phpark21 Privacy Policy

1. Introduction

phpark21 ("Company", "we", "us", or "our") operates the phpark21 online gaming platform available at phpark21.app (the "Platform"). This Privacy Policy (the "Policy") describes how phpark21 collects, uses, stores, discloses, and protects personal information provided by or collected from individuals ("Players", "Users", "you", or "your") who access or use the Platform.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (the "DPA"), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission of the Philippines ("NPC"). It is also consistent with phpark21's obligations under PAGCOR's player protection and data handling requirements.

By registering an account or accessing the Platform, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact us to close your account.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, phpark21 acts as the Personal Information Controller in respect of all personal data collected through the Platform. Our Data Protection Officer ("DPO") can be reached via the contact details provided in Section 14 of this Policy.

3. Personal Information We Collect

phpark21 collects personal information in the following categories:

3.1 Registration Information. When you create a phpark21 account, we collect your full name, date of birth, nationality, residential address, mobile phone number, and email address. This information is required to create and verify your account and to comply with our KYC obligations under PAGCOR regulations.

3.2 Identity Verification (KYC) Documents. To process withdrawals and comply with anti-money laundering regulations, phpark21 may request copies of government-issued identification documents (such as a Philippine national ID, driver's licence, passport, or SSS/GSIS card), proof of address, and in some cases proof of funds. These documents are handled with the highest level of confidentiality.

3.3 Financial Information. We collect details of payment methods linked to your account, including GCash or Maya account numbers, bank account details (for BPI, BDO, or Metrobank transfers), and transaction history. We do not store full credit card numbers on our servers.

3.4 Gaming Activity Data. phpark21 records details of all gaming sessions, including games played, wagers placed, outcomes, timestamps, device type, and IP address. This data is used for fraud prevention, responsible gaming monitoring, and regulatory reporting.

3.5 Technical and Device Information. We automatically collect device identifiers, browser type and version, operating system, screen resolution, referring URL, and session duration data when you access the Platform. This information is collected via cookies and server logs.

3.6 Communications. If you contact phpark21 via live chat, email, or any other channel, we retain a record of those communications for quality assurance, training, and dispute resolution purposes.

3.7 Voluntary Information. From time to time, you may voluntarily provide additional information through surveys, promotions, or feedback forms hosted on the Platform.

4. How We Use Your Personal Information

phpark21 uses your personal information for the following purposes:

• Account management: Creating, maintaining, and verifying your phpark21 account, including authentication and password recovery;
• Service delivery: Processing deposits, withdrawals, and GCash/Maya transactions; providing access to games and promotional offers;
• Identity verification and KYC: Complying with PAGCOR licensing requirements and Philippine anti-money laundering laws (Republic Act No. 9160, as amended);
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, cheating, and other prohibited conduct described in our Terms & Conditions;
• Responsible gaming: Monitoring gaming patterns to identify problem gambling behaviour and enforcing self-exclusion requests;
• Customer support: Responding to enquiries, resolving disputes, and providing technical assistance;
• Legal and regulatory compliance: Meeting our obligations under Philippine law, PAGCOR requirements, and NPC directives;
• Platform improvement: Analysing aggregated usage data to improve the Platform's performance, user experience, and game library;
• Marketing communications: Sending promotional offers, newsletters, and event notifications where you have provided consent to receive such communications. You may withdraw this consent at any time.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, phpark21 processes personal data on the following lawful bases:

• Contractual necessity: Processing required to perform the contract between phpark21 and the Player (account creation, gameplay, payouts);
• Legal obligation: Processing required to comply with PAGCOR, NPC, AMLC, and other applicable regulatory requirements;
• Legitimate interests: Fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by the Player's fundamental rights;
• Consent: Marketing communications and non-essential cookies, where your prior consent has been obtained.

6. Disclosure of Personal Information to Third Parties

phpark21 does not sell, rent, or trade your personal information to third parties for commercial purposes. We may share personal information in the following limited circumstances:

6.1 Payment Processors. We share necessary financial data with GCash, Maya, BPI, BDO, and other payment processors solely to facilitate your transactions. These processors operate under their own privacy policies and are contractually bound to handle your data securely.

6.2 KYC and Identity Verification Providers. Third-party KYC service providers may receive copies of your identity documents for automated or manual verification. These providers are contractually prohibited from using your data for any purpose other than verification.

6.3 Regulatory Authorities. phpark21 may disclose personal information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or law enforcement agencies where required by law, court order, or regulatory direction.

6.4 Game Software Providers. Limited technical data may be shared with game software providers (e.g., session tokens and game round data) to support game functionality and dispute resolution. No directly identifiable personal data is shared for this purpose beyond what is technically necessary.

6.5 Corporate Transactions. In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

7. Cookies and Tracking Technologies

phpark21 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you access the Platform. We use the following categories of cookies:

• Essential cookies: Required for the Platform to function — including session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences, such as language settings and last-accessed game category.
• Analytics cookies: Collect anonymised data about how Players navigate the Platform to help us improve its design and performance. No personally identifiable information is linked to analytics cookies.
• Marketing cookies: Used to deliver relevant promotional content within the Platform. You may opt out of marketing cookies through your account preferences.

You may manage cookie preferences through your browser settings. Disabling essential cookies will impair your ability to log in and use the Platform.

8. Data Retention

phpark21 retains personal information for the following periods:

• Active accounts: Personal data is retained for the lifetime of the account plus five (5) years following account closure, as required by PAGCOR and AMLC regulations.
• KYC documents: Retained for a minimum of five (5) years from the date of account closure or the date of the last transaction, whichever is later.
• Transaction records: Retained for five (5) years from the transaction date in compliance with anti-money laundering legislation.
• Gaming session logs: Retained for two (2) years from the date of each session for dispute resolution and responsible gaming purposes.
• Support communications: Retained for three (3) years from the date of the last communication in the ticket thread.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with phpark21's data destruction procedures.

9. Data Security

phpark21 implements a multi-layered security framework to protect your personal information against unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and phpark21 servers;
• AES-256 encryption for sensitive data stored in phpark21 databases;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments by independent security firms;
• Two-factor authentication available on all Player accounts;
• Automated anomaly detection systems monitoring for suspicious login activity and data access patterns.

While phpark21 employs industry-standard security measures, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to Player rights and freedoms, phpark21 will notify affected Players and the NPC within the timeframes required by the Data Privacy Act.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, Filipino players have the following rights in relation to their personal information held by phpark21:

To exercise any of these rights, contact phpark21's Data Protection Officer at the details provided in Section 14. We will respond to verified requests within fifteen (15) working days. phpark21 may need to verify your identity before processing a data subject request to prevent unauthorised disclosure.

11. Children's and Minors' Privacy

The phpark21 Platform is strictly for individuals aged 21 years and above. We do not knowingly collect personal information from persons under 21 years of age. If we become aware that a person below the age of 21 has registered an account or provided personal data, we will immediately close the account, delete the associated personal data, and return any deposited funds to the payment source in accordance with applicable regulations.

If you believe that a minor may have accessed the Platform or provided personal information, please contact us immediately at the details in Section 14.

12. Cross-Border Data Transfers

Some phpark21 service providers and game software licensors may be located outside the Philippines. Where personal data is transferred to a third country, phpark21 ensures that appropriate contractual safeguards are in place to protect your personal information to a standard consistent with the Data Privacy Act of 2012. phpark21 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards.

13. Changes to this Privacy Policy

phpark21 may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or Platform features. Material changes will be communicated to registered Players via email notification or a prominent notice on the Platform at least fourteen (14) days before the effective date of the change. The date at the top of this Policy indicates when it was last revised. Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy.

14. Contact and Complaints

For any questions regarding this Privacy Policy, to exercise your data subject rights, or to raise a privacy complaint, please contact phpark21's Data Protection Officer via:

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24 hours a day, 7 days a week via the Platform

phpark21 will acknowledge data privacy complaints within forty-eight (48) hours and aims to resolve them within thirty (30) calendar days. If you are dissatisfied with phpark21's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at the NPC's official contact channels.