phmarry Privacy Policy

1 Introduction and Scope

1.1 phmarry ("phmarry," "we," "us," "our") is committed to protecting the personal data of all users of the phmarry platform, accessible at https://phmarry.vip. This Policy sets out how we collect, use, disclose, store, and protect personal information in compliance with Republic Act 10173, the Data Privacy Act of 2012 ("DPA") of the Philippines, and the rules and regulations promulgated by the National Privacy Commission ("NPC").

1.2 This Policy applies to:

• All registered phmarry account holders;
• Visitors to the phmarry website who have not yet registered;
• Former account holders whose data phmarry retains in accordance with legal obligations;
• Any individual whose personal data is processed by phmarry in connection with account registration, identity verification, payment processing, or customer support.

1.3 This Policy is to be read in conjunction with phmarry's Terms & Conditions, available at phmarry.vip/terms-conditions. In the event of any conflict between this Policy and the Terms & Conditions on matters of data processing, this Policy shall prevail.

2 Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, phmarry is the Personal Information Controller (PIC) in respect of all personal data collected through the phmarry platform.

2.2 phmarry has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. The DPO may be contacted at [email protected]. All correspondence directed to the DPO should be clearly marked "Data Protection — Attention DPO."

3 Personal Data We Collect

3.1 phmarry collects the following categories of personal data in connection with platform operation:

3.2 phmarry does not intentionally collect sensitive personal information as defined under the DPA (including racial or ethnic origin, health data, or criminal records) except where such data is submitted voluntarily by the player or is required by regulatory authorities in the context of a specific legal obligation or investigation.

4 How We Collect Your Data

4.1 phmarry collects personal data through the following means:

• Direct Submission — data you provide when registering a phmarry account, completing KYC verification, making a deposit, contacting support, or updating your account settings;
• Automated Technical Collection — data collected automatically when you access phmarry.vip, including IP address, device identifiers, session data, and cookies (see Section 8);
• Payment Processors — transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard in connection with your deposits and withdrawals;
• Identity Verification Services — data received from third-party KYC and identity verification providers when processing your identity documents;
• Regulatory Authorities — data we may receive from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory bodies in connection with compliance requirements.

5 How We Use Your Personal Data

5.1 phmarry processes your personal data for the following purposes:

5.1 Platform Operation

To create and manage your phmarry account, verify your identity and age, process deposits and withdrawals, provide access to games and betting markets, and deliver customer support services.

5.2 Regulatory Compliance

To comply with phmarry's obligations under PAGCOR's licensing requirements, Republic Act 9160 (Anti-Money Laundering Act of 2001, as amended), Republic Act 10365, and all other applicable Philippine laws and regulations. This includes filing regulatory reports, retaining transaction records, and cooperating with lawful requests from competent Philippine authorities.

5.3 Responsible Gaming

To monitor gaming activity in connection with phmarry's responsible gaming obligations — including enforcing deposit limits, session time limits, self-exclusion periods, and the 21+ age requirement. Gaming data may be reviewed by phmarry's responsible gaming team to identify indicators of problem gambling behavior in accordance with PAGCOR guidelines.

5.4 Security and Fraud Prevention

To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, bonus abuse, and other prohibited conduct as defined in phmarry's Terms & Conditions. Technical data including IP addresses and device fingerprints is processed for this purpose.

5.5 Marketing Communications (with Consent)

To send promotional offers, bonus notifications, and platform updates to players who have provided explicit consent to receive marketing communications. Players may withdraw marketing consent at any time by updating communication preferences in account settings or contacting [email protected].

5.6 Platform Improvement

To analyze aggregated and anonymized usage data for the purpose of improving the phmarry platform's performance, user interface, game selection, and overall player experience.

6 Legal Bases for Processing

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

• Contractual Necessity — processing required to enter into or perform the player agreement, including account registration, game access, and payment processing;
• Legal Obligation — processing required to comply with PAGCOR regulations, AML legislation, NPC requirements, and other applicable Philippine legal obligations;
• Legitimate Interests — processing for fraud prevention, security monitoring, and platform improvement where such interests are not overridden by your privacy rights;
• Consent — processing for marketing communications and any other purpose for which phmarry has obtained your explicit prior consent.

7 Sharing Your Personal Data

7.1 phmarry does not sell, rent, or trade personal data to third parties for their own commercial purposes. We share personal data only in the following circumstances:

7.1 Service Providers

phmarry engages third-party service providers who process personal data on our behalf as Personal Information Processors (PIPs) under the DPA. These include identity verification services, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), cloud hosting providers, and customer support platforms. All PIPs are contractually bound to process data only on phmarry's instructions and to maintain appropriate security standards.

7.2 Regulatory Authorities

phmarry may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other competent Philippine government bodies where required by law, court order, or regulatory directive.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of phmarry's business or assets, personal data may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection commitments.

7.4 Legal Proceedings

phmarry may disclose personal data where necessary to establish, exercise, or defend legal claims, including in connection with fraud investigations, disputes, or enforcement of phmarry's Terms & Conditions.

8 Cookies and Tracking Technologies

8.1 phmarry uses cookies and similar tracking technologies on the phmarry.vip website. Cookies are small data files placed on your device that help us operate the platform, remember your preferences, and analyze usage patterns.

8.2 phmarry uses the following categories of cookies:

• Strictly Necessary Cookies — required for the platform to function. These include session cookies that maintain your login state and security tokens. These cookies cannot be disabled.
• Functional Cookies — store your preferences such as language settings, display options, and responsible gaming configurations to provide a consistent experience.
• Analytics Cookies — collect aggregated, anonymized data about how players navigate phmarry to help us improve platform performance and user experience.
• Security Cookies — assist in detecting and preventing fraudulent activity, bot access, and unauthorized login attempts.

8.3 You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the phmarry platform. phmarry does not use third-party advertising or behavioral tracking cookies.

9 Data Security

9.1 phmarry implements a range of technical and organizational security measures designed to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and phmarry servers;
• Encryption of sensitive data at rest, including identity documents and financial information;
• Access controls limiting personal data access to authorized phmarry personnel with a legitimate need;
• Multi-factor authentication requirements for internal systems access;
• Regular security assessments and penetration testing;
• Incident response procedures for detecting, containing, and reporting data security breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, phmarry will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA's breach notification requirements.

9.3 Notwithstanding the security measures phmarry employs, no system is completely secure. Players are responsible for maintaining the confidentiality of their own phmarry account credentials and for enabling available account security features such as Two-Factor Authentication (2FA).

10 Data Retention

10.1 phmarry retains personal data for the period necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and Identity Data — retained for the duration of the account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements;
• Transaction Records — retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act;
• Gaming History — retained for the duration of the account and for three (3) years following account closure, for regulatory reporting and dispute resolution purposes;
• Support Correspondence — retained for two (2) years from the date of the last interaction for customer service quality and dispute resolution purposes;
• Marketing Data — retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations.

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

11 Your Privacy Rights

11.1 Under the Data Privacy Act of 2012, phmarry players who are Philippine data subjects have the following rights with respect to their personal data:

11.2 To exercise any of the above rights, please submit a written request to phmarry's Data Protection Officer at [email protected] with the subject line "Data Rights Request." phmarry will respond within thirty (30) calendar days of receiving a valid request. Identity verification may be required before processing a data rights request.

11.3 Certain rights are subject to limitations under the DPA and related regulations. In particular, phmarry may decline erasure requests where retention is required by law (for example, under AMLC's five-year record-keeping mandate) or where the data is necessary for the establishment or defence of legal claims.

12 Children's Privacy and the 21+ Requirement

12.1 phmarry does not knowingly collect personal data from any person under 21 years of age. The phmarry platform is strictly restricted to adults aged 21 years and above, as required by PAGCOR regulations. Age verification is conducted for all registering players and at the point of first withdrawal.

12.2 If phmarry becomes aware that it has inadvertently collected personal data from a person under 21, that account will be immediately suspended, all personal data associated with the account will be securely deleted (subject to any mandatory regulatory reporting obligations), and any funds deposited will be returned to the source payment method.

12.3 If you have reason to believe that a person under 21 has registered a phmarry account, please contact phmarry immediately at [email protected] so that appropriate action can be taken without delay.

13 Cross-Border Data Transfers

13.1 In the course of operating the phmarry platform, personal data may be transferred to and processed by phmarry's service providers located outside the Philippines — including cloud infrastructure providers and identity verification platforms.

13.2 When personal data is transferred outside the Philippines, phmarry ensures that adequate safeguards are in place to protect the data, in compliance with Section 21 of the Data Privacy Act of 2012. These safeguards include contractual obligations that require recipient entities to maintain data protection standards equivalent to those required under Philippine law.

13.3 By using the phmarry platform and accepting this Privacy Policy, you consent to such cross-border transfers of your personal data to the extent necessary for phmarry's platform operations, subject to the safeguards described in this Section.

14 Changes to This Privacy Policy

14.1 phmarry reserves the right to update this Privacy Policy at any time to reflect changes in platform operations, applicable law, regulatory requirements, or industry best practices. The "Last Updated" date at the top of this document reflects the date of the most recent revision.

14.2 Material changes to this Privacy Policy that affect how phmarry processes your personal data will be communicated to registered players via the email address on file and/or through a notice displayed on phmarry.vip for a reasonable period prior to the changes taking effect.

14.3 Continued use of the phmarry platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. If you do not accept the revised Policy, you may close your account and request deletion of your personal data in accordance with Section 11.

15 Contact and Data Protection Officer

15.1 For any questions, concerns, or requests relating to this Privacy Policy or phmarry's data processing practices, please contact our Data Protection Officer:

• Email: [email protected] (Subject: "Privacy Policy Inquiry" or "Data Rights Request")
• Live Chat: Available 24/7 via your phmarry account dashboard — select "Privacy & Data" from the support menu
• Response Time: Data rights requests addressed within 30 calendar days; general privacy inquiries within 5 business days

15.2 phmarry's registered privacy contact for NPC purposes is available through official Philippine government channels. Players exercising rights under the DPA are entitled to seek recourse from the National Privacy Commission if they are not satisfied with phmarry's response to a data rights request.