phrich Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how phrich ("phrich," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("Player," "User," or "you") who access or use the phrich online casino and sports betting platform available at phrich.app and all associated services (collectively, the "Platform").

phrich is committed to safeguarding the privacy and personal data of all Filipino players, whether you are based in Metro Manila, Cebu, Davao, Quezon City, Makati, or anywhere else across Luzon, Visayas, and Mindanao. We operate in full compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and the implementing rules and regulations issued by the National Privacy Commission (NPC).

Please read this Policy carefully. By registering a phrich account or continuing to use 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 with this Policy, you must not use the phrich Platform.

2 Personal Data We Collect

phrich collects only the personal data that is necessary to provide our services, verify your identity, process transactions, and comply with applicable Philippine regulatory requirements. The categories of personal data we collect include:

3 How We Collect Your Data

phrich collects your personal data through the following means:

• Direct collection: Information you provide when registering your phrich account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the phrich Platform, including through cookies, web beacons, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers, fraud prevention data from security partners, and payment data from payment processors such as GCash and PayMaya.
• Regulatory sources: Information received from Philippine regulatory authorities in connection with compliance obligations.

4 How We Use Your Personal Data

phrich uses your personal data for the following purposes:

• To create, manage, and maintain your phrich account, including verifying your identity and age (21+ requirement).
• To process deposits and withdrawals in Philippine Peso (₱) via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• To provide and improve the phrich gaming experience, including live casino, slots, bingo, and sports betting services.
• To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct on the Platform.
• To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) requirements and PAGCOR-related compliance obligations.
• To send you transactional communications, including deposit confirmations, withdrawal notifications, and account security alerts.
• To send you marketing communications about phrich promotions, bonuses, and new features, where you have consented to receive such communications.
• To monitor your gaming activity for responsible gaming purposes, including identifying patterns that may indicate problem gambling behavior.
• To resolve disputes, enforce our Terms & Conditions, and respond to legal claims.

5 Legal Basis for Processing

phrich processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Contractual necessity: Processing required to perform our obligations under the phrich Terms & Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, KYC requirements, and regulatory reporting obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw your consent at any time.

6 Data Sharing and Disclosure

phrich does not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers who assist phrich in verifying your identity and age in compliance with Philippine regulatory requirements.
• Fraud prevention and security partners: Service providers who assist phrich in detecting and preventing fraudulent activity, money laundering, and other prohibited conduct.
• Regulatory authorities: Philippine government agencies and regulatory bodies, including PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by law or regulatory obligation.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on phrich's behalf under strict data processing agreements.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers where necessary for legal compliance, dispute resolution, or corporate governance purposes.

All third parties with whom phrich shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and are prohibited from using your data for any purpose other than the specific purpose for which it was shared.

7 Cookies and Tracking Technologies

phrich uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support our security and fraud prevention measures. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences and settings, such as your preferred language and display options, to provide a more personalized phrich experience.
• Analytics cookies: Help phrich understand how players use the Platform, which pages are most visited, and where improvements can be made. Data collected is aggregated and anonymized.
• Marketing cookies: Used to deliver relevant phrich promotions and offers. These are only placed with your explicit consent.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phrich Platform.

8 Data Retention

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

• Account data and transaction records are retained for a minimum of five (5) years following account closure, as required under Philippine anti-money laundering regulations.
• Identity verification documents are retained for the duration of your account and for five (5) years thereafter.
• Customer support communications are retained for three (3) years from the date of the last interaction.
• Marketing consent records are retained for as long as you remain a registered phrich player or until you withdraw your consent, whichever is earlier.
• Technical and usage data collected via cookies is retained for periods specified in our cookie settings, typically ranging from session-only to a maximum of twenty-four (24) months.

Upon expiry of the applicable retention period, phrich will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

9 Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the phrich Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls ensuring that only authorized phrich personnel can access personal data, on a need-to-know basis.
• Regular security audits and vulnerability assessments of the phrich Platform and infrastructure.
• Two-factor authentication options for phrich account login to protect against unauthorized access.
• Incident response procedures to detect, report, and address any personal data breaches in accordance with NPC notification requirements.

While phrich takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are also responsible for maintaining the security of your phrich login credentials and should notify us immediately if you suspect any unauthorized access to your account.

10 Your Data Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phrich:

• Right to be informed: You have the right to be informed about how phrich collects and processes your personal data, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data phrich holds about you.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data phrich holds about you.
• Right to erasure: You have 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 phrich's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe phrich has violated your data privacy rights.

To exercise any of the above rights, please contact the phrich Data Privacy Officer at [email protected]. phrich will respond to all verified data privacy requests within thirty (30) days of receipt, in accordance with NPC guidelines.

11 Children's Privacy and Age Restriction

The phrich Platform is strictly intended for adults aged 21 years and above, as required under Philippine law governing online gambling and casino-style gaming. phrich does not knowingly collect personal data from individuals under the age of 21.

If phrich becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered a phrich account, please contact our support team immediately at [email protected].

phrich employs age verification procedures during the account registration process to prevent underage access to the Platform. All players are required to provide valid proof of age before their account is fully activated.

12 Changes to This Privacy Policy

phrich reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or NPC guidelines. Where changes are material, phrich will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The effective date at the top of this Policy indicates when it was last updated. Your continued use of the phrich Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how phrich protects your personal data.

13 Contact Our Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or phrich's data processing practices, please contact our Data Privacy Officer. Our team is available to assist Filipino players across the Philippines, seven days a week.

Data Privacy Officer Email: [email protected]

For concerns related to your rights under the Data Privacy Act of 2012, you may also contact the National Privacy Commission (NPC) directly. For matters related to responsible gaming and self-exclusion, please visit our Responsible Gaming page. For a full overview of your account obligations, please review our Terms & Conditions.