds.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe phmarry has violated your data privacy rights. The NPC can be reached through its official website at privacy.gov.ph.

To exercise any of the above rights, please contact our Data Protection Officer (DPO) using the contact details provided in Section 13. phmarry will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

10. Children's Privacy

The phmarry Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR regulations. phmarry does not knowingly collect, process, or store personal data from individuals under the age of 21. Age verification is a mandatory step in the phmarry registration process, and we reserve the right to request documentary proof of age at any time.

If phmarry becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and report the matter to the appropriate authorities where required by law. If you are a parent or guardian and believe your child has registered on the phmarry Platform, please contact us immediately at the details provided in Section 13.

11. Third-Party Links

The phmarry Platform may contain links to third-party websites or services, such as payment provider portals, for the purpose of completing transactions. These third-party sites operate under their own privacy policies, which phmarry does not control. We encourage you to review the privacy policy of any third-party site you visit. phmarry is not responsible for the privacy practices or content of any third-party websites.

12. Changes to This Privacy Policy

phmarry 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, we will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. Your continued use of the phmarry Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how phmarry protects your personal data.

13. Contact & Data Protection Officer

phmarry has appointed a Data Protection Officer (DPO) in accordance with the Data Privacy Act of 2012 and NPC Circular No. 17-01. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our DPO:

For complaints that cannot be resolved directly with phmarry, you may contact the National Privacy Commission (NPC) of the Philippines. The NPC is the government authority responsible for administering and implementing the Data Privacy Act of 2012 and ensuring compliance with its provisions.