phlgo Privacy Policy

1. Scope and Application

This Privacy Policy applies to all personal data collected, processed, and stored by phlgo in connection with your use of the phlgo online gaming platform accessible at phlgo.cam (the "Platform"), including all associated pages, services, and features.

This Policy applies to all registered users, visitors, and any individuals whose personal data is processed by phlgo in the course of delivering its services to Filipino players across the Philippines. By registering an account with phlgo or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy is issued in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

2. Personal Data We Collect

phlgo collects personal data that is necessary, proportionate, and limited to what is required to deliver our gaming services, meet our regulatory obligations, and protect the safety of the platform.

2.1 Identity and Account Data

• Full legal name as it appears on government-issued identification
• Date of birth (to verify the minimum age of 21 years)
• Nationality and country of residence
• Username and password (stored in hashed form — passwords are never stored in plain text)
• Registered email address
• Philippine mobile number

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, PhilSys National ID, SSS ID, UMID, PRC ID, or voter's ID)
• Proof of address documents (e.g., utility bills, bank statements dated within three months)
• Selfie or liveness verification image for identity matching purposes

2.3 Financial Transaction Data

• GCash or Maya account identifiers associated with your transactions
• Bank account numbers (BPI, BDO, Metrobank) used for deposits or withdrawals
• Card details for Visa and Mastercard transactions (processed via PCI-DSS compliant payment processors — full card numbers are not stored by phlgo)
• USDT wallet addresses for cryptocurrency transactions
• Transaction amounts, dates, and reference numbers
• Withdrawal requests and processing history

2.4 Gaming Activity Data

• Game sessions, bet history, wagering totals, and win/loss records
• Game type preferences and session duration data
• Bonus and promotion utilization history
• Self-exclusion and responsible gaming tool activations

2.5 Technical and Device Data

• IP address at time of login and registration
• Device type, operating system, and browser information
• Geolocation data (country and region level) to verify Philippine residency
• Session logs, including login timestamps and platform activity events
• Cookie identifiers and similar tracking technologies (see Section 7)

2.6 Communication Data

• Customer support ticket content and chat transcripts
• Email correspondence with phlgo support and compliance teams
• Survey responses and feedback submissions

3. How We Collect Your Data

phlgo collects personal data through the following means:

• Direct submission: Information you provide during account registration, KYC verification, payment setup, or customer support interactions.
• Automated collection: Technical data collected automatically when you access the Platform, including IP addresses, device data, and session logs.
• Third-party sources: Identity verification data from KYC service providers; transaction data from payment processors such as GCash, Maya, and banking partners; fraud detection signals from risk management partners.
• Cookies and tracking technologies: Data collected via cookies and similar technologies as described in Section 7.

4. How We Use Your Personal Data

phlgo uses your personal data for the following purposes:

Purpose	Description
Account management	Creating, maintaining, and securing your phlgo account; processing login and authentication.
KYC verification	Verifying your identity and age (21+) in compliance with PAGCOR regulations and Philippine AML law.
Payment processing	Processing PHP deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, Visa, Mastercard, and USDT.
Regulatory compliance	Fulfilling obligations under RA 9160 (Anti-Money Laundering Act), PAGCOR requirements, and NPC data privacy regulations.
Fraud and risk prevention	Detecting and preventing fraudulent activity, bonus abuse, multi-accounting, and unauthorized access.
Responsible gaming	Monitoring gaming patterns to support responsible gaming tools, self-exclusion enforcement, and player protection programmes.
Customer support	Responding to inquiries, resolving disputes, and improving platform experience.
Platform improvement	Analyzing aggregated, anonymized usage data to improve game offerings, site performance, and user experience.
Marketing communications	Sending promotional offers, bonus notifications, and platform updates — only with your consent, which you may withdraw at any time.

5. Legal Basis for Processing

phlgo processes your personal data on the following legal bases, consistent with the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill phlgo's obligations under the Terms & Conditions you agreed to upon registration, including account management and payment processing.
• Legal obligation: Processing required to comply with Philippine law, including KYC under PAGCOR regulations, AML reporting under RA 9160, and data protection obligations under RA 10173.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests do not override your fundamental data privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed, and freely given consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

phlgo does not sell, rent, or otherwise commercially transfer your personal data to third parties. We share personal data only in the following limited circumstances:

6.1 Service Providers and Processors

phlgo engages third-party service providers who process personal data on our behalf, subject to data processing agreements that require them to maintain appropriate data protection standards. These include:

• KYC and identity verification technology providers
• Payment processors and banking partners (GCash, Maya, BPI, BDO, Metrobank, Visa/Mastercard processors, and cryptocurrency exchange partners)
• Cloud infrastructure and hosting providers
• Fraud detection and risk management partners
• Customer support platform providers
• Email and SMS communication service providers

6.2 Regulatory and Law Enforcement Authorities

phlgo may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities when required by law, court order, or regulatory directive. phlgo will not disclose more information than is legally required in such circumstances.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving phlgo, personal data may be transferred as part of the transaction. Affected users will be notified by email prior to any such transfer, and the acquiring entity will be required to honor the commitments made in this Privacy Policy.

7. Cookies and Tracking Technologies

phlgo uses cookies and similar tracking technologies to operate the Platform, enhance your experience, and gather analytics data. By using the Platform, you consent to the use of cookies in accordance with this section.

7.1 Types of Cookies Used

• Strictly necessary cookies: Essential for the Platform to function, including session management, login authentication, and security tokens. These cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your preferences, such as language settings, and improve platform usability. Disabling these may affect your experience.
• Analytics cookies: Collect anonymized or pseudonymized data on how users interact with the Platform to help us identify errors and improve performance.
• Marketing cookies: Used only with your consent to track preferences and deliver relevant promotions. You may opt out at any time via your account preferences.

7.2 Managing Cookies

You may control cookie preferences through your browser settings or through the cookie preference center accessible on the Platform. Disabling strictly necessary cookies will prevent you from using phlgo's core functions, including account login.

8. Data Retention

phlgo retains personal data only for as long as is necessary for the purposes described in this Privacy Policy or as required by applicable Philippine law.

• Account and KYC data: Retained for the duration of the active account relationship and for five (5) years following account closure, in compliance with AML record-keeping requirements under RA 9160.
• Financial transaction records: Retained for a minimum of five (5) years as required by Philippine tax and AML regulations.
• Gaming activity logs: Retained for a minimum of two (2) years for responsible gaming monitoring and dispute resolution purposes.
• Customer support records: Retained for two (2) years following resolution of the relevant interaction.
• Marketing consent records: Retained for the duration of the consent plus two (2) years as an audit trail.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in a manner that prevents re-identification.

9. Security Measures

phlgo implements technical and organizational security measures appropriate to the risk level of the personal data we process. Key measures include:

• TLS/SSL encryption for all data transmitted between your browser and phlgo servers
• Encryption of sensitive data at rest, including KYC documents and financial identifiers
• Password hashing using industry-standard cryptographic algorithms
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Two-factor authentication available for all user accounts and mandatory for administrative access
• Regular penetration testing and vulnerability assessments by qualified security professionals
• Security monitoring and intrusion detection systems operating continuously
• Regular staff training on data protection and information security practices

10. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by phlgo:

• Right to be informed: You have the right to know what personal data phlgo holds about you and how it is being processed. This Privacy Policy fulfills our primary obligation to inform.
• Right of access: You may request a copy of the personal data phlgo holds about you at any time.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, provided there is no overriding legal obligation to retain it.
• Right to object: You have the right to object to processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You may request that your personal data be provided to you in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: If you believe phlgo has mishandled your personal data, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verifiable data subject requests within thirty (30) calendar days.

11. Minors and Age Restrictions

The phlgo platform is strictly for individuals who are 21 years of age or older. phlgo does not knowingly collect personal data from individuals under 21 years of age. If we become aware that personal data has been collected from an underage individual, we will immediately close the associated account and delete the relevant data, subject to any legal obligation to retain records of the violation.

If you are a parent or guardian and believe your child has registered on phlgo, please contact us immediately at [email protected] so we can investigate and take appropriate action.

12. Third-Party Links and Services

The phlgo platform does not contain outbound links to external websites. However, to the extent that third-party payment processors or game providers operate within the phlgo environment, their own privacy policies govern any data processing they perform directly. phlgo is not responsible for the privacy practices of third-party processors operating under their own data controller role.

13. Changes to This Privacy Policy

phlgo reserves the right to amend this Privacy Policy at any time. When material changes are made, we will update the effective date at the top of this page and notify registered users via email or on-platform notification prior to the changes taking effect. Your continued use of the Platform after such notification constitutes acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to remain informed about how phlgo protects your personal information.

14. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phlgo, please contact our Data Protection Officer:

Email: [email protected]
Subject Line: Privacy / Data Privacy Request

We are committed to addressing all data privacy inquiries promptly and in accordance with the obligations set out in the Data Privacy Act of 2012 and applicable NPC guidelines.

This Privacy Policy was last reviewed and updated on January 1, 2026. It supersedes all prior versions of the phlgo Privacy Policy. For previous versions, contact our Data Protection Officer.