phmerry Privacy Policy

1. Introduction

phmerry ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all users ("you," "the Player," or "the User") who access or use the phmerry online casino platform. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It also reflects phmerry's obligations as an online gaming operator aligned with PAGCOR's regulatory framework.

This Privacy Policy should be read together with phmerry's Terms and Conditions and Responsible Gaming Policy. If you have any questions about how we handle your data, please contact our Data Protection Officer using the details in Section 14.

2. Personal Data We Collect

phmerry collects the following categories of personal data, depending on how you interact with the platform:

3. How We Collect Your Data

phmerry collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 7 for details on cookies.
• Third-Party Sources: In limited circumstances, phmerry may receive data from third parties, including identity verification service providers, payment processors (such as GCash and PayMaya), and fraud prevention services. Data received from third parties is handled in accordance with this policy.
• Regulatory Sources: phmerry may receive information from PAGCOR or other regulatory authorities in connection with licensing, compliance, or responsible gaming obligations.

4. How We Use Your Personal Data

phmerry uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your phmerry account, including identity verification and age verification (21+ requirement).
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of phmerry platform features.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct.
• Regulatory Compliance: To comply with applicable laws and regulations, including anti-money laundering (AML) obligations, PAGCOR licensing requirements, and the Philippine Data Privacy Act.
• Responsible Gaming: To monitor gaming behavior, enforce responsible gaming tools (deposit limits, self-exclusion), and identify players who may be at risk of problem gambling.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance via live chat and email.
• Platform Improvement: To analyze usage patterns, improve platform performance, and develop new features based on aggregated, anonymized data.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Legal Proceedings: To establish, exercise, or defend legal claims where necessary.

5. Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform our contract with you (account management, payment processing, game access).
• Legal Obligation: Processing required to comply with applicable laws, including AML regulations, PAGCOR requirements, and NPC directives.
• Legitimate Interests: Processing necessary for phmerry's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

phmerry does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only where necessary and lawful:

• Payment Processors: GCash, PayMaya (Maya), and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive financial data necessary to process your transactions. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity Verification Providers: Third-party KYC (Know Your Customer) service providers who assist in verifying your identity and age as required by law.
• Fraud Prevention Services: Specialist providers who help detect and prevent fraudulent activity, money laundering, and other prohibited conduct on the platform.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where disclosure is required by law or regulatory obligation.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors where necessary for legal compliance, dispute resolution, or business operations, subject to confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of phmerry's business, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7. Cookies & Tracking Technologies

phmerry uses cookies and similar technologies (web beacons, pixel tags, local storage) to operate and improve the platform. The following types of cookies are used:

• 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.
• Performance Cookies: Collect anonymized data about how players use the platform (e.g., pages visited, errors encountered) to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (e.g., language settings, game display preferences) to provide a more personalized experience.
• Analytics Cookies: Used to analyze aggregate usage patterns and measure the effectiveness of platform features. Data collected is anonymized and not linked to individual players.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the phmerry platform. Strictly necessary cookies cannot be disabled as they are required for the platform to operate securely.

8. Data Retention

phmerry retains your personal data for as long as necessary to fulfill the purposes described in this policy, subject to the following retention principles:

• Active Accounts: Personal data is retained for the duration of your account's active status and for a period thereafter as required by law or legitimate business need.
• Closed Accounts: Following account closure, phmerry retains identity, financial, and transaction data for a minimum of five (5) years in compliance with Philippine AML regulations and PAGCOR requirements.
• Support Communications: Customer support records are retained for three (3) years from the date of the interaction.
• Marketing Data: Where you have consented to marketing communications, your contact details for this purpose are retained until you withdraw consent or request deletion.
• Technical Logs: Server logs and technical data are retained for up to twelve (12) months for security and fraud prevention purposes.

When personal data is no longer required, phmerry securely deletes or anonymizes it in accordance with industry best practices.

9. Data Security

phmerry implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and phmerry's servers is encrypted using TLS 1.2 or higher. Sensitive data stored in our systems is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized phmerry personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular privacy training.
• Two-Factor Authentication: phmerry offers two-factor authentication (2FA) for player accounts and requires it for administrative access to systems containing personal data.
• Penetration Testing: phmerry's systems undergo regular security assessments and penetration testing by qualified third-party security professionals.
• Incident Response: phmerry maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, phmerry will notify the National Privacy Commission and affected players in accordance with NPC requirements.

While phmerry takes all reasonable steps to protect your data, no security system is completely impenetrable. You are also responsible for maintaining the security of your account credentials. Please refer to Section 4 of our Terms and Conditions for your account security obligations.

10. Your Data Privacy Rights

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

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which this Privacy Policy fulfills.
• Right of Access: The right to request a copy of the personal data phmerry holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your phmerry account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phmerry's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phmerry has violated your data privacy rights.

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

11. Children's Privacy & Age Restriction

phmerry is strictly an adult platform. The minimum age to register and use phmerry is twenty-one (21) years, in accordance with Philippine gaming regulations. phmerry does not knowingly collect personal data from individuals under the age of 21.

If phmerry becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately closed, the data will be deleted in accordance with applicable regulations, and any funds in the account will be handled as required by law.

Parents and guardians who believe their child may have registered on phmerry are urged to contact our Data Protection Officer immediately using the details in Section 14.

12. Third-Party Links

The phmerry platform may contain links to third-party websites or services (for example, payment provider portals). This Privacy Policy applies only to phmerry and does not cover the privacy practices of any third-party websites or services. phmerry is not responsible for the privacy practices or content of third-party sites.

We encourage you to review the privacy policies of any third-party services you access in connection with your use of phmerry, particularly payment processors such as GCash and PayMaya.

13. Changes to This Privacy Policy

phmerry reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, phmerry will notify registered players via email or a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the policy was most recently revised. Your continued use of phmerry following the effective date of any revised policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you must stop using phmerry and may close your account by contacting customer support.

We recommend reviewing this Privacy Policy periodically to stay informed of how phmerry protects your personal data.

14. Contact & Data Protection Officer

phmerry has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests regarding your personal data or this policy, please contact:

For responsible gaming support, please visit our Responsible Gaming page.