phdraem Privacy Policy

phdraem ("phdraem," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the phdraem online gaming platform available at phdraem.net. This Privacy Policy describes how phdraem collects, uses, stores, shares, and protects your personal information when you access our website, create an account, make transactions, or interact with our services.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as well as applicable PAGCOR regulations governing the handling of player data in the Philippine online gaming industry.

If you do not agree with any part of this Privacy Policy, please discontinue use of the phdraem platform and contact our support team to request account closure and data deletion where applicable.

For the purposes of the Philippine Data Privacy Act of 2012, phdraem acts as the Personal Information Controller (PIC) with respect to the personal data of its registered players and website visitors.

phdraem has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with data privacy obligations. You may contact the DPO directly for any privacy-related inquiries, requests, or complaints (see Section 14 for contact details).

phdraem collects the following categories of personal data, depending on how you interact with our platform:

• Full legal name, date of birth, and nationality
• Government-issued ID details (e.g., Philippine passport, SSS, UMID, driver's license, PhilSys ID)
• Residential address (including city — Manila, Cebu, Davao, Quezon City, Makati, etc.)
• Email address and mobile number
• Username and encrypted password

• Deposit and withdrawal records, including amounts in Philippine Peso (₱)
• Payment method details (GCash account reference, PayMaya/Maya reference, bank account name and last digits)
• Transaction history and account balance records
• Source-of-funds documentation where required by AML regulations

• Game session logs, bet history, win/loss records across all phdraem games
• Bonus and promotion participation records
• Responsible gaming tool settings (deposit limits, self-exclusion status, cooling-off periods)

• IP address, device type, operating system, and browser information
• Geolocation data (country/region level) to verify jurisdictional eligibility
• Session timestamps, pages visited, and features used on phdraem.net
• Cookie and tracking data (see Section 7)

• Records of your communications with phdraem customer support (live chat transcripts, email correspondence)
• Survey responses and feedback submitted voluntarily

phdraem uses your personal data for the following purposes:

• Account Management: To create, verify, maintain, and secure your phdraem account, including identity verification (KYC) as required by PAGCOR and AML regulations.
• Service Delivery: To provide access to phdraem's games, process deposits and withdrawals, award bonuses, and deliver customer support.
• Legal & Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Data Privacy Act (RA 10173), and other applicable Philippine laws.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, underage gambling, and other prohibited conduct on the phdraem platform.
• Responsible Gaming: To monitor gaming behavior, enforce responsible gaming tools, and identify players who may need support or intervention.
• Communications: To send you account notifications, transaction confirmations, security alerts, and — where you have opted in — promotional offers and updates about phdraem.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the phdraem user experience.

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

• Contractual Necessity: Processing is necessary to perform the contract between you and phdraem (i.e., to provide gaming services, process payments, and manage your account).
• Legal Obligation: Processing is required to comply with PAGCOR regulations, AMLA obligations, tax reporting requirements, and other applicable Philippine laws.
• Legitimate Interests: Processing is necessary for phdraem's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, phdraem relies on your freely given, specific, and informed consent, which you may withdraw at any time.

phdraem does not sell or rent your personal data. We may share your data with the following categories of recipients only to the extent necessary:

Third-party vendors who assist phdraem in operating the platform, including payment processors (GCash, PayMaya, Philippine banks), identity verification providers, cloud hosting services, and customer support tools. All service providers are bound by data processing agreements requiring them to protect your data.

PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government agencies where disclosure is required by law or court order.

Where required by PAGCOR regulations, phdraem may share limited player data with recognized problem gambling support organizations or self-exclusion registries to protect vulnerable players.

In the event of a merger, acquisition, or sale of phdraem's business assets, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

phdraem uses cookies and similar tracking technologies on phdraem.net to enhance your experience and gather analytics data. The types of cookies we use include:

• Essential Cookies: Required for the platform to function correctly — including session management, login authentication, and security features. These cannot be disabled.
• Analytics Cookies: Used to understand how players navigate phdraem.net, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized.
• Preference Cookies: Store your language, display, and notification preferences to personalize your phdraem experience.
• Marketing Cookies: Used only with your consent to deliver relevant promotional content about phdraem. You may opt out at any time via your account settings.

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies may affect the functionality of the phdraem platform.

phdraem implements comprehensive technical and organizational security measures to protect your personal data, including:

• TLS/SSL encryption for all data transmitted between your device and phdraem servers
• Encryption of sensitive data at rest, including financial records and identity documents
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits, vulnerability assessments, and penetration testing
• Multi-factor authentication (MFA) options for player accounts
• 24/7 monitoring of systems for suspicious activity and potential data breaches

phdraem retains your personal data for the following periods:

• Active Account Data: Retained for the duration of your account's active status plus five (5) years after account closure, as required by PAGCOR and AMLA regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA record-keeping requirements.
• Identity Verification Documents: Retained for five (5) years after account closure or the last transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained until you withdraw consent, plus one (1) year for compliance documentation purposes.

Upon expiry of the applicable retention period, phdraem will securely delete or anonymize your personal data in accordance with NPC-approved disposal methods.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phdraem:

• Right to be Informed: The right to know what personal data phdraem collects, how it is used, and with whom it is shared — as described in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phdraem holds about you, including information on how it has been processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your phdraem account settings.
• Right to Erasure: 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 legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe phdraem has violated your data privacy rights.

phdraem's services are strictly intended for individuals who are at least 21 years of age, in accordance with PAGCOR regulations governing online gaming in the Philippines. phdraem does not knowingly collect personal data from individuals under 21 years of age.

If phdraem discovers that personal data has been collected from a person under 21, the account will be immediately suspended, all data will be deleted, and the matter may be reported to the relevant authorities. If you believe a minor has registered on phdraem, please contact our support team immediately.

phdraem primarily stores and processes your personal data on servers located within the Philippines or in jurisdictions that provide an adequate level of data protection as recognized by the National Privacy Commission.

Where data is transferred outside the Philippines — for example, to cloud service providers or technology partners — phdraem ensures that appropriate safeguards are in place, including data processing agreements that require the recipient to protect your data to a standard equivalent to RA 10173.

phdraem may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When material changes are made, phdraem will notify registered players via email or a prominent notice on the platform, and the "Last Updated" date at the top of this page will be revised accordingly.

Your continued use of phdraem following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how phdraem protects your personal data.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact phdraem's Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the phdraem platform
• Response Time: Within 15 business days of receiving a verified request

If you are not satisfied with phdraem's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.