phcssh Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how phcssh ("the Platform," "we," "us," "our"), a PAGCOR-registered online gaming platform accessible at phcssh.cam, collects, uses, stores, shares, and protects the personal data of individuals ("Players," "Data Subjects," "you," "your") who access or use the phcssh platform.

phcssh recognizes the importance of personal data privacy to Filipino players. The Philippines has one of Southeast Asia's most comprehensive data protection frameworks, and phcssh is fully committed to operating in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR") as administered by the National Privacy Commission ("NPC").

This Policy applies to all personal data collected from Players and prospective Players in connection with your use of the phcssh platform, whether accessed via mobile browser, desktop browser, or any other interface. It should be read in conjunction with phcssh's Terms and Conditions and Responsible Gaming Policy.

By registering a phcssh account or continuing to use the phcssh 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.

Data Controller Identity

For the purposes of the Philippine Data Privacy Act of 2012, the Personal Information Controller (PIC) responsible for your personal data is phcssh, the entity operating the gaming platform at phcssh.cam under PAGCOR authorization.

phcssh has appointed a Data Protection Officer (DPO) responsible for overseeing data protection compliance across the platform. The DPO can be contacted at [email protected] with the subject line "Data Protection Officer — [Your Query]." All data protection enquiries, rights requests, and complaints should be directed to this address.

Personal Data We Collect

phcssh collects the following categories of personal data about Players, depending on the nature of the Player's interaction with the platform:

3.1 Identity and Registration Data

• Full legal name as it appears on a Philippine government-issued ID;
• Date of birth (for age verification — all Players must be 21 years or older);
• Gender;
• Philippine mobile number (primary login identifier);
• Email address;
• Residential address within the Philippines (Barangay, City/Municipality, Province).

3.2 Identity Verification (KYC) Data

• Copies of Philippine government-issued identification documents (e.g., SSS ID, PhilHealth, Driver's License, Passport, UMID, PhilSys ID);
• Selfie photographs or liveness verification images submitted for facial matching;
• Source of funds documentation where required by PAGCOR regulations or Philippine anti-money laundering law.

3.3 Financial and Transaction Data

• GCash account number or Maya account number linked to your phcssh wallet;
• Bank account details (BPI, BDO, Metrobank) where provided for withdrawal;
• Deposit and withdrawal transaction history, including amounts, timestamps, and payment method references;
• phcssh wallet balance at any given time.

3.4 Gaming Activity Data

• Game history, including all wagers placed, game outcomes, and session durations;
• Bonus usage and wagering requirement progress;
• Responsible gaming tool settings (deposit limits, loss limits, session reminders, self-exclusion status).

3.5 Technical and Device Data

• IP address at time of login and during sessions;
• Device type, operating system version, and browser type;
• Mobile network operator (e.g., Smart, Globe, DITO) where applicable;
• Geolocation data (city/region level only, used for fraud prevention);
• Session logs, including login times, session duration, and pages visited.

3.6 Communications Data

• Records of your communications with phcssh support, including live chat transcripts and email correspondence;
• Survey responses, feedback submissions, and complaint records.

How We Collect Your Data

phcssh collects personal data through the following channels:

• Direct submission by the Player — during account registration, KYC verification submissions, withdrawal requests, support contacts, and survey participation;
• Automated technical collection — through cookies, session logs, and analytics tools when you access and interact with the phcssh platform (see Section 10 for cookie details);
• Third-party payment processors — GCash, Maya, GrabPay, and banking partners may provide phcssh with transaction reference data necessary to confirm deposit and withdrawal completions;
• Identity verification partners — phcssh may engage accredited KYC service providers to assist with document verification and liveness checks, subject to data processing agreements compliant with the Philippine DPA;
• Fraud prevention services — IP reputation, device fingerprint, and geolocation data may be obtained from third-party fraud detection providers to protect the platform and its players.

Purposes of Data Processing

phcssh processes your personal data for the following specific, legitimate purposes:

• Account creation and management — verifying eligibility, creating your phcssh account, authenticating logins, and maintaining account records;
• Age and identity verification — confirming that Players meet the mandatory 21+ age requirement under PAGCOR regulations and Philippine law;
• Platform operation — facilitating game access, processing wagers, calculating winnings, managing bonus credits, and delivering the core phcssh gaming experience;
• Payment processing — processing deposits from GCash, Maya, and linked bank accounts, and facilitating withdrawals to Players' registered financial accounts;
• PAGCOR regulatory compliance — fulfilling phcssh's obligations under PAGCOR's terms of authorization, including player activity reporting, KYC compliance, and responsible gaming record-keeping;
• Anti-money laundering (AML) compliance — meeting phcssh's obligations under Republic Act No. 9160 (Anti-Money Laundering Act) as amended, including transaction monitoring and suspicious transaction reporting to the Anti-Money Laundering Council (AMLC);
• Fraud prevention and platform security — detecting and preventing unauthorized account access, collusion, bonus abuse, chargebacks, and other prohibited conduct;
• Customer support — responding to enquiries, resolving disputes, and processing complaints;
• Responsible gaming — monitoring gaming behaviour for indicators of problem gambling and administering self-exclusion, deposit limit, and cool-off requests;
• Platform improvement — analysing aggregated usage data to improve the phcssh platform, game library, and user experience;
• Marketing communications — sending promotional offers, bonus notifications, and platform updates to Players who have opted in to receive marketing communications (see Section 14 for opt-out details).

Legal Basis for Processing

phcssh processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity — processing required to fulfil our agreement with you under the phcssh Terms and Conditions, including account management, payment processing, and game delivery;
• Legal obligation — processing required to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself;
• Legitimate interests — processing for fraud prevention, platform security, and aggregated analytics, where these interests are not overridden by your data protection rights;
• Consent — processing for direct marketing communications, where we rely on your explicit opt-in consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

Data Sharing and Third Parties

phcssh does not sell your personal data to any third party. We share your personal data only in the following limited circumstances, and always subject to appropriate contractual and technical safeguards:

• Payment processors — GCash, Maya, GrabPay, BPI, BDO, Metrobank, and 7-Eleven CLiQQ receive transaction reference data necessary to process your deposits and withdrawals. Their handling of your data is governed by their own privacy policies;
• KYC and identity verification providers — accredited third-party providers engaged by phcssh to perform document verification and liveness checks, operating under data processing agreements with phcssh;
• Game content providers — providers such as PG Soft, Pragmatic Play, and Jili receive anonymized session tokens to enable game delivery; they do not receive personally identifiable information;
• Regulatory and government authorities — PAGCOR, the AMLC, the National Privacy Commission, and other competent Philippine government bodies where disclosure is required by law, court order, or regulatory directive;
• Fraud prevention and security services — third-party providers assisting with IP reputation analysis, device fingerprinting, and geolocation-based fraud detection, under strict data processing agreements;
• Professional advisors — lawyers, auditors, and compliance consultants engaged by phcssh under professional confidentiality obligations where access to personal data is reasonably necessary;
• Business transfers — in the event of a merger, acquisition, or sale of phcssh's business, personal data may be transferred to the successor entity, provided that the successor commits to honoring the terms of this Privacy Policy and applicable Philippine DPA requirements.

International Data Transfers

phcssh's primary data processing infrastructure is hosted within or directed at the Philippines. Where data is processed by third-party service providers whose infrastructure is located outside the Philippines — such as cloud services, KYC verification platforms, or game studios with offshore data centres — phcssh ensures that appropriate safeguards are in place in accordance with Section 21 of the Philippine Data Privacy Act and the NPC's rules on cross-border data transfers.

These safeguards include contractual commitments (data processing agreements and standard contractual clauses) requiring overseas recipients to protect your personal data to a standard substantially equivalent to that required under Philippine law. phcssh will not transfer your data to a jurisdiction whose data protection laws do not provide adequate safeguards without your explicit consent or a legally recognized transfer mechanism.

Data Retention

phcssh retains your personal data only for as long as is necessary for the purposes described in this Policy or as required by applicable Philippine law. The following retention periods apply:

• Account and identity data — retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AMLC record-keeping obligations;
• Transaction and financial data — retained for a minimum of five (5) years as required by the Philippine Anti-Money Laundering Act;
• KYC documents — retained for the duration of the account relationship and five (5) years post-closure, in accordance with PAGCOR and AMLC requirements;
• Gaming activity logs — retained for two (2) years from the date of each session for operational, dispute resolution, and regulatory purposes;
• Customer support records — retained for two (2) years from the date of the support interaction;
• Marketing consent records — retained until consent is withdrawn and for a reasonable period thereafter to demonstrate prior consent compliance.

On expiry of the applicable retention period, phcssh will securely delete or anonymize your personal data unless further retention is required by a new legal obligation arising after this Policy's effective date.

Cookies and Tracking Technologies

phcssh uses cookies and similar tracking technologies to operate the platform, maintain your login session, enable game delivery, and analyse platform usage. The following types of cookies are used:

• Strictly necessary cookies — required for the phcssh platform to function correctly, including session authentication, security tokens, and fraud prevention flags. These cannot be disabled without impairing platform functionality;
• Performance and analytics cookies — collect anonymized data about how Players interact with the phcssh platform, which pages are visited, and how long sessions last, to help us improve the platform experience;
• Functional cookies — remember your platform preferences, such as your last played game category, preferred deposit method, or notification settings;
• Marketing cookies — used only where you have opted in to receive marketing communications, to help phcssh deliver relevant promotional content. These are not used for third-party advertising networks.

You may control cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect the functionality of your phcssh account. Detailed cookie settings are available in your phcssh account preferences panel.

Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to the personal data phcssh holds about you. These rights may be exercised at any time by contacting phcssh's Data Protection Officer at [email protected].

phcssh will respond to all verified data subject rights requests within fifteen (15) business days of receipt. Where a request is complex or involves a large volume of data, phcssh will notify you of the extended timeline within the initial 15-day period. Identity verification may be required before processing a rights request to ensure we disclose or modify data only at the authenticated account holder's direction.

Security Measures

phcssh implements a comprehensive set of organizational and technical security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• Transport encryption — all data transmitted between Players and phcssh is encrypted using TLS 1.2 or higher (256-bit SSL);
• Data-at-rest encryption — sensitive personal data stored in phcssh's databases is encrypted at rest using AES-256 encryption;
• Access controls — phcssh personnel access to personal data is role-based and limited to those with a legitimate operational need. All internal access is logged and auditable;
• Two-factor authentication (2FA) — phcssh enforces OTP-based 2FA for Player logins from new or unrecognized devices;
• Penetration testing — phcssh's platform undergoes regular security assessments to identify and remediate vulnerabilities;
• Incident response — phcssh maintains a documented data breach response procedure aligned with NPC notification requirements under the Philippine DPA.

While phcssh applies rigorous security measures, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phcssh login credentials and for notifying phcssh immediately if you suspect unauthorized access to your account.

Children's Privacy and Age Restriction

phcssh is strictly an adults-only platform. In compliance with PAGCOR regulations governing online gaming in the Philippines, the minimum age for all phcssh account holders is twenty-one (21) years. phcssh does not knowingly collect personal data from persons under the age of 21.

If phcssh determines that a Player is under 21 years of age, the account will be permanently closed, any balance will be forfeited in accordance with phcssh's Terms and Conditions, and all personal data associated with the underage account will be deleted in a manner consistent with this Policy's retention obligations, except where retention is required for regulatory or legal compliance purposes.

If you believe that a person under 21 has created a phcssh account using false information, please contact phcssh immediately at [email protected].

Marketing Communications

phcssh may send you promotional offers, bonus notifications, new game announcements, and other platform updates via SMS, email, or in-platform notification, where you have opted in to receive such communications at the time of account registration or subsequently through your account notification settings.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your notification preferences in your phcssh account settings;
• Clicking the "unsubscribe" link in any marketing email sent by phcssh; or
• Contacting phcssh support at [email protected] with the subject line "Unsubscribe."

Withdrawal of consent to marketing will not affect the delivery of transactional communications that are necessary for platform operation, such as deposit confirmation SMS messages, withdrawal processing updates, security alerts, and account management notifications. These communications form part of the phcssh service and are sent regardless of marketing consent status.

Changes to This Privacy Policy

phcssh reserves the right to amend this Privacy Policy at any time to reflect changes in applicable Philippine law, PAGCOR regulatory requirements, platform operations, or data processing practices. Where amendments are material, phcssh will provide reasonable advance notice to registered Players via their registered email address or Philippine mobile number.

The amended Policy will be published on this page with a revised "Last Updated" date. Your continued use of the phcssh platform following the effective date of any amendment constitutes your acknowledgment and acceptance of the revised Policy. We encourage Players to review this Policy periodically to remain informed of how phcssh handles personal data.

Contact & Complaints

For any questions about this Privacy Policy, to exercise your data subject rights, or to raise a data protection concern, please contact phcssh's Data Protection Officer through the following channels:

• DPO and KYC Enquiries: [email protected] (subject: "Privacy Policy Enquiry")
• General Support: [email protected]
• Live Chat: Available 8:00 AM – 12:00 AM PHT, 7 days a week via the phcssh platform

If you are not satisfied with phcssh's handling of your personal data or your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, the independent regulatory authority responsible for enforcing the Philippine Data Privacy Act of 2012.