phace Privacy Policy

1. Information We Collect

1.1 Personal Information You Provide

When you register for a phace account, we collect the following personal information directly from you:

• Identity information: Full legal name, date of birth, nationality, and government-issued identification documents (for identity verification purposes as required by PAGCOR regulations).
• Contact information: Email address, mobile telephone number, and residential address.
• Account credentials: Username and encrypted password (phace does not store passwords in plain text).
• Payment information: GCash account details, Maya account details, bank account information, cryptocurrency wallet addresses, and payment transaction records.
• Verification documents: Copies of government-issued photo identification and proof of address documents submitted for account verification.

1.2 Information Collected Automatically

When you access and use the phace platform, we automatically collect certain technical and usage information:

• Device information: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, games played, bet amounts and outcomes, session duration, login times, and navigation patterns within the phace platform.
• Location data: Approximate geographic location derived from IP address to verify that you are accessing phace from within the Philippines, as required by our PAGCOR license.
• Cookies and tracking technologies: See Section 8 below for detailed information about cookies.

1.3 Information from Third Parties

phace may receive information about you from third-party service providers:

• Payment processors: Transaction confirmation data from GCash, Maya, banks, and other payment providers.
• Identity verification services: Verification results from third-party identity verification providers used to comply with PAGCOR Know Your Customer (KYC) requirements.
• Fraud prevention services: Risk assessment data from anti-fraud and anti-money laundering screening services.

2. How We Use Your Information

2.1 Lawful Basis for Processing

phace processes your personal data on the following lawful bases under the Data Privacy Act of 2012:

• Contractual necessity: To create and maintain your account, process deposits and withdrawals, enable gameplay, and fulfil our contractual obligations under the phace Terms & Conditions.
• Legal obligation: To comply with PAGCOR regulations, Anti-Money Laundering Act (AMLA) requirements, National Privacy Commission directives, tax reporting obligations, and other applicable Philippine laws.
• Legitimate interests: To prevent fraud, ensure platform security, improve user experience, and maintain the integrity of phace services.
• Consent: For marketing communications, where you have provided explicit opt-in consent.

2.2 Specific Purposes

phace uses your personal information for the following purposes:

• Creating and managing your phace account.
• Verifying your identity and age to comply with the 21+ requirement mandated by PAGCOR.
• Processing deposits, withdrawals, and other financial transactions.
• Enabling you to play casino games, place sports bets, and use other phace services.
• Providing customer support and responding to your inquiries.
• Detecting and preventing fraud, money laundering, underage gambling, and other illegal activities.
• Complying with PAGCOR reporting requirements and responding to lawful requests from government authorities.
• Sending transactional communications (deposit confirmations, withdrawal notifications, account alerts).
• Sending promotional communications if you have opted in to receive marketing (you may opt out at any time).
• Improving phace platform functionality, user experience, and game offerings based on usage analytics.
• Enforcing responsible gaming limits and self-exclusion requests.

3. How We Share Your Information

3.1 Service Providers

phace shares your personal information with trusted third-party service providers who perform services on our behalf:

• Payment processors: GCash, Maya, banks, and other payment providers process your deposits and withdrawals.
• Game providers: Third-party game developers and live casino providers process gameplay data when you play their games on the phace platform.
• Identity verification services: Specialised providers verify your identity documents to comply with PAGCOR KYC requirements.
• Cloud hosting providers: Secure servers hosting the phace platform and database infrastructure.
• Customer support tools: Live chat and support ticketing systems used by phace customer service agents.

All third-party service providers are contractually bound to protect your data and use it only for the specific purposes for which it is shared.

3.2 Regulatory and Legal Disclosures

phace may disclose your personal information to government authorities and regulatory bodies when required by law:

• PAGCOR: Regulatory reports and responses to official inquiries from the Philippine Amusement and Gaming Corporation.
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports as required under the Anti-Money Laundering Act.
• Bureau of Internal Revenue (BIR): Tax reporting for winnings above statutory thresholds.
• Law enforcement: Responses to valid legal process including court orders, subpoenas, and lawful government requests.

3.3 Business Transfers

In the event that phace is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your personal information may be transferred to the acquiring entity. You will be notified of any such change in ownership or control of your personal data.

3.4 No Selling of Personal Data

phace does not sell, rent, lease, or trade your personal information to third parties for their marketing purposes. Your data is used solely to operate phace services and comply with legal obligations.

4. Data Retention

4.1 Retention Periods

phace retains your personal information for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

4.2 Specific Retention Rules

4.3 Deletion After Retention Period

After the applicable retention period expires, phace will securely delete or anonymise your personal data so that it can no longer be associated with you as an individual.

5. Data Security

5.1 Security Measures

phace employs industry-standard technical and organisational measures to protect your personal information from unauthorised access, disclosure, alteration, and destruction:

• Encryption: 256-bit SSL/TLS encryption for all data in transit. AES-256 encryption for sensitive data at rest.
• Access controls: Role-based access controls ensure that only authorised phace personnel can access personal data, and only to the extent necessary for their job functions.
• Secure infrastructure: phace platform is hosted on secure cloud servers with regular security patching, firewalls, intrusion detection systems, and DDoS protection.
• Regular audits: Third-party security audits and penetration testing are conducted regularly to identify and remediate vulnerabilities.
• Employee training: All phace employees with access to personal data undergo mandatory data protection and security training.

5.2 Your Security Responsibilities

While phace implements robust security measures, you also have a responsibility to protect your account:

• Choose a strong, unique password and do not share it with anyone.
• Enable two-factor authentication from your account security settings.
• Log out of your phace account when using a shared or public device.
• Report any suspicious account activity to phace support immediately.

6. Your Data Rights Under the Data Privacy Act

6.1 Right to Access

You have the right to request a copy of the personal information phace holds about you. You may view much of this information directly from your phace account dashboard. For a complete data export, contact [email protected].

6.2 Right to Correction

You have the right to request correction of inaccurate or incomplete personal information. You can update your contact information, email address, and mobile number from your account settings. For other corrections, contact phace support.

6.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal data in certain circumstances. Note that phace may be legally required to retain certain data for regulatory compliance (PAGCOR and AMLA requirements mandate 7-year retention for most account data). Where legal retention obligations do not apply, phace will delete your data upon request.

6.4 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email or by updating your communication preferences in your account settings.

6.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format (such as CSV or JSON) and to transmit that data to another service provider. Contact [email protected] to request a data export.

6.6 Right to File a Complaint

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If you believe phace has violated your data privacy rights, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. Details on how to file a complaint are available on the NPC website.

7. International Data Transfers

phace primarily stores and processes your personal data within the Philippines. Where data is transferred to service providers located outside the Philippines (for example, cloud infrastructure or game providers based abroad), phace ensures that appropriate 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.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit the phace website. They help phace recognise your device, remember your preferences, maintain your login session, and understand how you use the platform.

8.2 Types of Cookies We Use

• Essential cookies: Required for the phace platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Performance cookies: Collect anonymised data about how you use phace — which pages you visit, how long you spend on each game, and which features you use most. This helps phace improve the platform experience.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and display preferences so you don't have to set them each visit.
• Analytics cookies: Help phace understand aggregate user behaviour and measure the effectiveness of platform improvements. Data collected is anonymised and aggregated.

8.3 Managing Cookies

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies will affect your ability to log in and use the phace platform. Most modern browsers allow you to block, delete, or receive warnings about cookies through the browser's privacy or security settings.

9. Children and Minors

phace is strictly prohibited from accepting players under 21 years of age, as required under PAGCOR regulations. phace does not knowingly collect personal information from individuals under 21 years old. If phace discovers that personal data has been collected from a person under the age of 21, such data will be immediately deleted and the account will be closed. If you believe a minor has registered on phace, please contact [email protected] immediately.

10. Changes to This Privacy Policy

phace may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Display a notice on the phace platform informing registered users of the change.
• Where required by law, seek your consent before applying the changes to your data.

We encourage you to review this Privacy Policy periodically. Continued use of the phace platform after any changes constitutes your acceptance of the revised Privacy Policy.

11. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, you may contact phace's Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Response time: phace will respond to all data privacy requests within 15 business days in accordance with the Data Privacy Act of 2012.

For complaints that phace is unable to resolve to your satisfaction, you may escalate to the National Privacy Commission of the Philippines.