phiery Privacy Policy

01 Introduction

phiery ("phiery", "we", "us", or "our") operates the online gaming platform accessible at phiery.cam (the "Platform"). We understand that your privacy is important to you and we are committed to processing your personal data responsibly, transparently, and in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

This Privacy Policy ("Policy") describes how phiery collects, uses, stores, protects, discloses, and otherwise processes the personal data of all individuals who register an account on, access, or otherwise interact with the phiery Platform ("you" or "Player"). It applies to all phiery services, features, and communications.

This Policy should be read together with phiery's Terms and Conditions and Responsible Gaming Policy, both of which are accessible from the footer of every page on the Platform.

02 Data Controller

phiery is the personal information controller in respect of all personal data collected through the Platform. As data controller, phiery determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with the Data Privacy Act of 2012 and this Policy.

phiery has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection compliance within the organisation. The DPO can be contacted at the email address specified in Section 14 of this Policy. All data privacy concerns, access requests, and complaints should be directed to the DPO in the first instance.

03 Personal Data We Collect

phiery collects the following categories of personal data from Players:

3.1 Registration and Identity Data

• Full legal name as it appears on your government-issued identification document;
• Date of birth (to verify you are 21 years of age or older as required by PAGCOR);
• Residential address, including barangay, city, province, and postal code;
• Email address and mobile number registered in the Philippines;
• Username and encrypted password;
• Gender (optional, used for personalisation purposes only).

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., PhilSys ID, passport, driver's licence, SSS ID, UMID);
• Proof of residential address documents (e.g., utility bill, bank statement issued within 90 days);
• Source of funds documentation where required for regulatory compliance;
• Selfie or facial image submitted for liveness verification, where applicable.

3.3 Financial and Transaction Data

• GCash mobile number, PayMaya account reference, and bank account details for deposit and withdrawal processing;
• Deposit and withdrawal transaction history, amounts, dates, and payment method references;
• Account balance history and bonus credit records.

3.4 Gaming and Usage Data

• Game session data including game type, session duration, wager amounts, and outcomes;
• Sports betting selections, wager amounts, and settlement records;
• Platform interaction logs including pages visited, features used, and session timestamps;
• Device and browser information including IP address, device type, operating system, and browser version;
• Geolocation data at the time of login (city and province level, used for fraud prevention purposes).

3.5 Communications Data

• Records of your communications with phiery's customer support team, including live chat transcripts and email correspondence;
• Survey responses and feedback submitted through the Platform;
• Preferences recorded for marketing communications, where you have provided consent.

04 How We Collect Personal Data

phiery collects your personal data through the following means:

• Directly from you when you register an account, complete KYC verification, make deposits or withdrawals, place bets, contact support, or submit any form on the Platform;
• Automatically through your use of the Platform — including through cookies, server logs, and analytics tools that record device information, IP addresses, and browsing behaviour on the Platform;
• From third-party service providers engaged by phiery for identity verification, payment processing, fraud detection, and responsible gaming compliance — where such providers share data with phiery in accordance with their own privacy policies and applicable data sharing agreements;
• From Philippine regulatory authorities where required by law, such as responses to lawful requests from PAGCOR or the AMLC.

05 Legal Basis for Processing

phiery processes personal data on one or more of the following legal bases as provided under the Data Privacy Act of 2012:

06 How phiery Uses Your Personal Data

phiery uses your personal data for the following purposes:

• To create, maintain, and manage your phiery Account, including verifying your identity and age as required by PAGCOR and the Data Privacy Act;
• To process your deposits, withdrawals, and all financial transactions on the Platform via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods;
• To provide access to all phiery games, live dealer tables, sports betting, and other Platform features in accordance with the phiery Terms and Conditions;
• To detect, prevent, and investigate fraud, money laundering, collusion, and other prohibited activities on the Platform, including reporting to the AMLC where required by law;
• To enforce phiery's Terms and Conditions, responsible gaming policies, and any applicable PAGCOR regulatory requirements;
• To respond to your support enquiries, resolve disputes, and manage your communications with phiery;
• To analyse aggregate, anonymised usage patterns for the purpose of improving Platform performance, game selection, and user experience — individual Player profiles are not used for this purpose;
• To send you service communications, including account notifications, security alerts, and material updates to phiery's policies;
• To send you promotional communications about phiery bonuses, new games, and offers — only where you have expressly consented to receive such communications and have not subsequently withdrawn that consent;
• To comply with all applicable Philippine laws, regulations, and orders from competent authorities including the NPC, PAGCOR, AMLC, and courts of competent jurisdiction.

07 Sharing and Disclosure of Personal Data

phiery does not sell, rent, or trade your personal data to any third party. phiery may share your personal data with the following categories of recipients only to the extent necessary and under appropriate contractual or legal safeguards:

7.1 Service Providers and Processors

phiery engages trusted third-party service providers who process personal data on phiery's behalf, including: payment processors and e-wallet providers (GCash/GXI Inc., PayMaya/Voyager Innovations, BPI, BDO, Metrobank); identity verification and KYC service providers; fraud detection and cybersecurity service providers; customer support platform providers; and cloud infrastructure providers. All such providers are bound by data processing agreements requiring compliance with the Data Privacy Act of 2012 and phiery's data protection standards.

7.2 Regulatory and Law Enforcement Authorities

phiery will disclose personal data to Philippine regulatory authorities, law enforcement agencies, and courts where required by law or a lawful order, including but not limited to: the National Privacy Commission (NPC), PAGCOR, the Anti-Money Laundering Council (AMLC), and the Philippine National Police or National Bureau of Investigation in the course of lawful investigations.

7.3 Business Transfers

In the event of a merger, acquisition, or transfer of all or substantially all of phiery's assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the acquiring entity will be required to honour the commitments set out in this Policy.

7.4 With Your Consent

phiery may share your personal data with third parties not described above where you have provided explicit, informed, and freely given consent to such disclosure.

08 Cookies and Tracking Technologies

phiery uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly Necessary Cookies: Required for the Platform to function — including maintaining your login session, storing your language preferences, and ensuring security features operate correctly. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences across sessions, such as your preferred table limits, game filters, and notification settings.
• Analytics Cookies: Used to collect aggregate, anonymised data about how players interact with the Platform — such as which game categories are most visited and where technical errors occur. This data is used solely to improve the Platform and is never linked to individual Player identities.

phiery does not use third-party advertising, retargeting, or cross-site tracking cookies. You may manage or delete cookies through your browser settings at any time. Note that disabling strictly necessary cookies will impair your ability to use the Platform.

09 Data Security

phiery implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phiery's servers;
• Encryption of sensitive data fields — including passwords, payment details, and identity document scans — at rest using industry-standard algorithms;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments of phiery's infrastructure;
• Two-factor authentication requirements for all phiery employees accessing internal systems containing personal data;
• Real-time fraud detection and anomaly monitoring systems that flag unusual account activity for immediate review.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phiery will notify the NPC and affected Players in accordance with the Data Privacy Act of 2012 and NPC Circular No. 16-03.

10 Data Retention

phiery retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law, whichever is longer. The following general retention periods apply:

• Account and identity data: Retained for a minimum of five (5) years following account closure or last activity, as required by PAGCOR record-keeping obligations and the AMLA's record retention requirements;
• Transaction and financial records: Retained for a minimum of five (5) years in accordance with AMLC regulations;
• KYC documentation: Retained for a minimum of five (5) years following account closure or last transaction;
• Customer support communications: Retained for three (3) years from the date of the relevant interaction;
• Gaming session logs: Retained for two (2) years from the date of the session, unless required for longer for a regulatory investigation or dispute;
• Analytics data: Retained in anonymised, aggregated form indefinitely; individual identifiers are removed after 90 days.

Upon expiry of applicable retention periods, personal data will be securely deleted or irreversibly anonymised in accordance with phiery's data disposal procedures.

11 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phiery. To exercise any of these rights, please contact phiery's Data Protection Officer using the contact details in Section 14.

phiery will respond to all data rights requests within thirty (30) calendar days of receipt. Where a request is complex or numerous, phiery may extend this period by a further thirty (30) days with prior notification to you. There is no fee for exercising your data rights, unless a request is manifestly unfounded or excessive.

12 Minors and Age-Restricted Platform

The phiery Platform is strictly restricted to individuals who are 21 years of age or older, as required by PAGCOR for licensed online gaming services in the Philippines. phiery does not knowingly collect personal data from individuals under 21 years of age.

All registrations are subject to age verification as part of phiery's KYC process. If phiery discovers that personal data has been collected from an individual below the age of 21, such data will be deleted immediately and the relevant account will be permanently closed. Any funds deposited by an underage player will be handled in accordance with applicable law and PAGCOR's guidelines on underage gambling.

If you are a parent or guardian and believe that your child below the age of 21 has registered an account on the phiery Platform, please contact phiery's Data Protection Officer immediately using the contact details in Section 14.

13 Changes to This Privacy Policy

phiery reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, phiery will provide Players with advance notice via the email address registered to their Account and/or through a prominent notice on the Platform prior to the changes taking effect.

The version of this Policy bearing the most recent "Last Updated" date shown at the top of this page is the operative version. Your continued use of the phiery Platform following the effective date of any revised Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you must close your Account and cease using the Platform.

14 Contact & Data Protection Officer

All data privacy queries, access requests, correction requests, erasure requests, objections, complaints, and other communications related to this Privacy Policy should be directed to phiery's Data Protection Officer:

• Role: Data Protection Officer, phiery
• Email: [email protected] (plain text — copy and paste to your email client; not a clickable link)
• Live Chat: Available 24/7 directly on the phiery Platform — accessible from any page once logged in.

phiery aims to acknowledge all privacy-related requests within 5 business days and to resolve them fully within 30 calendar days. For urgent matters relating to suspected unauthorised access to your Account, phiery recommends using the live chat function for the fastest possible response.

If you are not satisfied with phiery's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines.

This Privacy Policy was last reviewed and updated on 1 January 2026. This Policy governs the processing of personal data by phiery as data controller. phiery's processing of personal data as a data processor on behalf of third parties is governed by separate data processing agreements.