Privacy Policy

1. About This Privacy Policy

This Privacy Policy ("Policy") describes the personal data practices of phbing ("phbing," "we," "us," "our") in connection with the phbing online gaming platform available at phbing.org. It explains the types of personal data we collect from users ("you," "your," "Data Subject"), the purposes for which we process that data, the parties with whom we may share it, and the rights you have in respect of your personal data.

phbing is committed to the responsible handling of personal data in accordance with the Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines. This commitment reflects our respect for the privacy of every Filipino player who entrusts phbing with their personal information.

2. Data Controller

phbing acts as the personal information controller ("PIC") in respect of the personal data collected through the phbing platform. As PIC, phbing determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Data Privacy Act and applicable NPC regulations.

phbing has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection law. Contact details for the DPO are set out in Section 13 of this Policy.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register for a phbing account or use our services, we collect the following categories of personal data that you provide to us:

• Identity data: Full legal name, date of birth, nationality, and gender.
• Contact data: Philippine mobile telephone number, email address, and residential address (including barangay, city or municipality, province, and postal code).
• Identification documents: Copies of government-issued Philippine identification documents submitted for Know Your Customer (KYC) verification purposes, such as a PhilSys national ID, passport, or driver's licence.
• Financial data: Payment account details (such as GCash mobile number, PayMaya account, or bank account details for BPI, BDO, or Metrobank) provided for the purpose of processing deposits and withdrawals. phbing does not store full payment credentials on its own servers; payment processing is handled by certified payment partners.
• Account credentials: Your chosen username and hashed password. phbing never stores passwords in plain text.

3.2 Data Collected Automatically

When you access or use the phbing platform, certain data is collected automatically by our systems, including:

• IP address and approximate geolocation derived therefrom.
• Device type, operating system, and browser type and version.
• Pages visited, features used, games played, session duration, and click-stream data.
• Date and time of access and login activity logs.
• Cookies and similar tracking technologies, as further described in Section 7.

3.3 Sensitive Personal Information

In limited circumstances, phbing may process sensitive personal information as defined under the Data Privacy Act — for example, government-issued ID numbers. Where we process such information, we do so only to the extent required by our KYC, AML, and responsible gaming obligations, and we apply heightened protection measures to such data.

4. How phbing Uses Your Personal Data

phbing processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your phbing player account, including authentication and security.
• Service delivery: To provide access to phbing's gaming platform, process transactions, and deliver promotional offers you have opted into.
• Identity verification (KYC): To verify your identity and age (21+) as required by PAGCOR regulations and anti-money laundering obligations.
• Payment processing: To process deposits and withdrawals through supported Philippine payment channels, including GCash and PayMaya.
• Responsible gaming: To monitor gaming activity, apply player-set limits, identify patterns that may indicate problem gambling, and administer self-exclusion requests.
• Fraud prevention and security: To detect, prevent, and investigate fraudulent transactions, account compromise, money laundering, and other prohibited conduct.
• Customer support: To respond to your enquiries, resolve complaints, and provide technical assistance.
• Legal compliance: To comply with phbing's obligations under Philippine law, PAGCOR licensing conditions, and NPC directives.
• Platform improvement: To analyse usage patterns in aggregated or pseudonymised form to improve the phbing platform experience for Filipino players.

5. Legal Bases for Processing

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

• Contractual necessity: Processing is necessary to perform the contract between you and phbing — namely, providing you with access to the phbing gaming platform.
• Legal obligation: Processing is necessary to comply with legal and regulatory obligations applicable to phbing, including PAGCOR licensing requirements and AML regulations.
• Legitimate interests: Processing is necessary for the legitimate interests of phbing, including fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights and interests.
• Consent: Where phbing sends you marketing communications, we do so only with your prior consent. You may withdraw consent at any time by updating your communication preferences in your phbing account settings.

6. Data Sharing and Disclosure

phbing does not sell or rent your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment service providers: Certified Philippine payment processors (such as GCash, PayMaya, and accredited banking partners) for the purpose of processing your transactions.
• Identity verification providers: Third-party KYC and AML compliance service providers engaged to assist with identity verification and fraud screening.
• Game content providers: Licensed game developers and distributors whose titles are offered on the phbing platform, to the extent necessary for game operation and RNG certification.
• Regulatory authorities: PAGCOR, the National Privacy Commission, and other competent Philippine authorities where disclosure is required by law, court order, or regulatory direction.
• IT and infrastructure providers: Cloud hosting, security, and technical service providers engaged by phbing who process data on phbing's behalf under data processing agreements that bind them to equivalent data protection standards.

All third parties with whom phbing shares personal data are contractually required to maintain the confidentiality and security of such data and to process it only for the purposes for which it was shared.

7. Cookies and Tracking Technologies

phbing uses cookies and similar technologies (such as pixel tags and local storage) on its platform for the following purposes:

• Essential cookies: Required for the phbing platform to function, including session authentication and security. These cannot be disabled without affecting platform functionality.
• Analytical cookies: Used in aggregated or pseudonymised form to understand how players use the phbing platform and to identify areas for improvement. These do not identify you personally.
• Preference cookies: Store your platform preferences, such as language and display settings, to improve your phbing experience across sessions.

You may manage cookie preferences through your browser settings. Note that disabling essential cookies will impact your ability to use the phbing platform. phbing does not use cookies to serve third-party advertising.

8. Data Retention

phbing retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements. In practice:

• Account and transaction data is retained for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML regulations.
• KYC documentation is retained for the same five-year minimum period following account closure.
• Login and security logs are retained for a period of twelve (12) months.
• Marketing consent records are retained for as long as you remain a phbing player, or until consent is withdrawn, whichever is earlier.

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

9. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phbing:

To exercise any of these rights, please contact phbing's Data Protection Officer using the details in Section 13. phbing will respond to all valid data subject requests within fifteen (15) working days of receipt, in accordance with NPC guidelines.

10. Children's Privacy

phbing's platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations and Philippine law. phbing does not knowingly collect personal data from persons under the age of 21. If phbing becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete that data and close the associated account. If you believe a minor has accessed phbing, please contact our support team immediately.

11. Security Measures

phbing implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction, including:

• TLS 1.2 / 1.3 encryption for all data in transit between your device and phbing's servers.
• AES-256 encryption for sensitive data at rest.
• Bcrypt hashing for all stored passwords — phbing employees cannot view your password.
• Role-based access controls ensuring only authorised phbing personnel can access personal data, limited to what is necessary for their role.
• Regular third-party security audits and penetration testing of the phbing platform.
• Automated monitoring for anomalous access patterns and potential security incidents.

Notwithstanding these measures, no online platform can guarantee absolute security. phbing encourages all players to use strong, unique passwords for their phbing account and to enable two-factor authentication as an additional security layer.

12. Changes to This Privacy Policy

phbing may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or business operations. Where changes are material, phbing will notify registered players by email or via a prominent notice on the phbing platform at least fourteen (14) days before the changes take effect. The "Last Updated" date at the top of this Policy indicates when the current version was adopted. Your continued use of phbing after the effective date of any revised Policy constitutes your acceptance of the updated terms.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or phbing's data practices, or if you wish to exercise your data subject rights, please contact the phbing Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe phbing has not adequately addressed your privacy concerns.