phrich Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how phrich ("phrich," "we," "us," or "our"), the operator of the online gaming platform at phrich.vip, collects, processes, stores, and protects the personal data of individuals who visit, register on, or interact with the phrich platform. This Policy applies to all phrich users, whether accessing the platform from Manila, Cebu, Davao, Quezon City, or anywhere else in the Philippines.

phrich is committed to complying with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and the implementing rules and regulations issued by the National Privacy Commission (NPC) of the Philippines. By using the phrich platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein.

2. Data Controller Information

phrich is the data controller responsible for the personal data collected through the phrich platform. For all data privacy matters, phrich has designated a Data Protection Officer (DPO) who can be contacted via the details provided in Section 14 of this Policy. phrich processes personal data strictly within the bounds of PAGCOR regulatory requirements and the Data Privacy Act of 2012.

3. Personal Data We Collect

In the course of operating the phrich platform and providing gaming services to Filipino players, phrich collects the following categories of personal data:

Identity and Contact Data:

• Full legal name as it appears on your government-issued ID;
• Date of birth (for mandatory age verification — phrich is strictly 21+);
• Philippine residential address;
• Email address;
• Philippine mobile phone number.

Identity Verification Data:

• Copies of government-issued identification documents (passport, SSS card, UMID, driver's license, or equivalent);
• Selfie or liveness verification images submitted during the phrich KYC (Know Your Customer) process.

Financial and Transaction Data:

• GCash account details, PayMaya account details, and bank account information (BPI, BDO, Metrobank) used for deposits and withdrawals;
• Full transaction history including deposit amounts, withdrawal requests, dates, reference numbers, and payment method used;
• Account balance history.

Gaming Activity Data:

• Game history, wagering records, wins, losses, and session durations across all phrich games;
• Sports betting selections and results;
• Bonus and promotion usage records.

Technical and Usage Data:

• IP address and approximate geographic location at the time of login;
• Device type, operating system, and browser information;
• Session timestamps, page views, and click-path data within the phrich platform;
• Cookie identifiers and similar tracking data (see Section 8).

Communications Data:

• Records of your communications with phrich's customer support team via live chat or email;
• Feedback, survey responses, and complaint records.

4. How We Collect Your Data

phrich collects personal data through the following means:

• Direct submission: Data you provide when registering a phrich account, completing KYC verification, making deposits or withdrawals, or contacting phrich support;
• Automated collection: Technical and usage data collected automatically through cookies, server logs, and analytics tools when you access the phrich platform;
• Third-party sources: Identity verification and fraud prevention data from licensed third-party KYC service providers; payment verification data from GCash, PayMaya, and banking partners.

5. Purposes and Legal Basis for Processing

phrich processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

• Account registration and management — necessary for the performance of the contract between you and phrich;
• Age and identity verification — legal obligation under PAGCOR regulations (21+ requirement) and the Anti-Money Laundering Act;
• Processing deposits and withdrawals — necessary for contract performance and compliance with financial regulations;
• Fraud prevention and security monitoring — legitimate interest in protecting the platform and its users;
• Responsible gaming compliance — legal obligation; detection of at-risk gambling behaviour and enforcement of self-exclusion;
• Customer support — contract performance and legitimate interest in resolving player inquiries;
• Marketing communications — with your explicit consent; you may withdraw consent at any time;
• Platform improvement and analytics — legitimate interest, using aggregated and anonymised data where possible.

6. Sharing of Personal Data

phrich does not sell your personal data to third parties. phrich may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment service providers: GCash, PayMaya, and banking partners for the processing of deposits and withdrawals;
• KYC and identity verification providers: licensed third-party services for age and identity verification;
• Game software providers: to the minimum extent required for game delivery and fair-play auditing;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, where required by Philippine law;
• IT infrastructure providers: cloud hosting and security service providers engaged by phrich, subject to data processing agreements.

All third parties with whom phrich shares personal data are required to process that data in accordance with applicable Philippine privacy law and under written data processing agreements.

7. Data Retention

phrich retains personal data for as long as necessary to fulfil the purposes outlined in this Policy, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

• Account and identity verification records: minimum 5 years from account closure;
• Financial transaction records: minimum 5 years from the date of transaction, in compliance with the Anti-Money Laundering Act;
• Gaming activity records: minimum 3 years from the date of activity;
• Customer support communications: 2 years from the date of the interaction.

Upon expiry of the applicable retention period, phrich will securely delete or anonymise your personal data in accordance with NPC-approved data disposal procedures.

8. Cookies and Tracking Technologies

phrich uses cookies and similar tracking technologies to operate and improve the platform. Cookies used on phrich.vip fall into the following categories:

• Strictly necessary cookies: Required for login session management and platform security. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and preferred payment method.
• Analytics cookies: Collect anonymised data about how players navigate the phrich platform, used to improve the user experience.

You may manage non-essential cookies through your browser settings. Disabling cookies may affect the functionality of certain phrich platform features.

9. Security of Your Personal Data

phrich implements industry-standard 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 in transit, encrypted storage of sensitive account data, multi-factor authentication (OTP) for phrich login, regular security audits, and strict access controls limiting data access to authorised phrich personnel on a need-to-know basis.

While phrich takes all reasonable steps to protect your data, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights, phrich will notify affected users and the National Privacy Commission in accordance with the Data Privacy Act of 2012.

10. Your Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phrich:

• Right to be informed: You have the right to know what personal data phrich holds about you and how it is being used;
• Right of access: You may request a copy of the personal data phrich holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data in your phrich account;
• Right to erasure: You may request deletion of your personal data in certain circumstances, subject to phrich's legal retention obligations;
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability: You may request your personal data in a commonly used, machine-readable format;
• Right to lodge a complaint: You have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact phrich's Data Protection Officer using the contact details in Section 14. phrich will respond to all valid data subject requests within 15 business days.

11. Children and Minors

The phrich platform is strictly for individuals aged 21 years and above, in full compliance with Philippine gambling regulations and PAGCOR requirements. phrich does not knowingly collect personal data from individuals under 21 years of age. If phrich discovers that an account has been registered by a person under 21, the account will be immediately suspended and all personal data associated with it will be deleted in accordance with our data retention procedures. If you believe a minor has registered a phrich account, please notify us immediately at the contact details in Section 14.

12. Cross-Border Data Transfers

Some of the third-party service providers engaged by phrich — particularly cloud infrastructure and KYC providers — may process personal data outside of the Philippines. Where such transfers occur, phrich ensures that adequate safeguards are in place, including contractual data protection clauses that meet the standards required by the Data Privacy Act of 2012 and the National Privacy Commission's guidelines on cross-border data transfers.

13. Changes to This Privacy Policy

phrich may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or PAGCOR regulatory requirements. Material changes will be communicated to registered phrich users via email or a prominent notice on the platform prior to taking effect. The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of the phrich platform following any update constitutes your acceptance of the revised Policy.

14. Contact and Data Privacy Inquiries

For all privacy-related inquiries, data subject access requests, or to contact phrich's Data Protection Officer, please write to: [email protected] (plain text — not a clickable link) with the subject line "Privacy Inquiry."

phrich's customer support team is available 24/7 via live chat on the phrich platform for general account and platform questions. The Data Protection Officer will respond to formal privacy requests within 15 business days of receipt.