philpower Privacy Policy

1. Data Controller

philpower, the operator of the Platform accessible at philpower.app, is the Data Controller of your personal information as defined under the Philippine Data Privacy Act of 2012. philpower determines the purposes and means of processing personal data collected through the Platform. A dedicated Data Protection Officer ("DPO") has been appointed and is reachable via the contact details provided in Section 14 of this Policy.

2. Personal Data We Collect

2.1 Registration and Identity Data

When you create a philpower account, we collect: full legal name; date of birth; Philippine mobile number; email address; and the username or account identifier you select. This information forms the core of your Player profile and is used for account management, communication, and identity verification.

2.2 KYC and Verification Data

Before your first withdrawal, philpower is required by PAGCOR regulations and Philippine Anti-Money Laundering Act ("AMLA") obligations to verify your identity. KYC data collected includes: government-issued photo identification (UMID, Philippine Passport, LTO Driver's License, PhilSys National ID, or SSS/GSIS ID); selfie photograph or liveness verification image; and, where applicable, proof of address (utility bill, bank statement, or barangay certification). KYC documents are processed through philpower's secure verification infrastructure and, where third-party verification services are used, under data processing agreements that comply with Philippine DPA requirements.

2.3 Financial Transaction Data

philpower records all financial transactions on your Account, including: deposit amounts, timestamps, and payment method references (GCash transaction IDs, InstaPay reference numbers, or bank transfer references); withdrawal requests, amounts, destination e-wallet references, and processing timestamps; and bonus credits and their associated wagering history. Note that philpower does not store full GCash PIN codes, bank account passwords, or complete card numbers. Payment processing is handled by certified payment gateways, and philpower receives only the reference and status data necessary to credit or debit your account.

2.4 Gaming and Behavioural Data

philpower collects comprehensive gaming activity data, including: game sessions played (game title, provider, duration); bet amounts, outcomes, and RNG seeds (for audit purposes); login timestamps, session durations, and device identifiers used for each session; and betting patterns, which may be used for responsible gaming monitoring as required by PAGCOR.

2.5 Technical and Device Data

When you access the Platform, we automatically collect: IP address and approximate geolocation derived from IP; device type, operating system version, and browser type; cookies and session identifiers (see Section 9); and referral source data where applicable for affiliate tracking purposes.

2.6 Communications Data

Records of your communications with philpower's support team via live chat, email, or any ticketing system are retained for service quality assurance, dispute resolution, and compliance purposes.

3. How We Collect Your Data

philpower collects personal data through the following channels:

• Directly from you — at registration, during KYC submission, when you contact support, or when you update your account settings;
• Automatically — through Platform usage logs, cookies, and session tracking technology as you navigate and play on the Platform;
• From payment processors — transaction confirmation data from GCash, Maya/PayMaya, BPI, BDO, Metrobank, and other payment partners in the course of processing deposits and withdrawals;
• From third-party KYC providers — identity verification data returned by certified document and liveness check services engaged by philpower;
• From PAGCOR and regulatory bodies — compliance-related data exchanges as required under philpower's gaming licence.

4. Purposes of Processing

philpower processes your personal data for the following purposes:

• Account creation and management — establishing, maintaining, and administering your Player Account on the Platform;
• Identity verification (KYC) — fulfilling PAGCOR licensing requirements and AMLA obligations by verifying the identity and age eligibility of all Players;
• Payment processing — executing deposits, withdrawals, and bonus credits to and from your Account via the payment methods you select;
• Game delivery and fairness — enabling access to game content, recording game outcomes for audit trails, and maintaining RNG certification records;
• Responsible gaming compliance — monitoring gaming patterns to detect potential problem gambling behaviours and administering self-exclusion requests as required by PAGCOR;
• Fraud and AML prevention — detecting, investigating, and preventing fraudulent activity, money laundering, and other prohibited conduct on the Platform;
• Customer support — responding to your queries, resolving disputes, and administering your account settings;
• Platform security — detecting and responding to unauthorized access attempts, technical vulnerabilities, and security incidents;
• Legal and regulatory compliance — fulfilling mandatory reporting obligations to PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission ("NPC"), and other competent Philippine authorities;
• Marketing communications — where you have provided consent, sending promotional offers, game announcements, and platform updates via SMS, email, or push notification. You may withdraw marketing consent at any time via account settings or by contacting support.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, philpower relies on the following legal bases for processing your personal data:

• Contractual necessity — processing required to perform the Player Account agreement, including account management, payment processing, and game delivery;
• Legal obligation — processing required to comply with PAGCOR's licensing conditions, AMLA reporting requirements, and NPC regulations;
• Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights;
• Consent — processing for direct marketing communications, where consent is obtained and may be withdrawn at any time without affecting other processing activities.

6. Data Sharing & Disclosure

philpower does not sell, rent, or trade your personal information. We may share your data with the following categories of recipients under strict data protection obligations:

• Payment processors — GCash (Mynt / Globe Fintech), PayMaya Philippines, InstaPay/PesoNet member banks, and other payment partners, solely for transaction processing;
• KYC verification providers — third-party identity verification services engaged to perform document and liveness checks under data processing agreements;
• Game providers — JILI Gaming, PG Soft, Evolution Gaming, Pragmatic Play, and other certified game studios, who may receive session and bet data as required for game delivery and RTP audit purposes;
• Regulatory and law enforcement bodies — PAGCOR, AMLC, the National Privacy Commission, and Philippine law enforcement authorities, where disclosure is required by law, court order, or regulatory direction;
• Technology and cloud service providers — infrastructure, hosting, and security service providers engaged by philpower, all operating under data processing agreements that require compliance with Philippine DPA standards;
• Professional advisers — legal counsel, auditors, and compliance consultants, under obligations of confidentiality.

7. International Data Transfers

Some of philpower's technology and game delivery partners operate servers located outside the Philippines — including in Singapore, Hong Kong, and Malta, where international gaming technology providers are commonly headquartered. Where personal data is transferred to entities outside the Philippines, philpower takes appropriate safeguards to ensure that the transfer complies with the Philippine Data Privacy Act, including: executing data transfer agreements with appropriate contractual protections; transferring data only to jurisdictions or entities with equivalent data protection standards; and maintaining records of international data transfers as required by the National Privacy Commission.

8. Data Retention

philpower retains your personal data for as long as your Account is active and for the periods required by applicable law and regulatory obligations thereafter. Specific retention periods include:

• KYC documents and identity records — minimum five (5) years from account closure, as required by AMLA regulations;
• Financial transaction records — minimum five (5) years from the date of each transaction, as required by PAGCOR licensing conditions and AMLA;
• Gaming history logs — minimum three (3) years from the date of each game session;
• Customer support communications — minimum two (2) years from the date of each interaction;
• Marketing consent records — retained until consent is withdrawn plus one (1) year for compliance documentation purposes.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised. Where data has been anonymised such that individual re-identification is not reasonably possible, it may be retained indefinitely for statistical and platform improvement purposes.

9. Cookies & Tracking Technologies

The philpower Platform uses cookies and similar tracking technologies to deliver and improve the service. Categories of cookies used include:

• Strictly necessary cookies — required for Platform functionality including session authentication, load balancing, and security token management. These cannot be disabled without preventing Platform use.
• Performance and analytics cookies — collect aggregated data on Platform usage patterns to improve service performance, game loading times, and payment flow efficiency. Data is anonymised where possible.
• Functional cookies — remember your preferences such as language, device settings, and game lobby filters to personalise your experience.
• Responsible gaming cookies — store session duration data locally to enable reality-check notifications and session limit functionality.

You may configure cookie preferences through your browser settings. Disabling non-essential cookies will not prevent Platform access but may affect certain preference and personalisation features. philpower does not use third-party advertising cookies or tracking pixels for behavioural advertising purposes.

10. Data Security

philpower implements technical and organisational measures commensurate with the sensitivity of the personal data processed and the risks associated with an online gaming and financial services platform. Security measures include:

• TLS 1.3 / 256-bit SSL encryption for all data in transit between the Platform and end-user devices;
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records;
• Two-factor authentication (2FA) available and encouraged for all Player Accounts;
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis;
• Regular third-party penetration testing and vulnerability assessments;
• Comprehensive security incident response procedures, including mandatory NPC breach notification where required under the Philippine DPA.

No data security system is impenetrable. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, philpower will notify you and the National Privacy Commission as required by the Philippine Data Privacy Act within 72 hours of becoming aware of the breach.

11. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal data held by philpower:

To exercise any of these rights, submit your request via live chat or email to support@philpower.app with the subject line "Data Rights Request." philpower will acknowledge receipt within 3 business days and respond substantively within 15 business days.

12. Children and Minors

The philpower Platform is strictly restricted to individuals aged 21 years or older, as required by PAGCOR regulations governing online gaming in the Philippines. philpower does not knowingly collect personal data from individuals under 21. If philpower discovers that personal data has been collected from a person under 21, that account will be immediately suspended, all data collected will be deleted to the extent not required for regulatory compliance, and any deposited funds will be returned through the original payment method following standard verification procedures.

If you believe a minor has accessed or registered on the Platform, please contact philpower support immediately via live chat or email.

13. Changes to This Privacy Policy

philpower reserves the right to update this Privacy Policy to reflect changes in our data processing practices, Platform features, or applicable Philippine law and National Privacy Commission guidance. Material changes will be communicated to registered Players via the email address on file or through a prominent Platform notice at least fourteen (14) days before the amended Policy takes effect. The "Last updated" date at the top of this Policy indicates the most recent revision. Continued use of the Platform after the effective date of a revised Policy constitutes acceptance of the changes. If you do not accept the revised Policy, you must cease using the Platform and may request account closure.

14. Contact & Data Protection Officer

For all privacy-related enquiries, data rights requests, or concerns regarding philpower's handling of your personal information, please contact:

• Data Protection Officer (DPO): support@philpower.app — Subject line: "Privacy / DPO Enquiry"
• Live Chat: Available 24/7 via the Platform — responses within 2 minutes during operating hours

For formal complaints that cannot be resolved by philpower's DPO, you may contact the National Privacy Commission of the Philippines. philpower cooperates fully with NPC investigations and compliance reviews.