phdrem Privacy Policy

1. Overview

phdrem ("phdrem," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the phdrem online casino platform. This Privacy Policy ("Policy") describes how phdrem collects, uses, stores, discloses, and protects personal information in connection with your use of the phdrem website at phdrem.net and all related services (collectively, the "Platform").

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. By registering an account or using the phdrem Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, phdrem acts as the Personal Information Controller (PIC) in respect of the personal data collected through the Platform. As PIC, phdrem determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

Where phdrem engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification providers, or analytics platforms), those providers act as Personal Information Processors (PIPs) and are contractually bound to process your data only on phdrem's instructions and in accordance with this Policy and applicable law.

For all data protection inquiries, please contact phdrem's designated Data Protection Officer (DPO) at: [email protected]

3. Personal Data We Collect

phdrem collects the following categories of personal data from players and Platform users:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Gender
• Nationality and country of residence
• Username and account password (stored in encrypted form)

3.2 Contact Data

• Email address
• Philippine mobile number
• Residential address (barangay, city/municipality, province)

3.3 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., PhilSys ID, passport, driver's license, UMID, SSS/GSIS ID)
• Proof of address documents (e.g., utility bill, bank statement)
• Selfie or liveness verification image where required
• Source-of-funds documentation for large transactions

3.4 Financial & Transaction Data

• GCash or PayMaya/Maya account reference numbers
• Bank account details (bank name, account number) for bank transfer transactions
• Debit card details (card number masked, expiry date)
• Deposit and withdrawal history, amounts, and timestamps
• Account balance and transaction records

3.5 Gaming Activity Data

• Games played, wagers placed, and outcomes
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.6 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Cookies and similar tracking technologies (see Section 9)
• Login timestamps and session logs

3.7 Communications Data

• Records of your communications with phdrem customer support
• Feedback, complaints, and dispute records
• Marketing preferences and communication opt-in/opt-out records

4. How We Collect Your Data

phdrem collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion.
• Automatically — through cookies, web beacons, and server logs when you access and interact with the Platform.
• From third parties — from KYC and identity verification service providers, payment processors (GCash, PayMaya, banks), fraud prevention services, and, where applicable, PAGCOR or other regulatory bodies.

5. Purpose and Legal Basis for Processing

phdrem 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 — to create and maintain your phdrem account, verify your identity, and provide access to Platform services. Legal basis: Performance of contract.
• Age verification — to confirm that you meet the 21-year minimum age requirement for casino-style gambling under Philippine law. Legal basis: Legal obligation; legitimate interest.
• KYC and anti-money laundering compliance — to comply with the Anti-Money Laundering Act (AMLA) and PAGCOR regulatory requirements. Legal basis: Legal obligation.
• Payment processing — to process deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card. Legal basis: Performance of contract.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, cheating, and unauthorized access. Legal basis: Legitimate interest; legal obligation.
• Responsible gaming — to monitor gaming activity, enforce deposit limits and self-exclusion, and identify players who may be at risk of problem gambling. Legal basis: Legal obligation; legitimate interest.
• Customer support — to respond to your inquiries, complaints, and dispute resolution requests. Legal basis: Performance of contract; legitimate interest.
• Marketing and promotions — to send you information about phdrem promotions, bonuses, and new games, where you have opted in to receive such communications. Legal basis: Consent.
• Platform improvement and analytics — to analyze usage patterns and improve the Platform's features, performance, and user experience. Legal basis: Legitimate interest.
• Legal and regulatory compliance — to comply with applicable Philippine laws, court orders, and regulatory requirements. Legal basis: Legal obligation.

6. Sharing Your Personal Data

phdrem does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phdrem may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors — GCash, PayMaya/Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and debit card processors, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers — third-party providers engaged to verify your identity documents and perform liveness checks as required by PAGCOR and AMLA regulations.
• Fraud prevention and security services — providers that assist phdrem in detecting and preventing fraudulent activity on the Platform.
• IT and hosting providers — cloud infrastructure and data hosting providers that store Platform data on phdrem's behalf.
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or court order.
• Professional advisors — lawyers, auditors, and accountants engaged by phdrem in connection with legal, compliance, or financial matters, subject to professional confidentiality obligations.

All third-party processors engaged by phdrem are required to enter into data processing agreements that obligate them to process your personal data only on phdrem's instructions, to implement appropriate security measures, and to comply with the Data Privacy Act of 2012.

7. Data Retention

phdrem retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC data — retained for a minimum of five (5) years from the date of account closure, as required by AMLA regulations.
• Transaction records — retained for a minimum of five (5) years from the date of each transaction, in accordance with AMLA and PAGCOR requirements.
• Gaming activity logs — retained for a minimum of three (3) years from the date of each gaming session.
• Customer support records — retained for three (3) years from the date of resolution of the relevant inquiry or dispute.
• Marketing consent records — retained until you withdraw your consent or for three (3) years after your last interaction with phdrem marketing communications, whichever is earlier.

Upon expiry of the applicable retention period, phdrem will securely delete or anonymize your personal data in accordance with its data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for statistical and analytical purposes, as it can no longer be used to identify you.

8. Data Security

phdrem implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption — all data transmitted between your device and the phdrem Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Passwords are stored using strong one-way hashing algorithms and are never stored in plain text.
• Access controls — access to personal data within phdrem's systems is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-factor authentication — phdrem offers two-factor authentication (2FA) for player accounts and requires it for internal administrative access to systems containing personal data.
• Regular security assessments — phdrem conducts periodic vulnerability assessments and security audits of its Platform and data processing systems.
• Incident response — phdrem maintains a data breach response procedure. In the event of a personal data breach that poses a real risk to your rights and freedoms, phdrem will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, as required by the Data Privacy Act of 2012.

While phdrem takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phdrem account credentials and for notifying phdrem immediately if you suspect unauthorized access to your account.

9. Cookies & Tracking Technologies

phdrem uses cookies and similar tracking technologies to operate and improve the Platform, personalize your experience, and analyze usage patterns. A cookie is a small text file placed on your device when you visit the Platform.

9.1 Types of Cookies Used

• Strictly necessary cookies — essential for the Platform to function. These include session cookies that keep you logged in during your visit. These cookies cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies — used to collect anonymized information about how players use the Platform, such as which pages are visited most frequently and whether error messages are received. This data helps phdrem improve the Platform.
• Functionality cookies — used to remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations.
• Security cookies — used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies may prevent you from accessing certain features of the phdrem Platform, including logging in to your account. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

10. Your Rights Under the Data Privacy Act of 2012

As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by phdrem:

To exercise any of the above rights, please contact phdrem's Data Protection Officer at [email protected]. phdrem will respond to all verified data subject requests within thirty (30) days of receipt, as required by the Data Privacy Act of 2012. phdrem may request proof of identity before processing your request to prevent unauthorized disclosure of personal data.

11. Minors and Age Restriction

The phdrem Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR regulations governing casino-style gambling. phdrem does not knowingly collect personal data from individuals under the age of 21.

If phdrem becomes aware that personal data has been collected from a person under 21 years of age, phdrem will immediately suspend the relevant account, delete the associated personal data, and report the matter to the appropriate regulatory authorities where required. If you believe that a minor has registered on the phdrem Platform, please notify us immediately at [email protected].

12. Cross-Border Data Transfers

phdrem primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines — for example, cloud hosting providers or international KYC verification services — phdrem ensures that such transfers are conducted in compliance with Section 21 of the Data Privacy Act of 2012 and the NPC's guidelines on cross-border data transfers.

Specifically, phdrem will only transfer personal data outside the Philippines where: (a) the recipient country provides an adequate level of data protection; (b) appropriate contractual safeguards are in place, such as standard contractual clauses approved by the NPC; or (c) you have given your explicit consent to the transfer.

13. Third-Party Services and Links

The phdrem Platform may reference or integrate with third-party services such as payment gateways (GCash, PayMaya, Philippine banks) and game content providers. These third parties operate under their own privacy policies, which phdrem does not control. phdrem encourages you to review the privacy policies of any third-party services you interact with in connection with your use of the Platform.

phdrem is not responsible for the privacy practices or content of third-party services. The inclusion of any third-party service reference on the Platform does not constitute an endorsement of that service's privacy practices.

14. Changes to This Privacy Policy

phdrem reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or phdrem's data processing practices. When material changes are made, phdrem will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the phdrem Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the amended Policy, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or phdrem's handling of your personal data, please contact our Data Protection Officer (DPO):

Data Protection Officer — phdrem

Email: [email protected]

Please include your registered username, a clear description of your request or concern, and any relevant details. phdrem's DPO will acknowledge receipt of your inquiry within five (5) business days and will provide a substantive response within thirty (30) days, as required by the Data Privacy Act of 2012.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.