Privacy Policy – phjoint

1. Introduction

phjoint ("phjoint," "we," "us," "our") is committed to safeguarding the privacy and personal data of all individuals who access or use the phjoint Platform at phjoint.org (the "Platform"). This Privacy Policy ("Policy") describes how phjoint collects, uses, stores, shares, and protects personal information in connection with the Platform and all services offered therein.

This Policy applies to all registered players, prospective players, and any other individuals whose personal data phjoint processes in connection with the operation of the Platform. By creating a phjoint account or using any phjoint service, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

phjoint processes personal data in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its implementing rules and regulations, and the issuances of the National Privacy Commission ("NPC"). Our processing activities are also subject to applicable PAGCOR regulatory requirements concerning player data and anti-money laundering controls.

2. Data We Collect

phjoint collects personal data that is necessary, adequate, and relevant to the purposes for which it is processed. The categories of personal data we may collect include:

2.1 Registration Data

• Full legal name as it appears on a valid Philippine government-issued ID.
• Date of birth (for mandatory 21+ age verification).
• Philippine mobile number (used as primary account identifier and OTP delivery channel).
• Email address (optional but used for account communications where provided).
• Residential address within the Philippines.
• Username and password (password is stored in hashed, non-reversible form).

2.2 Verification Data

• Government-issued photo ID (e.g., PhilSys ID, passport, driver's license, SSS or GSIS card, Voter's ID) for KYC verification.
• Proof of address documents (e.g., utility bill, bank statement) where required.
• Selfie or live photo for identity matching during verification, where applicable.

2.3 Financial Data

• GCash or Maya mobile wallet numbers linked to your account for deposit and withdrawal transactions.
• Bank account details (account name, account number, bank name) where bank transfer is used.
• Transaction history — deposits, withdrawals, and game wager/win records maintained for regulatory and operational purposes.

2.4 Technical & Usage Data

• IP address at the time of login and during active sessions.
• Device type, operating system, and browser information.
• Session duration, pages visited, and game activity logs.
• Geolocation data (country and region level) derived from IP address to verify jurisdictional eligibility.
• Cookie identifiers and similar tracking technologies (see Section 8).

2.5 Communications Data

• Records of your interactions with phjoint Customer Support, including live chat transcripts, where retained for quality assurance and dispute resolution.
• Feedback, survey responses, and promotional communications responses where voluntarily provided.

3. How We Use Your Data

phjoint uses personal data collected from players for the following purposes:

• Account Creation and Management: To register your account, verify your identity and age, manage your profile, and provide access to the Platform.
• KYC and Regulatory Compliance: To fulfil PAGCOR's Know Your Customer requirements and anti-money laundering obligations under Philippine law, including verifying the source of funds for large transactions.
• Payment Processing: To process deposits, withdrawals, and refunds through your linked GCash, Maya, or bank account.
• Gaming Services: To provide, operate, and improve the games and features available on the Platform, including maintaining fair play records and resolving disputes.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct.
• Responsible Gaming: To monitor gaming behavior patterns that may indicate problem gambling, to apply player-requested limits and self-exclusion orders, and to provide responsible gaming support.
• Customer Support: To respond to your queries, resolve complaints, and provide assistance via live chat and email support channels.
• Marketing Communications: To send you information about promotions, bonuses, and new Platform features — only where you have opted in to receive such communications. You may opt out at any time via your account settings or by contacting support.
• Platform Improvement: To analyze aggregated, anonymized usage data to improve the Platform's functionality, game selection, and user experience.
• Legal Obligations: To comply with applicable laws, regulations, court orders, and regulatory directions from PAGCOR, the NPC, and other competent Philippine government authorities.

4. Legal Basis for Processing

phjoint processes personal data on the following legal bases, as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary for the performance of the contract between you and phjoint — i.e., the Terms & Conditions you accepted upon registration — including account management, payment processing, and game delivery.
• Legal Obligation: Processing required by applicable law, including PAGCOR licensing conditions, anti-money laundering regulations under the AMLA, and NPC data governance requirements.
• Legitimate Interests: Processing necessary for phjoint's legitimate business interests, including fraud prevention, Platform security, and responsible gaming monitoring, provided such interests do not override your fundamental privacy rights.
• Consent: Where phjoint seeks your explicit consent for specific processing activities (such as optional marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing

phjoint does not sell, rent, or otherwise commercially disclose your personal data to third parties. We may share personal data in the following limited circumstances:

• Payment Service Providers: GCash, Maya, BPI, BDO, Metrobank, UnionBank, Coins.ph, and other payment processors receive only the minimum personal data necessary to process your transactions.
• Game Providers: Licensed game studios and providers may receive anonymized or pseudonymized session data necessary for game delivery and fairness auditing. Personal identifiers are not shared with game providers.
• KYC and Verification Partners: Identity verification service providers used for document checking and age verification receive the specific data submitted for verification purposes under strict data processing agreements.
• Regulatory and Law Enforcement: phjoint may disclose personal data to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), the National Bureau of Investigation (NBI), or other competent Philippine government authorities where required by law or in response to a valid legal order.
• Professional Advisors: Legal counsel, accountants, and auditors may access personal data strictly as necessary for the provision of professional services, subject to confidentiality obligations.

6. Data Security

phjoint implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phjoint Platform.
• Encrypted storage for sensitive personal data, including passwords (stored in hashed, non-reversible form) and financial account identifiers.
• Role-based access controls ensuring that phjoint employees can only access personal data necessary for their specific function.
• Regular security audits and penetration testing conducted by independent third-party security firms.
• Two-factor authentication (OTP via registered mobile number) for account access and sensitive account changes.
• Automated fraud detection systems that monitor transaction patterns and account activity for anomalies in real time.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be completely secure. phjoint encourages all players to maintain strong, unique passwords and to avoid accessing their phjoint account from public or unsecured Wi-Fi networks.

In the event of a personal data breach that poses a real risk to the rights and freedoms of affected players, phjoint will notify the NPC and affected individuals in accordance with the timelines and procedures prescribed by the Data Privacy Act and its implementing rules.

7. Data Retention

phjoint retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve any disputes that may arise. Our general retention guidelines are as follows:

• Active Account Data: Retained for the duration of the account relationship and for a period of at least five (5) years thereafter, in compliance with PAGCOR record-keeping requirements and Philippine anti-money laundering laws.
• Transaction Records: Deposit, withdrawal, and wager records are retained for a minimum of five (5) years from the date of the transaction, in accordance with AMLC regulatory requirements.
• KYC Verification Documents: Retained for the duration of the account relationship plus five (5) years, or longer if required by applicable regulation or ongoing legal proceedings.
• Support Interaction Records: Customer support communications are retained for up to two (2) years from the date of the interaction, unless required for longer periods to support unresolved disputes.
• Marketing Data: Retained until you withdraw consent to receive marketing communications, or for a maximum of three (3) years from the date of last interaction with a marketing communication, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents re-identification.

8. Cookies & Tracking Technologies

phjoint uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies may be used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly — including session management, login authentication, and security. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, last game played, and interface display preferences, to provide a more personalized experience.
• Analytics Cookies: Used to collect anonymized, aggregated data about how players navigate and use the Platform, enabling phjoint to identify and fix usability issues and improve the overall experience.
• Security & Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, including identifying unusual login patterns or suspicious account behavior.

You may manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality and availability of some Platform features. phjoint does not use cookies to serve third-party advertising on the Platform.

9. Your Data Rights

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

To exercise any of the above rights, please contact phjoint Customer Support via the live chat function or by email. phjoint will respond to all data rights requests within the timeframes prescribed by the Data Privacy Act. Where a request cannot be fulfilled due to overriding legal or regulatory obligations, phjoint will explain the reason in writing.

If you believe phjoint has not adequately addressed a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

10. Children & Minors

Parents and guardians who believe a minor may have accessed phjoint are encouraged to contact our support team immediately via live chat. phjoint will investigate such reports promptly and take appropriate remedial action.

11. Third-Party Links

The phjoint Platform may contain references or links to third-party payment service providers (such as GCash and Maya) and other external services. phjoint is not responsible for the privacy practices of third-party websites or services. We encourage you to review the privacy policies of any third-party services you access in connection with using phjoint. This Policy applies solely to personal data processed by phjoint in connection with the Platform.

12. International Data Transfers

Where phjoint engages service providers or infrastructure partners located outside the Philippines — for example, cloud hosting or game content delivery — personal data may be transferred to and processed in jurisdictions outside the Philippines. phjoint ensures that any such international transfer of personal data is subject to appropriate safeguards consistent with the Data Privacy Act of 2012, including contractual data protection obligations with receiving parties that provide protections at least equivalent to those under Philippine law.

13. Policy Updates

phjoint reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or our data processing practices. When material changes are made, the "Last Updated" date at the top of this page will be revised. Where changes are significant, phjoint will provide notice to registered players via in-platform notification or email.

Your continued use of the phjoint Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree to any updated Policy, you must cease use of the Platform and may request account closure by contacting phjoint Customer Support.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or phjoint's handling of your personal data, please contact our Data Privacy team through any of the following channels:

• Live Chat: Available 24/7 via the phjoint Platform — the fastest way to reach us for any data privacy matter.
• Email: [email protected] (plain text — not a clickable link). Please include "Privacy" in your subject line for faster routing to the data privacy team.

phjoint aims to acknowledge all data privacy enquiries within two (2) business days and to resolve them within the timeframes specified by the Data Privacy Act of 2012.