phcku Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how phcku ("phcku," "we," "us," or "our") collects, uses, stores, and discloses personal data about individuals ("you" or "User") who access or use the phcku online gaming platform, including the website at phcku.app and any related mobile applications or services (collectively, the "Platform").

phcku is committed to protecting the privacy and security of your personal data. This Policy is intended to give you a clear and transparent account of our data practices so that you can make informed decisions about your use of the phcku Platform. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read alongside our Terms & Conditions, which govern your use of the phcku Platform.

2. Data Controller Information

phcku is the data controller responsible for the personal data collected through the Platform. As data controller, phcku determines the purposes and means of processing your personal data. If you have any questions or concerns about how phcku handles your personal data, please contact our Data Protection team via the live chat support available within the Platform, or by email at: [email protected]

3. Personal Data We Collect

phcku collects the following categories of personal data:

3.1 Identity and Contact Data:

• Full legal name
• Date of birth (for age verification purposes)
• Government-issued identification number
• Email address
• Mobile phone number
• Residential address (including city, province, and postal code)

3.2 Financial Data:

• GCash or Maya account details (account number/mobile number)
• Bank account details (for bank transfer transactions)
• Debit card details (card number, expiry date — stored in tokenised form only)
• Transaction history, including deposits, withdrawals, and wagers

3.3 Technical and Usage Data:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Login timestamps and session duration
• Pages visited and features used within the Platform
• Game history and wagering activity

3.4 Communications Data:

• Records of communications with phcku customer support
• Feedback, survey responses, and promotional opt-in preferences

4. How We Collect Your Data

phcku collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, or contacting customer support.
• Automated collection: Technical and usage data collected automatically when you access and use the Platform, including through cookies and similar tracking technologies.
• Third-party sources: Identity verification data from third-party KYC service providers; fraud prevention data from anti-fraud service providers; payment data from payment processors such as GCash and Maya.

5. How We Use Your Personal Data

phcku uses your personal data for the following purposes:

• Account management: To register and maintain your phcku account, verify your identity, and manage your account settings.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the core functionality of the Platform.
• Regulatory compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations, and other applicable Philippine laws and regulations, including mandatory age verification (21+).
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features and performance of the Platform.
• Marketing communications: To send you promotional offers and updates about phcku, where you have opted in to receive such communications. You may opt out at any time.

6. Legal Basis for Processing

phcku processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account registration, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable laws and regulations, including PAGCOR requirements, AML obligations, and age verification mandates.
• Legitimate interests: Processing necessary for phcku's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your explicit consent, including marketing communications and certain cookie uses. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

phcku does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, Maya, and banking partners, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention services: Third-party providers engaged to detect and prevent fraudulent activity on the Platform.
• Regulatory authorities: PAGCOR and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by court order or applicable law.
• IT and infrastructure providers: Cloud hosting and technology service providers engaged to operate and maintain the Platform, subject to strict data processing agreements.

All third parties with whom phcku shares personal data are required to handle such data in accordance with applicable data protection laws and phcku's data security standards.

8. International Data Transfers

phcku's primary operations and data storage are based in the Philippines. Where personal data is transferred to service providers located outside the Philippines, phcku ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses and assessments of the recipient country's data protection standards. By using the phcku Platform, you acknowledge that your data may be transferred and processed in countries outside the Philippines in accordance with this Policy.

9. Data Retention

phcku retains your personal data for as long as your account remains active and for such additional periods as are required by applicable law or regulatory obligation. Specifically:

• Account and identity data is retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AML requirements.
• Transaction and financial data is retained for a minimum of five (5) years from the date of the transaction.
• Communications data is retained for up to three (3) years from the date of the communication.
• Technical and usage data is retained for up to two (2) years from collection.

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

10. Cookies and Tracking Technologies

phcku uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the Platform. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security features. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, helping us identify areas for improvement.
• Marketing cookies: Used to deliver relevant promotional content within the Platform, where you have consented to receive marketing communications.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. phcku does not use cookies to track your activity across unrelated third-party websites.

11. Security of Your Personal Data

phcku implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption and hashing of passwords and sensitive financial data at rest;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits and vulnerability assessments;
• Incident response procedures for detecting and responding to data security breaches.

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

12. Your Rights

Subject to applicable Philippine data protection law, you have the following rights in relation to your personal data held by phcku:

• Right of access: You may request a copy of the personal data phcku holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data, subject to phcku's legal and regulatory retention obligations.
• Right to object: You may object to processing of your personal data based on legitimate interests, including direct marketing.
• Right to data portability: You may request a copy of your personal data in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact phcku via the 24/7 live chat support within the Platform or by email at [email protected]. phcku will respond to your request within the timeframes required by applicable law. We may need to verify your identity before processing your request.

13. Children and Minors

The phcku Platform is strictly intended for individuals aged 21 years and above. phcku does not knowingly collect personal data from persons under the age of 21. If phcku becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered an account on the phcku Platform, please contact us immediately via live chat or at [email protected].

14. Changes to This Privacy Policy

phcku reserves the right to update or amend this Privacy Policy at any time. The revised Policy will be published on the Platform with an updated "Last Updated" date. Where changes are material, phcku will endeavour to provide reasonable notice to registered users. Your continued use of the Platform following publication of an updated Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how phcku protects your personal data.

15. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or phcku's data practices, please contact our Data Protection team:

• Live chat: Available 24/7 within your phcku account dashboard
• Email: [email protected]

If you are not satisfied with phcku's response to your privacy concern, you may escalate the matter to the relevant Philippine data protection authority or to PAGCOR through its official regulatory channels.

This Privacy Policy was last reviewed and updated in May 2026. phcku reserves all rights not expressly granted herein.