phmerry Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how phmerry ("phmerry", "we", "our", "us") collects, uses, stores, shares, and protects personal information obtained from users ("Player", "you", "your") of the phmerry online casino and sports betting platform accessible at phmerry.win (the "Platform").

phmerry is committed to protecting the privacy and personal data of every Filipino player who registers and engages with our services. This Policy is written in compliance 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 phmerry's obligations under applicable PAGCOR regulations regarding player data management.

By registering an account or continuing to use the phmerry Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller

phmerry is the data controller responsible for personal data collected through the Platform. As data controller, phmerry determines the purposes for which and the means by which personal data is processed. For all data-related enquiries, you may contact our Data Protection Officer (DPO) at the address provided in Section 14 of this Policy.

3. Personal Data We Collect

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

Category	Examples	Source
Identity Data	Full legal name, date of birth, government ID number, selfie/photo for KYC	Provided by you
Contact Data	Philippine mobile number, email address, residential address	Provided by you
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history	Provided by you / payment processors
Usage Data	Games played, wagers placed, session duration, login timestamps, device type, IP address, browser type	Collected automatically
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Provided by you
Responsible Gaming Data	Deposit limits set, self-exclusion requests, cooling-off periods activated	Provided by you / system generated

phmerry does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and compliance purposes. Where sensitive data is collected (such as a government ID), it is handled with heightened security measures and access controls.

4. How phmerry Uses Your Personal Data

phmerry processes your personal data for the following specific purposes:

• Account Registration and Management: To create, maintain, and secure your phmerry player account, including identity verification (KYC) as required under PAGCOR and AML regulations.
• Service Delivery: To provide access to casino games, sports betting, bingo, Super Keno, and all other phmerry Platform features.
• Payment Processing: To facilitate deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to detect and prevent fraudulent transactions.
• Regulatory Compliance: To comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) obligations, and NPC data governance requirements.
• Responsible Gaming: To implement and monitor responsible gaming tools including deposit limits, self-exclusion, and session controls at your request or where legally required.
• Customer Support: To respond to your enquiries, resolve disputes, and improve the quality of our support services.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent. You may opt out of marketing communications at any time via your account settings.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve phmerry's games, features, and overall user experience.
• Security and Fraud Prevention: To detect and investigate unauthorised access, suspicious activity, collusion, or other security incidents involving your phmerry account.

5. Legal Basis for Processing

phmerry processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the phmerry Terms and Conditions you agreed to upon registration.
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, AMLA obligations, and NPC directives.
• Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications and certain optional account features.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.

6. Data Sharing and Disclosure

phmerry does not sell, rent, or trade your personal data to any third party. phmerry may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors to facilitate your financial transactions.
• KYC / Identity Verification Providers: Third-party identity verification services engaged to support phmerry's AML and PAGCOR compliance obligations.
• Game Content Providers: Game studios such as JILI, PG Soft, Pragmatic Play, and Evolution may receive session data required to deliver game services.
• Regulatory Authorities: PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), and law enforcement agencies as required by applicable Philippine law or court order.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and analytics providers who process data on phmerry's behalf under strict contractual data protection obligations.

Any third party processing personal data on behalf of phmerry is bound by a data processing agreement that requires them to maintain confidentiality, implement adequate security measures, and process data only as directed by phmerry.

7. Cookies and Tracking Technologies

phmerry uses cookies and similar tracking technologies to operate the Platform and improve your experience. These include:

• Essential Cookies: Required for the Platform to function, including session management and login authentication. These cannot be disabled.
• Analytics Cookies: Used to understand how players navigate the Platform, which pages are most visited, and where technical issues occur. Analytics data is aggregated and anonymised.
• Preference Cookies: Store your language, display, and notification preferences to personalise your phmerry experience.

You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the phmerry Platform.

8. Data Retention

phmerry retains personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with legal obligations. Specific retention periods include:

• Account data: Retained for the duration of your active phmerry account and for a minimum of five (5) years following account closure, as required by AMLA and PAGCOR regulations.
• Transaction data: Retained for a minimum of five (5) years from the date of the transaction.
• Support communications: Retained for two (2) years from the date of resolution.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with phmerry's data disposal procedures.

9. Data Security

phmerry implements technical and organisational security measures appropriate to the risk associated with processing your personal data. These measures include 256-bit SSL/TLS encryption for all data in transit, encrypted storage for sensitive data at rest, access controls limiting data access to authorised phmerry personnel only, regular security audits and penetration testing, and incident response procedures aligned with NPC breach notification requirements.

Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in risk to your rights, phmerry will notify the NPC and affected players within the timeframes required by the Data Privacy Act of 2012.

10. Your Data Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phmerry:

• Right to be Informed: You have the right to know how your personal data is being collected and processed by phmerry — which is the purpose of this Policy.
• Right of Access: You may request a copy of the personal data phmerry holds about you.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data where processing is no longer necessary and no legal obligation requires its retention.
• Right to Data Portability: You may request your personal data in a structured, commonly used format where technically feasible.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phmerry has not handled your personal data in accordance with the law.

To exercise any of these rights, please contact phmerry's Data Protection Officer using the details in Section 14. We will respond to all valid requests within thirty (30) days.

11. Children and Minors

phmerry does not knowingly collect personal data from individuals under the age of 21. The phmerry Platform is strictly for adults aged 21 years and older in accordance with Philippine gambling regulations. If phmerry becomes aware that personal data has been collected from a person under 21 without appropriate verification, such data will be deleted and the associated account closed immediately. If you believe a minor has registered on phmerry, please contact us immediately at the details in Section 14.

12. Cross-Border Data Transfers

phmerry primarily stores and processes personal data within the Philippines. Where data is transferred to service providers located outside the Philippines (for example, international cloud infrastructure or game content providers), phmerry ensures such transfers are conducted in compliance with Section 21 of the Data Privacy Act of 2012, including the use of appropriate contractual safeguards such as standard data protection clauses and data processing agreements that require recipients to maintain standards of protection equivalent to those required under Philippine law.

13. Changes to This Privacy Policy

phmerry may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. The date of the most recent revision is displayed at the top of this page. For material changes, phmerry will notify registered players via the contact details associated with their account or through a prominent notice on the Platform prior to the change taking effect. We encourage you to review this Policy periodically. Continued use of phmerry following notification of changes constitutes acceptance of the updated Policy.

14. Contact and Data Protection Officer

For all privacy-related enquiries, data subject access requests, or complaints, you may contact phmerry's Data Protection Officer at:

Email: [email protected] (please include "Privacy / DPO Request" in your subject line)

Live Chat: Available 24/7 inside your phmerry account dashboard — the fastest channel for urgent account-related matters.

If you are not satisfied with phmerry's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC) through their official channels.