phtt Privacy Policy

1Introduction

1.1 This Privacy Policy ("Policy") is issued by phtt ("phtt," "we," "us," or "our") and governs the collection, use, storage, and disclosure of personal data obtained from individuals ("you," "User," or "Player") who access or use the phtt platform at phtt.asia and any related services.

1.2 phtt is committed to protecting the privacy and security of your personal data in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA"), its Implementing Rules and Regulations, and other applicable Philippine data protection laws and regulations.

1.3 By registering a phtt account, completing the phtt Login process, or otherwise using phtt.asia, you acknowledge that you have read, understood, and agree to the collection and use of your personal data as described in this Policy.

1.4 This Policy should be read in conjunction with the phtt Terms and Conditions, which govern the overall relationship between you and phtt. In the event of any conflict between this Policy and the Terms and Conditions regarding data privacy, this Policy shall prevail.

2Personal Data We Collect

2.1 Registration Data. When you create a phtt account, we collect: full legal name; date of birth (to verify the 21+ age requirement); Philippine mobile number; email address; residential address; and username and password credentials for your phtt login.

2.2 Identity Verification Data. To comply with PAGCOR regulations and anti-money laundering requirements under Philippine law, phtt may collect copies of government-issued identity documents (e.g., PhilSys National ID, passport, driver's licence, UMID), selfie photographs for facial verification, and proof of address documents.

2.3 Financial Data. When you conduct transactions through phtt, we collect payment method details (e.g., GCash account reference, Maya wallet reference, bank account identifiers), deposit and withdrawal history, and transaction amounts in Philippine Peso (PHP).

2.4 Gaming Activity Data. phtt records game session logs, bet amounts, win/loss results, game preferences, and responsible gaming tool settings associated with your phtt account.

2.5 Technical Data. We automatically collect IP address, device type and operating system, browser type and version, session timestamps, page visit logs, and referral source data when you access phtt.asia.

2.6 Communications Data. If you contact phtt support at [email protected] or via any other support channel, we retain records of your communications including the content of messages, timestamps, and any resolutions provided.

2.7 Marketing Preferences. We record your consent status and preferences regarding promotional communications from phtt.

3How We Use Your Personal Data

3.1 phtt uses your personal data for the following purposes:

• Account Management: To create, verify, and maintain your phtt account, process your phtt login, and provide you with access to games and services on the platform;
• Identity Verification & Compliance: To verify your identity and age (21+), comply with PAGCOR regulatory requirements, and fulfil anti-money laundering (AML) and Know Your Customer (KYC) obligations under Philippine law;
• Transaction Processing: To process deposits, withdrawals, and other financial transactions through GCash, Maya, and other supported Philippine payment methods;
• Platform Improvement: To analyse usage patterns, diagnose technical issues, optimise platform performance, and develop new features based on how Filipino players use phtt;
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling, enforce deposit limits and self-exclusion requests, and fulfil responsible gaming obligations;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, money laundering, and other prohibited activities;
• Customer Support: To respond to your queries, complaints, and support requests submitted to [email protected];
• Marketing Communications: To send you promotional offers, bonuses, and platform updates where you have provided consent — and only for as long as that consent remains valid.

4Legal Basis for Processing

4.1 phtt processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing necessary to fulfil phtt's obligations under the Terms and Conditions you agreed to at registration (account management, payment processing, game access);
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML laws, and tax obligations;
• Legitimate Interest: Processing necessary for phtt's legitimate interests in fraud prevention, platform security, and responsible gaming compliance, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications, where phtt relies on your freely given, specific, and informed consent as the legal basis.

5Data Sharing and Disclosure

5.1 phtt does not sell, rent, or trade your personal data to any third party for their own independent marketing or commercial purposes.

5.2 phtt may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection obligations:

• Payment Service Providers: GCash (GXI Inc.), Maya (Maya Philippines Inc.), and other Philippine payment processors, to facilitate deposits and withdrawals from your phtt account;
• Identity Verification Providers: Third-party KYC service providers engaged by phtt to verify player identity in compliance with regulatory requirements;
• Game Content Providers: Game software providers whose titles are available on the phtt platform, to the extent necessary to facilitate game access and resolve disputes;
• Regulatory Authorities: PAGCOR and other competent Philippine government authorities, where required by law or regulatory order;
• Law Enforcement: Philippine law enforcement agencies and the Anti-Money Laundering Council (AMLC), where phtt is legally required or permitted to disclose information in connection with the investigation of crime;
• Professional Advisers: Legal, financial, and compliance advisers engaged by phtt, subject to professional confidentiality obligations.

5.3 In the event of a corporate restructuring, merger, acquisition, or sale of phtt's business or assets, your personal data may be transferred to a successor entity, subject to equivalent data protection commitments.

6Cookies and Tracking Technologies

6.1 phtt uses cookies and similar tracking technologies (collectively, "Cookies") on phtt.asia to ensure the platform functions correctly, remember your preferences, and analyse how players interact with the site.

6.2 The following types of Cookies are used by phtt:

• Essential Cookies: Required for core platform functionality including your phtt login session, security tokens, and language preferences. These cannot be disabled without impairing your ability to use phtt;
• Analytics Cookies: Used to collect aggregated data about platform usage to help phtt improve performance and the player experience;
• Preference Cookies: Used to remember settings and preferences you have selected during your phtt session.

6.3 You may control or delete Cookies through your browser settings at any time. Disabling non-essential Cookies will not prevent you from accessing phtt, but may affect the quality of your experience on the platform.

7Data Retention

7.1 phtt retains your personal data for as long as your phtt account remains active and for a minimum period of five (5) years following account closure, or such longer period as required by applicable Philippine law (including AML retention requirements).

7.2 Gaming transaction records and financial data may be retained for up to ten (10) years where required by PAGCOR regulations or applicable tax laws.

7.3 Communications data (support interactions) is retained for a period of three (3) years from the date of the communication unless a longer retention period is required for the resolution of a dispute or legal proceeding.

7.4 Where personal data is no longer required for any legitimate purpose, phtt will securely delete or anonymise it in accordance with industry-standard data destruction practices.

8Data Security

8.1 phtt implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include 256-bit SSL/TLS encryption for all data in transit, encryption of sensitive data at rest, access controls restricting data access to authorised personnel, regular security assessments and penetration testing, and employee data protection training.

8.2 In the event of a personal data breach that is likely to adversely affect your rights and freedoms, phtt will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Philippine Data Privacy Act.

9Your Data Rights

9.1 Under the Philippine Data Privacy Act, as a phtt account holder you have the following rights in relation to your personal data:

• Right to be Informed: You have the right to be informed that your personal data is being collected and processed by phtt, and the purposes for which it is being used;
• Right of Access: You have the right to request a copy of the personal data phtt holds about you;
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data held in your phtt account;
• Right to Erasure: You have 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 phtt's legal retention obligations;
• Right to Object: You have the right to object to processing of your personal data where phtt relies on legitimate interest as the legal basis, and to withdraw consent to marketing communications at any time;
• Right to Data Portability: You have the right to receive personal data you have provided to phtt in a structured, commonly used, and machine-readable format.

9.2 To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Privacy Request." phtt will respond within thirty (30) days of receiving a complete and valid request. Identity verification may be required before processing your request.

9.3 If you believe phtt has not addressed your data privacy concerns adequately, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).

10Children's Privacy

10.1 phtt does not knowingly collect personal data from individuals under the age of 21. The phtt platform is strictly for adults aged 21 and above in compliance with Philippine law and PAGCOR regulations. If phtt becomes aware that personal data has been collected from a person under 21, that account will be immediately closed and the data deleted.

10.2 If you are a parent or guardian and believe your child has provided personal information to phtt, please contact us at [email protected] immediately so that we can take appropriate action.

11International Data Transfers

11.1 phtt's primary data processing infrastructure is located within or accessible from the Philippines. Where personal data is processed by third-party service providers outside the Philippines (for example, cloud infrastructure providers), phtt ensures that appropriate safeguards are in place, including contractual data protection obligations consistent with the requirements of the Philippine Data Privacy Act.

11.2 phtt will not transfer your personal data to a country that does not provide an adequate level of data protection without first implementing appropriate safeguards as required by applicable Philippine data protection law.

12Changes to This Privacy Policy

12.1 phtt reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, platform services, or applicable legal requirements. When material changes are made, phtt will notify registered users by in-platform notification or by email to the address registered on your phtt account, at least seven (7) days before the updated Policy takes effect.

12.2 Your continued use of the phtt platform after the effective date of any updated Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.

13Contact Us

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

13.2 phtt is committed to resolving all data privacy concerns promptly and transparently. If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission of the Philippines.