phbu Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how phbu ("phbu", "we", "us", "our") collects, uses, discloses, stores, and protects the personal data of individuals ("you", "your", "Player") who access and use the phbu online gaming platform at phbu.net and all associated services (collectively, the "Platform").

phbu is a PAGCOR-regulated operator serving Filipino players across the Philippines. As a regulated gaming platform, phbu is subject to the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC). This Policy is designed to meet and exceed the requirements of that regulatory framework.

By registering an account on phbu, making a deposit, or otherwise using the 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. If you do not agree to this Policy, you must not use the phbu Platform.

This Policy should be read together with phbu's Terms & Conditions and Responsible Gaming Policy, both of which are available on this website.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, phbu acts as the personal information controller in respect of all personal data collected through the Platform. phbu 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.

phbu has appointed a Data Protection Officer (DPO) who is responsible for day-to-day oversight of data protection compliance. Contact details for the DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

phbu collects the following categories of personal data from players and Platform visitors:

3.1 Registration & Identity Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (used to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Residential address (street, city, province, postal code)
• Mobile phone number
• Email address
• Username and encrypted password

3.2 Verification & KYC Documents

• Copies of government-issued photo identification (Philippine passport, SSS ID, UMID, driver's licence, PhilSys national ID)
• Proof of address documentation (utility bills, bank statements, barangay certificates)
• Payment method ownership evidence (e.g., GCash or Maya account screenshots)
• Source of funds declarations where required by PAGCOR or AML regulations

3.3 Financial & Transaction Data

• Deposit amounts, dates, and payment methods used (GCash, Maya, BPI, BDO, UnionBank, 7-Eleven Cliqq, Coins.ph, USDT TRC20)
• Withdrawal requests, amounts, and destination payment details
• Bonus and promotional credit history
• Account balance history

3.4 Gaming Activity Data

• Game types played and session history (Sic Bo, slots, live dealer, bingo, Hi-Lo, snooker, sports betting)
• Bet amounts, game outcomes, and win/loss records
• Session start and end times, session duration
• Responsible gaming tool usage (deposit limits set, cooling-off periods activated, self-exclusion requests)

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type and version
• Unique device identifiers
• Log data including pages visited, time spent on pages, and clickstream data
• Cookie identifiers and similar tracking technology data (see Section 8)

3.6 Communications Data

• Records of correspondence with phbu customer support (live chat transcripts, email content, support ticket history)
• Records of complaints and dispute resolution proceedings
• Marketing communication preferences and opt-in / opt-out records

4. How We Collect Your Data

phbu collects personal data through the following channels and mechanisms:

• Directly from you: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or updating your account profile.
• Automatically through the Platform: Technical and device data collected via cookies, web beacons, server logs, and similar tracking technologies when you browse or use the phbu website.
• From payment providers: Transaction confirmation data shared by GCash, Maya, BPI, BDO, UnionBank, 7-Eleven Cliqq, Coins.ph, and other payment processors in connection with your deposits and withdrawals.
• From identity verification services: Data returned by third-party KYC and identity verification providers engaged by phbu to assist with document authentication and fraud prevention.
• From regulatory and law enforcement sources: Information provided by PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine government bodies in connection with phbu's regulatory obligations.
• From fraud prevention and security partners: Risk signals, device fingerprinting data, and behavioural analytics provided by phbu's fraud detection service providers.

5. Legal Basis for Processing

phbu relies on the following legal bases under the Data Privacy Act of 2012 to process your personal data:

Processing Purpose	Legal Basis
Account registration and management	Contractual necessity — performance of the phbu Player Agreement
KYC identity verification	Legal obligation — PAGCOR licensing requirements and AML regulations
Processing deposits and withdrawals	Contractual necessity
Anti-money laundering monitoring	Legal obligation — Republic Act No. 9160 (AMLA), as amended
Responsible gaming monitoring and intervention	Legal obligation — PAGCOR responsible gaming framework
Fraud prevention and platform security	Legitimate interest — protecting the integrity of the Platform and all players
Marketing communications (where opted in)	Consent — you may withdraw consent at any time
Analytics and Platform improvement	Legitimate interest — improving service quality and user experience
Dispute resolution and legal claims	Legitimate interest and legal obligation

6. How We Use Your Personal Data

phbu uses the personal data collected from you for the following specific purposes:

6.1 Platform Operations

To create and manage your phbu account, process your deposits and withdrawals via GCash, Maya, and Philippine banking channels, provide access to all gaming products on the Platform, deliver customer support, and communicate important account-related information including security alerts and policy updates.

6.2 Regulatory Compliance

To verify your identity and age (21+ requirement) in accordance with PAGCOR licensing conditions, conduct ongoing anti-money laundering transaction monitoring as required by the AMLA, file suspicious transaction reports (STRs) and covered transaction reports (CTRs) with the AMLC where legally required, and respond to lawful requests from regulatory and law enforcement authorities.

6.3 Responsible Gaming

To monitor your gaming activity for indicators of problem gambling, give effect to responsible gaming tools you activate (deposit limits, cooling-off periods, self-exclusion), and proactively reach out where phbu identifies patterns consistent with gambling harm — consistent with phbu's obligations under PAGCOR's responsible gaming framework.

6.4 Security and Fraud Prevention

To detect and prevent fraudulent account registrations, bonus abuse, payment fraud, money laundering, and other prohibited conduct; to investigate suspected breaches of phbu's Terms & Conditions; and to protect the integrity of the Platform and the safety of all players.

6.5 Marketing (With Your Consent)

Where you have opted in to marketing communications, to send you information about phbu promotions, new games, sportsbook offers, and platform updates via email or SMS. You may withdraw your marketing consent at any time by contacting support at [email protected] or by using the unsubscribe mechanism in any marketing message.

6.6 Analytics and Platform Improvement

To analyse aggregated and anonymised usage data to understand how players use the Platform, identify areas for improvement, optimise game offerings, and enhance the overall player experience. Where analytics involve personal data, phbu applies appropriate pseudonymisation and minimisation measures.

7. Sharing Your Personal Data

phbu does not sell or rent your personal data to third parties. We share your personal data only in the following circumstances and with the following categories of recipients:

7.1 Service Providers and Data Processors

phbu engages third-party service providers to assist with Platform operations, including payment processing (GCash, Maya, Philippine banks), KYC and identity verification, fraud detection, cloud hosting and infrastructure, customer support technology, and email and SMS delivery. All such providers process your data only on phbu's instructions and under contractual obligations consistent with the Data Privacy Act.

7.2 Regulatory and Government Authorities

phbu is required by law to share certain personal data with PAGCOR in connection with its regulatory oversight role, the Anti-Money Laundering Council (AMLC) in connection with AML transaction reporting obligations, and other Philippine government agencies and law enforcement bodies upon receipt of a valid and lawful request or order.

7.3 Game and Software Providers

phbu's Platform incorporates games and software from third-party providers, including JILI and live dealer studio partners. These providers may receive limited technical data necessary to operate their games within the phbu environment. Game providers do not receive your full profile or financial data beyond what is technically required to deliver the gaming experience.

7.4 Professional Advisers

phbu may share personal data with its legal advisers, auditors, and accountants where disclosure is necessary for them to provide professional services to phbu, subject to applicable professional confidentiality obligations.

7.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of phbu's business, your personal data may be transferred to the acquiring or successor entity as part of that transaction. phbu will notify you via email or a prominent Platform notice in advance of any such transfer affecting your personal data, and the receiving entity will be required to honour the commitments made in this Policy.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit the phbu website. phbu uses cookies and similar technologies (web beacons, pixel tags, local storage) to operate and improve the Platform, remember your preferences, maintain your login session, and analyse usage patterns.

8.2 Types of Cookies Used

• Strictly necessary cookies: Essential to the operation of the Platform, including maintaining your login session and enabling core Platform functionality. These cannot be disabled without impairing Platform use.
• Functional cookies: Remember your preferences such as language settings, preferred game view, and responsible gaming tool configurations.
• Analytics cookies: Collect aggregated and anonymised data about how players navigate the Platform, which pages are visited most frequently, and where players encounter difficulties. Used to improve Platform design and performance.
• Security cookies: Assist in detecting and preventing fraud, unauthorised account access, and bot activity on the Platform.

8.3 Managing Cookies

You may manage cookie preferences through your browser settings. Most modern browsers allow you to refuse or delete non-essential cookies. Please note that disabling certain cookies may affect the functionality of the phbu Platform. phbu does not use third-party advertising or behavioural tracking cookies.

9. Data Security

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

• AES-256 encryption of personal data at rest across all phbu data storage systems.
• TLS 1.3 encryption of all data transmitted between your device and the phbu Platform.
• Salted hashing of account passwords — phbu cannot retrieve or view your raw password.
• Multi-factor authentication options available for player accounts.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• 24/7 intrusion detection and security monitoring of phbu's infrastructure.
• Formal data breach response procedures, including NPC notification within 72 hours of becoming aware of a breach that poses a real risk to data subjects.

While phbu takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are also responsible for protecting your own account credentials and for notifying phbu immediately if you suspect unauthorised access to your account.

10. Data Retention

phbu retains personal data for the periods set out below, after which data is securely deleted or anonymised:

Data Category	Retention Period
Account registration and identity data	Duration of account plus 5 years after account closure
KYC verification documents	Duration of account plus 5 years (AMLA requirement)
Financial and transaction records	5 years from the date of each transaction (AMLA requirement)
Gaming activity logs	Duration of account plus 3 years after account closure
Customer support communications	3 years from the date of the last interaction
Marketing consent records	Until consent is withdrawn, plus 3 years thereafter
Technical / server log data	12 months on a rolling basis

Where phbu is required by law or regulatory obligation to retain data for a longer period than stated above, the longer period will apply. Where a legal dispute is ongoing at the time a retention period expires, data will be retained until the dispute is fully resolved.

11. Your Data Protection Rights

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

• Right to be Informed: The right to know what personal data phbu holds about you, the purposes for which it is processed, and the recipients to whom it has been disclosed — as set out in this Policy.
• Right of Access: The right to request a copy of the personal data phbu holds about you. phbu will respond to access requests within 30 calendar days.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly within your phbu account settings; for other corrections, contact support.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phbu's overriding legal and regulatory retention obligations.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that phbu transmit it directly to another controller where technically feasible.
• Right to Object: The right to object to processing of your personal data based on legitimate interest, including profiling. phbu will cease such processing unless it has compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where phbu relies on your consent to process personal data (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phbu has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact phbu's Data Protection Officer at the details provided in Section 15. phbu may need to verify your identity before processing a data subject request.

12. Children's and Minors' Privacy

The phbu Platform is strictly intended for adults aged 21 years and above. phbu does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted during the account registration process, and phbu reserves the right to request documentary proof of age at any time.

If phbu becomes aware that personal data has been collected from an individual under 21 years of age, that account will be immediately closed, all data associated with the account will be deleted, and any funds deposited will be returned to the originating payment source after completion of any required regulatory review.

If you are a parent or guardian and believe your child has registered a phbu account, please contact us immediately at [email protected] so that we can take prompt action.

13. International Data Transfers

phbu's primary data processing infrastructure is located within the Philippines. Where phbu engages service providers located outside the Philippines — for example, cloud infrastructure providers or fraud detection specialists operating internationally — any transfer of personal data outside the Philippines is conducted in accordance with the requirements of the Data Privacy Act and NPC regulations.

Such transfers are made only where: (a) the receiving country provides an adequate level of protection for personal data as recognised by the NPC; or (b) phbu has implemented appropriate contractual safeguards, such as standard contractual clauses approved by the NPC, that bind the recipient to data protection standards equivalent to those applicable in the Philippines.

14. Updates to This Privacy Policy

phbu reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or regulatory obligations. The "Last updated" date at the top of this page reflects the date of the most recent revision.

Where a material change is made to this Policy — particularly one that affects your rights or the purposes for which your data is used — phbu will notify you by email to the address registered on your account and will post a prominent notice on the Platform at least 14 days before the change takes effect. Your continued use of the phbu Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

We encourage you to review this page periodically to stay informed about how phbu is protecting your personal data.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or phbu's handling of your personal data, please contact phbu's Data Protection Officer using the details below. All data subject requests and privacy-related complaints will be acknowledged within 5 business days and resolved within 30 calendar days where possible.

Data Protection Officer, phbu
Email: [email protected]

For general support enquiries, our customer support team is available 24 hours a day, 7 days a week at the same email address.

If you are not satisfied with phbu's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.