phdaily Privacy Policy

01. Introduction & Scope

This Privacy Policy ("Policy") describes how phdaily ("phdaily," "we," "us," or "our") collects, processes, stores, and protects personal information belonging to users ("Player," "User," "you") of the phdaily online gaming platform accessible at phdaily.vip and associated interfaces.

This Policy applies to all personal data processed by phdaily regardless of the channel through which it was collected — including account registration, KYC verification, deposit and withdrawal transactions, gameplay sessions, customer support interactions, and marketing communications.

phdaily is committed to the responsible handling of personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (NPC) of the Philippines. Our data processing practices are also shaped by PAGCOR licensing requirements, which impose specific data collection, retention, and reporting obligations on licensed online gaming operators.

02. Data Controller

phdaily is the Personal Information Controller (as defined in RA 10173) in respect of all personal data collected and processed through the phdaily Platform. This means phdaily determines the purposes and means of processing your personal data.

Where phdaily engages third-party service providers to process personal data on its behalf — for example, payment processors, KYC verification providers, cloud hosting services, or customer support platforms — those parties act as Personal Information Processors under written agreements that bind them to process data only on phdaily's documented instructions and to implement appropriate security measures consistent with RA 10173.

phdaily has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy law. Contact details for the DPO are provided in Section 15 of this Policy.

03. Information We Collect

phdaily collects personal data through several channels and for distinct purposes. The categories of personal data we process are set out below:

phdaily does not collect sensitive personal information as defined under RA 10173 (such as health data, biometric data used for profiling, political or religious affiliation) except where a selfie photograph is required for KYC liveness verification — which constitutes biometric data processed exclusively for identity verification and PAGCOR compliance.

04. How We Use Your Personal Data

phdaily uses personal data strictly for the purposes for which it was collected or for compatible purposes that you would reasonably expect. Specifically:

• Account Management: To create, maintain, and administer your phdaily account, including verifying your identity and managing your login credentials.
• PAGCOR Compliance & KYC: To verify your eligibility to play (including age verification — 21+ required), comply with PAGCOR licensing conditions, fulfil AML reporting obligations under RA 9160, and maintain the gaming activity records mandated by PAGCOR.
• Transaction Processing: To process deposits, withdrawals, and internal transfers via GCash, Maya, and Philippine banking channels; to reconcile payment records and investigate disputed transactions.
• Platform Security: To detect and prevent fraud, account takeovers, bonus abuse, money laundering activity, and other prohibited conduct; to monitor unusual account activity and trigger two-factor authentication where required.
• Customer Support: To respond to your queries, process complaints, and fulfill our dispute resolution obligations under the phdaily Terms & Conditions and PAGCOR procedures.
• Responsible Gaming: To monitor gaming patterns that may indicate problem gambling behaviour; to apply and track deposit limits, self-exclusion periods, cooling-off requests, and other responsible gaming tools activated by you or by phdaily's welfare team.
• Marketing Communications: To send you phdaily promotions, bonus offers, and platform updates via SMS, email, or push notification — but only where you have opted in. You may withdraw consent at any time from your account settings.
• Platform Improvement: To analyse aggregated usage data for the purpose of improving platform performance, game selection, and user experience. Aggregated analytics do not identify individual players.

05. Legal Bases for Processing

phdaily processes personal data on the following legal bases, consistent with RA 10173:

• Contractual Necessity: Processing of registration data, financial data, and gaming activity logs is necessary for the performance of the service agreement between phdaily and the player (the Terms & Conditions).
• Legal Obligation: KYC data, AML records, gaming activity logs, and age verification data are processed to comply with PAGCOR licensing requirements, RA 9160 (Anti-Money Laundering Act), and RA 10173 itself.
• Legitimate Interests: Device and technical data are processed on the basis of phdaily's legitimate interest in detecting fraud, maintaining platform security, and improving service quality — where this interest is not overridden by your privacy rights.
• Consent: Marketing communications via SMS and email are processed on the basis of your explicit opt-in consent. This consent may be withdrawn at any time without affecting the lawfulness of processing conducted prior to withdrawal.

06. Data Sharing & Disclosure

phdaily does not sell, rent, trade, or otherwise transfer your personal data to third parties for their own commercial purposes. Personal data is shared only in the following limited circumstances:

• Payment Processors: GCash (GXI Inc.), Maya Philippines, BancNet, InstaPay, and other payment service providers receive the minimum data necessary to process your deposit or withdrawal transactions. These providers are subject to BSP oversight and their own PDPA compliance obligations.
• KYC Verification Providers: phdaily may engage PAGCOR-approved identity verification platforms to process government ID uploads and liveness checks. Data shared is limited to what is necessary for the verification task.
• Game Technology Providers: Aggregate session data (non-identifying game logs) may be shared with game providers (JILI, PG Soft, Evolution Gaming, etc.) for RNG audit and technical compliance purposes.
• PAGCOR and Philippine Regulatory Authorities: phdaily is legally required to provide gaming activity records, player registration data, and AML-relevant transaction data to PAGCOR upon lawful request. phdaily may also disclose data to the AMLC (Anti-Money Laundering Council), the NPC, or other competent Philippine authorities pursuant to court order, subpoena, or mandatory reporting obligations.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by phdaily may access personal data strictly on a need-to-know basis and are bound by professional confidentiality obligations.

07. KYC, Age Verification & AML Data

phdaily is legally required to verify the identity and age of all players before processing withdrawals, consistent with PAGCOR online gaming regulations and RA 9160. This process involves the collection and processing of government-issued identification documents and biometric data (selfie photograph).

KYC documentation is processed and stored with heightened security controls, including access restrictions to authorised phdaily compliance personnel only, encrypted at-rest storage, and audit logging of all access events.

AML-related transaction monitoring involves automated analysis of deposit and withdrawal patterns against risk thresholds defined under RA 9160. Where a transaction or pattern triggers a reporting threshold, phdaily is legally required to file a Covered Transaction Report (CTR) or Suspicious Transaction Report (STR) with the Anti-Money Laundering Council. phdaily is prohibited by law from disclosing to the subject of such a report that a filing has been made.

08. Cookies & Tracking Technologies

The phdaily Platform uses cookies and similar technologies to function correctly and to provide a secure, personalised experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These manage your logged-in session, security tokens, and CSRF protection. They cannot be disabled without breaking core functionality.
• Analytics Cookies: Used by phdaily's internal analytics systems to understand aggregate usage patterns — which game categories are most popular, how players navigate the lobby, and where technical errors occur. Analytics data is not used to identify individual players and is not shared with advertising platforms.
• Preference Cookies: Store your language, display, and notification preferences so they persist across sessions.

You may manage cookie preferences through your browser's settings. Note that disabling strictly necessary cookies will impair your ability to log in or maintain a session on the Platform.

09. Data Retention

phdaily retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to longer retention periods required by law. Retention periods are as follows:

• Account and Registration Data: Retained for the duration of your active account plus five (5) years following account closure, consistent with PAGCOR record-keeping requirements and Philippine civil law prescription periods.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of verification, as required under RA 9160 and PAGCOR directives.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by PAGCOR and the AMLC.
• Gaming Activity Logs: Retained for a minimum of five (5) years under PAGCOR licensing conditions.
• Support Communications: Retained for two (2) years from the date of the last interaction, or longer where the communication relates to an ongoing dispute or regulatory inquiry.
• Marketing Preference Data: Retained until you withdraw consent or close your account, at which point it is deleted or anonymised within 30 days.

Upon expiry of applicable retention periods, phdaily will securely delete or irreversibly anonymise the relevant personal data. Where deletion is not immediately possible due to technical constraints (such as data residing in encrypted backup archives), the data will be isolated from active processing and deleted at the next scheduled purge cycle.

10. Data Security

phdaily implements technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption: All data transmitted between your device and phdaily servers is encrypted using TLS 1.3. Personal data stored in phdaily databases is encrypted at rest using AES-256.
• Access Controls: Access to personal data is restricted to authorised phdaily personnel on a strict need-to-know basis. All administrative access is logged and subject to periodic review.
• Two-Factor Authentication: Internal systems handling personal data require multi-factor authentication for all phdaily staff access.
• Security Monitoring: phdaily maintains continuous security monitoring for anomalous access patterns, potential data breaches, and infrastructure vulnerabilities.
• Penetration Testing: The Platform undergoes periodic third-party security assessments and penetration tests to identify and remediate vulnerabilities.

In the event of a personal data breach that poses a real risk of serious harm to affected players, phdaily 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, consistent with RA 10173 breach notification requirements.

11. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you are entitled to exercise the following rights in respect of personal data held by phdaily:

• Right to be Informed: You have the right to know what personal data phdaily holds about you and how it is processed — which this Policy fulfils.
• Right of Access: You may request a copy of the personal data phdaily holds about you. Requests will be fulfilled within fifteen (15) business days of verification of your identity.
• Right to Correction: You may request correction of inaccurate or incomplete personal data. Name and date of birth corrections require re-verification of your government ID.
• 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. Note that data subject to mandatory PAGCOR or AMLC retention requirements cannot be deleted until the relevant retention period expires.
• 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 phdaily's legitimate interests; phdaily will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Data Portability: You may request that personal data you provided to phdaily be delivered to you in a commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe phdaily has violated your data privacy rights, you may file a complaint with the National Privacy Commission of the Philippines.

12. Children's Privacy — 21+ Only

The phdaily Platform is strictly intended for adults aged twenty-one (21) years and above, consistent with PAGCOR's minimum age requirement for online gaming in the Philippines.

phdaily does not knowingly collect personal data from individuals under the age of 21. All registration attempts are subject to age declaration, and all accounts are subject to KYC age verification before any withdrawal is processed.

If you believe an underage person has registered on the phdaily Platform, please contact our support team immediately via live chat or email.

13. International Data Transfers

phdaily's primary data processing infrastructure is located within the Philippines or in data centres with contractual commitments to Philippine data protection standards. Where phdaily engages technology providers or processors whose servers are located outside the Philippines — for example, certain cloud infrastructure or international KYC platforms — such transfers are conducted only where:

• The recipient country or organisation has been assessed to provide an adequate level of data protection; or
• phdaily has put in place appropriate contractual safeguards (such as NPC-approved standard contractual clauses or equivalent binding commitments) to ensure your data receives a level of protection consistent with RA 10173.

You may request information about the specific safeguards in place for international transfers by contacting phdaily's Data Protection Officer.

14. Amendments to This Policy

phdaily may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Where amendments are material — including changes that affect how your personal data is used, shared, or retained — phdaily will provide notice via a prominent Platform banner and, where applicable, via email to your registered address, at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Non-material clarifications (e.g., correcting typographical errors or improving readability without changing substantive content) may be made without prior notice.

Your continued use of the phdaily Platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the updated Policy. If you do not accept a material change, you may request account closure as described in the Terms & Conditions.

15. Contact & Data Protection Officer

For all privacy-related requests, inquiries, complaints, or to exercise your rights under RA 10173, please contact phdaily's Data Protection Officer through the following channels:

phdaily acknowledges all privacy requests within twenty-four (24) hours. Substantive responses are provided within fifteen (15) business days. Where additional time is required for complex requests, phdaily will notify you within the initial 15-day window.