phtt Privacy Policy

1. Introduction and Scope

phtt ("phtt", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who use our online casino and sports betting platform at https://phtt.one (the "Platform"). This Privacy Policy ("Policy") describes how phtt collects, uses, discloses, stores, and otherwise processes personal data relating to players, visitors, and prospective users of the phtt Platform.

This Policy applies to all personal data processed by phtt in connection with the provision of the phtt Platform, including account registration, identity verification (KYC), deposit and withdrawal processing, gameplay, customer support, and marketing communications. This Policy should be read together with phtt's Terms & Conditions and Responsible Gaming Policy.

By registering for a phtt account or otherwise using the phtt Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you should not use the phtt Platform.

2. Data Controller

phtt is the data controller responsible for the personal data collected through the phtt Platform. As data controller, phtt determines the purposes and means of processing your personal data and is accountable for compliance with applicable data protection law, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

For all data privacy matters, including requests to exercise your rights under applicable law, you may contact phtt's designated Data Protection Officer at [email protected].

3. Personal Data We Collect

phtt collects and processes the following categories of personal data:

3.1 Registration and Identity Data

• Full name as it appears on a government-issued Philippine identification document;
• Date of birth (used to verify you are at least 21 years of age);
• Registered mobile number (Philippine mobile number format);
• Email address;
• Residential address (city/municipality, province, Philippines);
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

• Copy of a valid Philippine government-issued identification document (e.g., PhilSys National ID, UMID, passport, driver's licence, voter's ID);
• Selfie or live photograph for identity matching purposes where required;
• Proof of address documentation where requested.

3.3 Financial and Transaction Data

• GCash account reference or Maya account details (account holder name and registered number);
• BPI, BDO, Metrobank, or other bank account details used for deposits and withdrawals;
• Deposit and withdrawal history, including amounts (in Philippine Peso) and timestamps;
• Transaction reference numbers.

3.4 Gaming and Activity Data

• Betting and wagering history across all phtt game categories;
• Game session durations and activity timestamps;
• Bonus and promotion redemption history;
• Responsible gaming settings you have configured on your phtt account.

3.5 Technical and Device Data

• IP address;
• Device type, operating system, and browser information;
• Session identifiers and cookie data;
• Geolocation data (country/region level, derived from IP address).

3.6 Communications Data

• Records of customer support interactions via live chat or email;
• Records of complaints and dispute communications;
• Marketing communication preferences.

4. How We Collect Your Data

phtt collects personal data through the following means:

• Directly from you — when you register a phtt account, complete KYC verification, make deposits or withdrawals, contact phtt support, or respond to surveys or promotions;
• Automatically through platform usage — when you access the phtt Platform, our servers and analytics tools automatically collect technical and activity data as described in Section 3.4 and 3.5;
• From third-party payment processors — when you transact via GCash, Maya, or bank transfer, the payment processor provides phtt with transaction confirmation data necessary to credit your account;
• From identity verification services — phtt may use third-party KYC and identity verification providers to assist with validating government-issued Philippine IDs and other verification documents.

5. Purposes and Legal Basis for Processing

phtt processes your personal data for the following purposes and on the following legal bases:

• Account creation and management — necessary for the performance of the contract between you and phtt (our Terms & Conditions);
• Identity verification and KYC compliance — compliance with legal obligations under PAGCOR regulations and Philippine Anti-Money Laundering Act (AMLA) requirements;
• Payment processing — necessary for performance of the contract and to facilitate deposits and withdrawals in Philippine Peso;
• Fraud prevention and security — necessary for phtt's legitimate interests in protecting the integrity of the platform and preventing financial crime;
• Regulatory reporting — compliance with PAGCOR reporting obligations and Anti-Money Laundering Council (AMLC) requirements;
• Customer support — necessary for the performance of the contract and phtt's legitimate interest in resolving player issues;
• Responsible gaming monitoring — compliance with PAGCOR responsible gaming requirements and phtt's legitimate interest in player protection;
• Marketing communications — based on your consent, where you have opted in to receive phtt promotional communications. You may withdraw consent at any time by contacting phtt support;
• Platform improvement and analytics — phtt's legitimate interest in improving the phtt Platform and user experience, using aggregated and anonymised data where possible.

6. Disclosure of Personal Data

phtt does not sell your personal data. phtt may disclose your personal data to the following categories of recipients only where necessary and under appropriate safeguards:

• Payment processors — GCash (GCash/Mynt), Maya Philippines, BancNet, and other payment infrastructure providers required to process your transactions;
• Game content providers — licensed third-party game studios whose games are available on phtt, limited to session identifiers and game activity necessary to operate the games;
• Identity verification providers — third-party KYC service providers used to verify Philippine government-issued identification documents;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other applicable Philippine government agencies where required by law;
• Law enforcement — where phtt is required or authorised by applicable Philippine law to disclose information to law enforcement authorities;
• Professional advisers — lawyers, auditors, and compliance consultants engaged by phtt, under confidentiality obligations;
• Business successors — in the event of a merger, acquisition, or sale of phtt's assets, your data may be transferred to the successor entity subject to equivalent privacy protections.

All third-party recipients are required by phtt to process your personal data only for the specified purpose and under contractual obligations consistent with applicable data protection law.

7. Data Retention

phtt retains your personal data for as long as your phtt account is active and for a period thereafter as required by applicable law and regulation. Specifically:

• Transaction and financial records are retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AMLA regulations;
• KYC and identity verification documents are retained for a minimum of five (5) years from account closure or the date of the last transaction, whichever is later;
• Account activity and gaming history records are retained for five (5) years from the date of the activity;
• Customer support records are retained for three (3) years from the date of the support interaction.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with phtt's data retention procedures.

8. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and phtt's servers;
• Encryption of sensitive data at rest, including passwords (stored as salted cryptographic hashes) and financial account references;
• Access controls limiting personal data access to authorised phtt personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the phtt Platform;
• Two-factor authentication available for phtt player accounts.

While phtt takes data security seriously, no internet-based platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, phtt will notify you and the National Privacy Commission (NPC) in accordance with applicable Philippine law.

9. Cookies and Tracking Technologies

phtt uses cookies and similar tracking technologies to operate the Platform and analyse usage. The categories of cookies used by phtt include:

• Strictly necessary cookies — required for the phtt Platform to function, including session management and security tokens. These cannot be disabled.
• Analytics cookies — used by phtt to understand how players use the Platform in aggregate, enabling performance improvements. Analytics data is anonymised where possible.
• Preference cookies — used to remember your Platform preferences, such as language settings.

You can manage or block non-essential cookies through your browser settings. Blocking strictly necessary cookies may impair the functionality of the phtt Platform. phtt does not use third-party advertising cookies or sell browsing data to advertising networks.

10. Your Data Rights

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by phtt:

• Right to be informed — the right to know what personal data phtt collects and how it is used, as set out in this Policy;
• Right of access — the right to request a copy of the personal data phtt holds about you;
• Right to rectification — the right to request correction of inaccurate or incomplete personal data;
• Right to erasure or blocking — the right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, subject to applicable legal retention requirements;
• Right to data portability — the right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to object — the right to object to processing based on phtt's legitimate interests, including direct marketing;
• Right to lodge a complaint — the right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe phtt has violated your data privacy rights.

To exercise any of these rights, please contact phtt's Data Protection Officer at [email protected]. phtt will respond to your request within thirty (30) days of receipt, as required under applicable law.

11. Children's Privacy

The phtt Platform is strictly for adults aged 21 years and older, in compliance with PAGCOR's age restriction requirements for online gaming in the Philippines. phtt does not knowingly collect personal data from individuals under 21 years of age. If phtt becomes aware that personal data has been collected from an underage person, such data will be deleted immediately and the associated account will be closed without refund of any deposited funds, which may be subject to regulatory forfeiture procedures.

If you have reason to believe that a person under 21 years of age has registered on phtt, please notify us immediately at [email protected].

12. Cross-Border Data Transfers

phtt primarily stores and processes personal data within secure infrastructure serving the Philippine market. In limited circumstances, personal data may be transferred to or accessed by phtt's service providers located outside the Philippines — for example, game content providers operating certified studios in other jurisdictions.

Where such transfers occur, phtt ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Philippine Data Privacy Act and its Implementing Rules and Regulations. phtt will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or applicable legal authorisation.

13. Changes to This Privacy Policy

phtt reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or phtt's data processing practices. The effective date of the current version is stated at the top of this page.

Where a material change is made to this Policy, phtt will notify registered players through the phtt Platform or via the email address associated with the player's phtt account. Continued use of the phtt Platform following the effective date of any revised Policy constitutes acceptance of the updated terms.

14. Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or phtt's processing of your personal data, please contact phtt's Data Protection Officer using the following details:

• Email: [email protected]
• Live Chat: Available 24/7 through the phtt Platform

If you are not satisfied with phtt's response to your privacy concern, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). For information about the NPC and how to file a complaint, please visit the NPC's official resources.