phdeeam Privacy Policy

This Privacy Policy ("Policy") is issued by phdeeam ("phdeeam", "we", "us", "our"), the operator of the online gaming platform accessible at phdeeam.net (the "Platform"). This Policy describes how phdeeam collects, uses, stores, shares, and protects the personal data of registered users, visitors, and other individuals ("you", "your") who interact with the Platform or our customer support channels.

phdeeam is committed to processing personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and all issuances of the National Privacy Commission ("NPC"). This Policy forms an integral part of the phdeeam Terms & Conditions, which are accessible at phdeeam.net/terms-conditions.

By registering for a phdeeam account or continuing to use the Platform, you acknowledge that you have read, understood, and consented to the collection and processing of your personal data as described in this Policy. If you do not agree with any part of this Policy, you should discontinue use of the Platform and contact phdeeam support to request account closure.

For the purposes of the Data Privacy Act of 2012, phdeeam acts as the personal information controller ("PIC") in respect of the personal data collected through the Platform. As PIC, phdeeam determines the purposes and means of processing your personal information and bears primary responsibility for ensuring that such processing is carried out lawfully, fairly, and transparently.

phdeeam has appointed a Data Protection Officer ("DPO") who is responsible for overseeing the Platform's data protection compliance program, handling data subject rights requests, and serving as the primary point of contact with the National Privacy Commission. Contact details for the DPO are provided in Section 14 of this Policy.

phdeeam collects the following categories of personal data, depending on how you interact with the Platform:

phdeeam does not intentionally collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) unless it is voluntarily disclosed by you in the course of a support interaction, in which case it will be handled with the heightened protections applicable to sensitive data under the DPA.

phdeeam collects personal data through the following means:

• Direct collection: Data you provide when registering a phdeeam account, completing identity verification, making deposits or withdrawal requests, setting responsible gaming limits, or contacting our support team.
• Automated collection: Technical and usage data collected automatically via cookies, session tokens, server logs, and analytics tools as you browse and use the Platform. See Section 8 for details on cookies.
• Third-party sources: Identity verification data received from licensed KYC service providers; payment confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency network partners; fraud and AML screening results from compliance data providers.

phdeeam processes your personal data for the following purposes. We process only the minimum data necessary for each stated purpose:

• To create, verify, and maintain your phdeeam account and ensure that only eligible users (21 years of age or older) access the Platform.
• To process deposits and withdrawals via GCash, PayMaya, bank transfer, USDT, and other supported payment methods, and to maintain accurate transaction records.
• To verify your identity and conduct due diligence required under applicable anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
• To detect, investigate, and prevent fraud, account abuse, bonus exploitation, and other prohibited conduct as described in the phdeeam Terms & Conditions.
• To operate and improve the phdeeam Platform, including game performance monitoring, platform analytics, and feature development.
• To provide customer support and respond to your queries, complaints, and responsible gaming requests.
• To send you service-related communications, including transaction confirmations, account security alerts, and material policy updates.
• To send you promotional communications and personalized offers where you have consented to receive such communications (you may withdraw this consent at any time).
• To comply with phdeeam's legal obligations under Philippine law, including record-keeping requirements, regulatory reporting, and responding to lawful requests from government authorities.

Under the Data Privacy Act of 2012, phdeeam relies on the following lawful bases for processing your personal data:

• Contractual necessity: Processing required to fulfill our obligations to you under the phdeeam Terms & Conditions, including account management, game delivery, and payment processing.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — particularly for marketing communications and optional data uses. You may withdraw consent at any time by contacting support.
• Legal obligation: Processing necessary to comply with applicable Philippine laws, including anti-money laundering regulations, tax reporting requirements, and regulatory directions from PAGCOR and the NPC.
• Legitimate interests: Processing necessary for phdeeam's legitimate business interests — including fraud prevention, platform security, and service improvement — provided those interests are not overridden by your rights and interests.

phdeeam does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, solely to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency payment gateway providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Licensed KYC and AML compliance service providers who assist phdeeam in verifying user identities and screening for sanctions and politically exposed persons.
• Technology and hosting partners: Cloud infrastructure providers and technology vendors who host and support the phdeeam Platform under strict data processing agreements that prohibit independent use of your data.
• Game providers: Licensed third-party game studios that supply games accessible through the phdeeam Platform. These providers may receive limited technical session data necessary to deliver game functionality.
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies in the Philippines where phdeeam is required by law or court order to disclose personal data.
• Professional advisers: Legal counsel, auditors, and accountants bound by professional confidentiality obligations, where necessary for phdeeam's legal and compliance functions.

phdeeam uses cookies and similar tracking technologies on the Platform to ensure core functionality, improve performance, and deliver a personalized experience. A cookie is a small text file stored on your device when you visit the Platform.

phdeeam uses the following categories of cookies:

• Strictly necessary cookies: Essential for Platform operation, including authentication session management, security tokens, and load balancing. These cannot be disabled without impairing Platform functionality.
• Performance cookies: Collect anonymized data about how users interact with the Platform (pages visited, error rates, session duration) to help phdeeam improve performance and fix issues.
• Functional cookies: Remember your preferences (language settings, responsible gaming settings, last visited game categories) to provide a more personalized experience.
• Analytics cookies: Used by phdeeam's internal analytics tools to understand aggregate usage patterns. phdeeam does not use third-party advertising or behavioral tracking cookies.

You may manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality and performance of the phdeeam Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to function securely.

phdeeam retains personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years after account closure, in accordance with AML record-keeping obligations under Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, consistent with financial record-keeping requirements under Philippine law.
• Customer support communications: Retained for three (3) years from the date of the last interaction, or longer where the communication relates to an unresolved dispute or legal proceeding.
• Technical and usage data: Retained in identifiable form for up to twelve (12) months, after which it is aggregated or anonymized for analytics purposes.
• Marketing consent records: Retained for the duration of the account relationship plus two (2) years as evidence of consent.

Upon expiry of the applicable retention period, phdeeam will securely delete or anonymize your personal data in accordance with our data destruction procedures, unless retention is required to establish, exercise, or defend a legal claim.

phdeeam implements comprehensive technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security program includes, but is not limited to:

• TLS 1.3 encryption for all data transmitted between your device and the phdeeam Platform.
• AES-256 encryption for sensitive data stored in phdeeam databases, including financial and identity data.
• Strict role-based access controls ensuring that phdeeam personnel access only the personal data necessary for their specific job functions.
• Multi-factor authentication requirements for all phdeeam staff accessing systems that process personal data.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Continuous monitoring for suspicious access patterns and automated alerts for potential security incidents.
• A documented data breach response procedure including NPC notification protocols consistent with Section 20(f) of the DPA.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phdeeam. These rights may be exercised by contacting our Data Protection Officer using the details in Section 14.

phdeeam will respond to all verified data subject rights requests within thirty (30) calendar days of receipt. Where a request requires additional time to process, phdeeam will notify you of the extension and provide a revised timeline. phdeeam will not charge a fee for processing rights requests unless they are manifestly unfounded or excessive.

The phdeeam Platform is strictly intended for adults aged 21 years and above. phdeeam does not knowingly collect personal data from individuals under 21 years of age. If phdeeam becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the phdeeam Platform or provided personal data to phdeeam, please contact our Data Protection Officer immediately using the contact details in Section 14. We will investigate and remediate the situation promptly.

phdeeam reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. When material changes are made, phdeeam will notify registered users via the Platform and by email to the registered email address on file, at least fourteen (14) days before the changes take effect.

Minor or non-material changes (such as typographical corrections or clarifications that do not affect your rights) may be made without prior notice. The "Last updated" date at the top of this Policy will be revised whenever any change is made. Your continued use of the phdeeam Platform following the effective date of a revised Policy constitutes your acceptance of the updated terms.

We encourage you to review this Policy periodically. Previous versions of this Policy are available on request from the Data Protection Officer.

For questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phdeeam, please contact our Data Protection Officer through the channels listed below. All contact details are provided as plain text only and are not clickable links.

• Email (DPO): [email protected]
• Live Chat: Available 24/7 directly on the phdeeam Platform — select "Privacy & Data" from the support topic menu
• Response time: All privacy-related requests are acknowledged within 72 hours and resolved within 30 calendar days

If you are not satisfied with phdeeam's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available through official Philippine government channels.