Privacy Policy – phdream22

phdream22 ("we," "us," "our," or "phdream22") operates the online gaming platform accessible at phdream22.club and any associated mobile applications (collectively, the "Platform"). phdream22 is the data controller responsible for the personal data you provide when using our Platform.

This Privacy Policy applies to all personal data collected by phdream22 in connection with your use of the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and marketing communications.

phdream22 operates within the regulatory framework established by the Philippine Amusement and Gaming Corporation ("PAGCOR") and is committed to upholding the privacy rights of all Filipino players in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR").

phdream22 collects the following categories of personal data from players and visitors to the Platform:

Identity Data:

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — you must be 21 or older);
• Gender;
• Nationality and country of residence;
• Government-issued identification number (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS number).

Contact Data:

• Email address;
• Mobile phone number;
• Residential address (barangay, city/municipality, province, ZIP code).

Financial Data:

• GCash or PayMaya account details (mobile number associated with the account);
• Bank account details for bank transfer transactions (account name, account number, bank name);
• Debit card details (card number, expiry date — stored in tokenised form only);
• Transaction history, including deposit amounts, withdrawal amounts, and dates.

Technical & Usage Data:

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Pages visited, features used, and time spent on the Platform;
• Game history, wagering activity, and session logs;
• Login timestamps and session duration.

Communications Data:

• Records of your communications with phdream22 customer support, including live chat transcripts and email correspondence;
• Feedback, survey responses, and promotional opt-in preferences.

phdream22 collects personal data through the following means:

• Direct collection: Data you provide when registering for a phdream22 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, log files, and similar tracking technologies when you access the Platform;
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash and Maya; and publicly available data from government registries where permitted by law.

phdream22 uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phdream22 account, including verifying your identity and age;
• Service delivery: To provide you with access to games, process deposits and withdrawals, and deliver customer support;
• Legal and regulatory compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the DPA, and other applicable Philippine laws and regulations;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct;
• Responsible gaming: To monitor gaming behaviour and enforce responsible gaming tools such as deposit limits, loss limits, and self-exclusion;
• Marketing and communications: To send you promotional offers, newsletters, and platform updates, where you have consented to receive such communications;
• Platform improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the phdream22 Platform;
• Dispute resolution: To investigate and resolve complaints, disputes, and legal claims.

phdream22 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform our contract with you (i.e., to provide the phdream22 gaming services you have registered for);
• Legal obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA obligations, and tax reporting requirements;
• Legitimate interests: Processing is necessary for phdream22's legitimate interests, including fraud prevention, platform security, and business analytics, provided such interests are not overridden by your privacy rights;
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

phdream22 may share your personal data with the following categories of recipients:

• Payment processors: GCash, Maya, and banking partners, for the purpose of processing your deposits and withdrawals;
• KYC and identity verification providers: Third-party service providers that assist phdream22 in verifying your identity and age in compliance with PAGCOR and AMLA requirements;
• Fraud prevention and security partners: Service providers that assist phdream22 in detecting and preventing fraudulent activity;
• IT and platform service providers: Cloud hosting, data storage, and software providers that support the operation of the phdream22 Platform, subject to strict data processing agreements;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission ("NPC"), and other Philippine government authorities, where required by law or regulation;
• Legal and professional advisers: Lawyers, accountants, and auditors, where necessary for the conduct of phdream22's business or the resolution of legal disputes.

All third parties with whom phdream22 shares personal data are required to handle such data in accordance with the DPA and are bound by appropriate data processing agreements or equivalent contractual safeguards.

phdream22 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation.

The following retention periods apply as a general guide:

• Account data: Retained for the duration of your account and for a period of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and its implementing regulations;
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by AMLA;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing preferences: Retained until you withdraw your consent or request deletion.

Upon expiry of the applicable retention period, phdream22 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

phdream22 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phdream22 Platform;
• Encryption of sensitive data at rest, including financial data and government ID numbers;
• Access controls limiting access to personal data to authorised personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Two-factor authentication options for player accounts;
• Incident response procedures for detecting, reporting, and responding to personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phdream22 will notify the National Privacy Commission and affected players in accordance with the DPA and NPC Circular No. 16-03.

While phdream22 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your phdream22 account credentials.

phdream22 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver relevant content. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences and settings, such as language and display options, to personalise your experience.
• Analytics cookies: Collect anonymised data about how you use the Platform, helping phdream22 understand which features are most popular and where improvements can be made.
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of phdream22's marketing campaigns, where you have consented to receive marketing communications.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phdream22 Platform. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

phdream22 does not use cookies to collect sensitive personal data such as financial information or government ID numbers.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phdream22:

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14 of this Policy. phdream22 will respond to your request within fifteen (15) business days. We may need to verify your identity before processing your request.

If you believe phdream22 has not handled your personal data in accordance with the DPA, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

phdream22 implements age verification procedures during the registration process to prevent minors from accessing the Platform. If phdream22 becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete such data and close the associated account.

If you are a parent or guardian and believe that your child has registered on phdream22 without your consent, please contact our support team immediately so we can investigate and take appropriate action.

In certain circumstances, phdream22 may transfer your personal data to service providers or partners located outside the Philippines, for example, cloud hosting providers or international KYC verification services. Where such transfers occur, phdream22 ensures that appropriate safeguards are in place to protect your personal data, including:

• Entering into data processing agreements that incorporate standard contractual clauses approved by the National Privacy Commission;
• Transferring data only to countries or organisations that provide an adequate level of data protection as determined by the NPC;
• Obtaining your explicit consent for the transfer where required by the DPA.

phdream22 will not transfer your personal data to any jurisdiction where doing so would violate applicable Philippine law or compromise the protections afforded to you under the DPA.

phdream22 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email or by posting a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how phdream22 is protecting your personal data. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy.

phdream22 has appointed a Data Protection Officer ("DPO") in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our DPO using the details below:

When submitting a privacy request, please include your registered username, a clear description of your request, and any relevant account details to help us process your request efficiently. phdream22 may need to verify your identity before acting on your request.

For complaints that cannot be resolved directly with phdream22, you may contact the National Privacy Commission (NPC) of the Philippines through its official channels.