phtaya51 Privacy Policy

1 Introduction

1.1 phtaya51 is an online casino and sports betting platform serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and all other regions. We take the privacy and security of our players' personal information seriously.

1.2 This Policy applies to all personal data collected by phtaya51 through the phtaya51 website, mobile platform, customer support channels, and any other touchpoints through which you interact with phtaya51.

1.3 This Policy should be read alongside phtaya51's Terms & Conditions and Responsible Gaming Policy, which together govern your relationship with phtaya51.

1.4 phtaya51 processes personal data in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations ("IRR"), as overseen by the National Privacy Commission ("NPC").

2 Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, phtaya51 acts as the personal information controller in respect of the personal data it collects from players and users of the platform.

2.2 phtaya51 has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at the email address provided in Section 15 of this Policy.

2.3 Where phtaya51 engages third-party service providers to process personal data on its behalf, those providers act as personal information processors and are bound by contractual obligations to process data only in accordance with phtaya51's instructions and this Policy.

3 Personal Data We Collect

3.1 phtaya51 collects the following categories of personal data from players and users:

3.1.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (to verify you are 21 years of age or older);
• Gender;
• Nationality and country of residence;
• Government-issued identification number (e.g., PhilSys ID, passport number, driver's license number).

3.1.2 Contact Data

• Email address;
• Philippine mobile number;
• Residential address (barangay, city/municipality, province).

3.1.3 Financial Data

• GCash or PayMaya mobile wallet number;
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where used for transactions;
• Credit or debit card details (Visa, Mastercard) — card numbers are tokenized and never stored in full;
• Transaction history including deposits, withdrawals, and bonus activity.

3.1.4 Gaming & Behavioral Data

• Game play history, bet amounts, win/loss records;
• Session duration and frequency of play;
• Responsible gaming tool usage and self-exclusion records;
• Bonus and promotion participation history.

3.1.5 Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Cookie identifiers and session tokens;
• Login timestamps and access logs.

3.1.6 Communications Data

• Records of your communications with phtaya51 customer support;
• Feedback, survey responses, and complaints submitted to phtaya51.

4 How We Collect Your Data

4.1 phtaya51 collects personal data through the following means:

• Direct collection: Information you provide when registering for a phtaya51 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the phtaya51 platform, including via cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment data from GCash, PayMaya, and banking partners.

4.2 phtaya51 does not collect personal data from social media platforms or purchase data lists from third-party data brokers.

5 How We Use Your Personal Data

5.1 phtaya51 uses your personal data for the following purposes:

5.2 phtaya51 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

6.1 phtaya51 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with Philippine laws, including AML regulations, PAGCOR licensing requirements, and tax obligations;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time.

7 Sharing Your Personal Data

7.1 phtaya51 does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• KYC and identity verification providers: To verify your identity and age as required by law;
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, to process your financial transactions;
• AML and fraud screening services: To detect and prevent money laundering, fraud, and other financial crimes;
• Game content providers: Game studios and live casino operators who provide games on the phtaya51 platform may receive limited technical data necessary to deliver their services;
• IT and cloud infrastructure providers: Hosting, database, and security service providers operating under strict data processing agreements;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and Philippine law enforcement agencies, where required by law or court order.

7.2 All third-party processors engaged by phtaya51 are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with phtaya51's documented instructions.

7.3 Where personal data is transferred outside the Philippines, phtaya51 ensures that appropriate safeguards are in place in accordance with the DPA and NPC guidelines, including contractual clauses that provide equivalent data protection standards.

8 Cookies & Tracking Technologies

8.1 phtaya51 uses cookies and similar tracking technologies to enhance your experience on the platform, maintain your session, and analyze platform usage. The following types of cookies are used:

• Strictly necessary cookies: Required for the platform to function. These cannot be disabled. They include session authentication tokens and security cookies;
• Functional cookies: Remember your preferences such as language settings and display options;
• Analytics cookies: Collect anonymized data about how players use phtaya51 to help us improve the platform. No personally identifiable information is included in analytics data;
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your explicit consent.

8.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phtaya51 platform.

8.3 phtaya51 does not use third-party advertising networks or cross-site tracking technologies that share your data with external advertisers.

9 Data Security

9.1 phtaya51 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data in transit;
• AES-256 encryption for sensitive data at rest;
• Multi-factor authentication for account access;
• Regular penetration testing and security audits;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• 24/7 security monitoring and intrusion detection systems;
• Tokenization of payment card data — full card numbers are never stored on phtaya51 servers.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phtaya51 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay in accordance with the DPA.

9.3 While phtaya51 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your phtaya51 account credentials.

10 Data Retention

10.1 phtaya51 retains your personal data for the following periods:

• Active account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations;
• Transaction records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and PAGCOR regulations;
• KYC documents: Retained for five (5) years following account closure or the last transaction, whichever is later;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained until you withdraw consent, plus one (1) year for compliance documentation purposes;
• Technical logs: Retained for twelve (12) months for security and fraud investigation purposes.

10.2 Upon expiry of the applicable retention period, phtaya51 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

11 Your Rights as a Data Subject

11.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phtaya51:

• Right to be informed: The right to know what personal data phtaya51 holds about you and how it is being processed;
• Right of access: The right to request a copy of the personal data phtaya51 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to phtaya51's legal retention obligations;
• Right to object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

11.2 To exercise any of the above rights, please contact phtaya51's Data Protection Officer at [email protected]. phtaya51 will respond to your request within thirty (30) days in accordance with the DPA.

11.3 phtaya51 may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties.

12 Children's Privacy

12.1 phtaya51 is strictly intended for persons aged twenty-one (21) years and above. phtaya51 does not knowingly collect personal data from persons under the age of 21.

12.2 If phtaya51 discovers that it has inadvertently collected personal data from a person under 21 years of age, it will immediately close the relevant account, delete the personal data, and return any deposited funds to the payment source.

12.3 If you are a parent or guardian and believe that your child has registered on phtaya51, please contact our support team immediately at [email protected] so that we can take prompt action.

13 Third-Party Links

13.1 The phtaya51 platform may contain links to third-party websites or services, such as payment provider portals. phtaya51 is not responsible for the privacy practices of those third-party sites and encourages you to review their privacy policies before providing any personal information.

13.2 The inclusion of a link to a third-party site on phtaya51 does not constitute an endorsement of that site's privacy practices or content.

14 Changes to This Privacy Policy

14.1 phtaya51 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements.

14.2 Where changes are material, phtaya51 will notify registered players via their registered email address or via a prominent notice on the platform at least seven (7) days before the changes take effect.

14.3 The most current version of this Privacy Policy will always be available at phtaya51.club/privacy-policy. The "Last Updated" date at the top of this Policy indicates when it was most recently revised.

14.4 Your continued use of phtaya51 following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

15 Contact & Complaints

15.1 If you have any questions, concerns, or requests regarding this Privacy Policy or phtaya51's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: Privacy / Data Subject Request
• Response time: Within 30 days of receipt
• Support languages: English and Filipino

15.2 If you are not satisfied with phtaya51's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC)
• 3rd Floor, Core G, GSIS Headquarters, Financial Center, Roxas Boulevard, Pasay City, Metro Manila, Philippines