1. Who Is the Data Controller?
The data controller responsible for your personal information collected through phhsky.net is phhsky, operating under a licence issued by the Philippine Amusement and Gaming Corporation (PAGCOR). Our designated Data Protection Officer (DPO) can be reached at privacy@phhsky.net.
As data controller, phhsky determines the purposes and means of processing your personal data. We are accountable to the National Privacy Commission (NPC) and to you, our players, for how that data is handled.
2. What Personal Data We Collect
phhsky collects personal data through three main channels: information you provide directly, information generated by your activity on our platform, and information we receive from third-party payment and verification providers.
2.1 Information You Provide Directly
- Full name, date of birth, gender
- Email address and mobile number
- Registered home address in the Philippines
- Government-issued ID details (for KYC verification: National ID, passport, driver's licence, SSS/GSIS card)
- Username and encrypted password
- Payment method details (GCash number, Maya account, bank account details for withdrawals)
- Selfie or photo for facial verification (where required)
2.2 Automatically Collected Data
- IP address and approximate geolocation (to confirm you are in the Philippines)
- Device type, operating system, browser version
- Session timestamps, pages visited, game play history
- Deposit and withdrawal transaction records
- Betting patterns and game preferences (used for responsible gaming monitoring)
2.3 Data from Third-Party Providers
- Identity verification results from PAGCOR-accredited KYC providers
- Transaction status and risk signals from payment processors (GCash, Maya, banks)
- Fraud risk scores from AML screening services, as required under the Anti-Money Laundering Act
We do not collect sensitive personal information such as racial origin, political opinions, religious beliefs, or health data unless specifically required by law or directly relevant to responsible gaming obligations.
3. How phhsky Uses Your Personal Data
Every piece of data we collect has a specific, documented purpose. Here is a clear breakdown:
| Purpose |
Data Used |
Legal Basis |
| Account registration and management |
Name, email, mobile, address, username |
Contractual necessity |
| Identity verification (KYC) |
Government ID, selfie, date of birth |
Legal obligation (PAGCOR, AMLA) |
| Processing deposits and withdrawals |
Payment method details, transaction history |
Contractual necessity |
| Fraud prevention and AML compliance |
IP address, device data, transaction patterns |
Legal obligation |
| Responsible gaming monitoring |
Betting patterns, session data |
Legitimate interest / legal obligation |
| Customer support |
All account-related data |
Contractual necessity |
| Promotional communications (opt-in only) |
Email, mobile number, game preferences |
Consent |
| Platform improvement and analytics |
Aggregated, anonymised usage data |
Legitimate interest |
phhsky does not use automated decision-making that produces solely automated legal or similarly significant effects on you. All account closure or restriction decisions involve a human review stage.
4. Who We Share Your Data With
phhsky does not sell your personal data. We share information only where strictly necessary, and only with parties who are contractually bound to protect it:
- Payment processors: GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet partners, BDO/BPI/UnionBank, Visa/Mastercard networks — to process your transactions.
- KYC/AML providers: PAGCOR-accredited identity verification and fraud screening services.
- Game software providers: Third-party studios like JILI Games receive anonymised session tokens necessary for game delivery — they do not receive your full identity data.
- Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC) where legally required.
- IT infrastructure providers: Cloud hosting and CDN providers who process data solely under our instruction and are bound by data processing agreements.
Any third party that receives your personal data from phhsky is required to handle it with the same level of protection required under Philippine law.
5. Cookies and Tracking Technologies
phhsky uses cookies and similar technologies to make our platform work properly and to understand how players use the site. Here's what we use and why:
Essential Cookies
These are required for the platform to function. They keep you logged in, maintain your session, and enable security features. You cannot opt out of these without disabling your use of phhsky entirely.
Analytics Cookies
We use privacy-respecting analytics tools to understand how players navigate phhsky — which pages are most visited, where players encounter issues, and how the registration flow performs. This data is aggregated and anonymised; it does not identify you personally.
Functional Cookies
These remember your preferences — such as your preferred language, last played game, and display settings — so you have a smoother experience each time you visit.
Marketing Cookies (Opt-in Only)
phhsky does not use third-party advertising cookies. Any first-party cookies used for promotional targeting (e.g., showing you a relevant promo banner) are based on your explicit consent and can be managed in your account settings.
You can manage cookie preferences through your browser settings at any time. Note that disabling essential cookies will affect your ability to use phhsky. For details on opting out of analytics, contact privacy@phhsky.net.
6. How Long We Keep Your Data
phhsky does not keep your personal data longer than necessary. Retention periods are determined by the purpose of collection and applicable legal obligations:
- Active account data: Retained for the duration of your account and for 5 years after account closure, as required under the Anti-Money Laundering Act (AMLA).
- Transaction records: Kept for 10 years in compliance with PAGCOR and AMLC record-keeping obligations.
- KYC documents: Retained for 5 years after account closure or last transaction, whichever is later.
- Support communications: Kept for 3 years after the issue is resolved.
- Marketing preferences and consent records: Retained until you withdraw consent, plus 1 year for audit purposes.
- Anonymised analytics data: May be retained indefinitely as it cannot be used to identify you.
When data is no longer needed and no legal obligation requires its retention, phhsky will securely delete or anonymise it.
7. How We Keep Your Data Secure
Data security at phhsky is not an afterthought — it is built into every part of our platform. Here are the protections we have in place:
- Encryption at rest: All stored personal and financial data is encrypted using AES-256.
- Encryption in transit: All data exchanged between your device and phhsky's servers uses TLS 1.3.
- Access controls: Only authorised phhsky staff with a legitimate need can access your personal data. Access is logged and regularly audited.
- Two-factor authentication: Available for all player accounts and mandatory for staff accessing backend systems.
- Regular security audits: We conduct periodic penetration testing and vulnerability assessments on our infrastructure.
- Incident response plan: In the event of a data breach, phhsky will notify affected players and the NPC within 72 hours, as required under the DPA.
8. Your Data Rights as a Philippine Player
Under the Data Privacy Act of 2012, you have the following rights regarding your personal data held by phhsky. These are not just formalities — they are enforceable rights that we are obligated to honour.
Right to Be Informed
Know what data we collect and how we use it — which is exactly what this Privacy Policy covers.
Right to Access
Request a copy of all personal data we hold about you. We will respond within 15 business days.
Right to Correction
If any data we hold about you is inaccurate or incomplete, you can request a correction at any time.
Right to Erasure
Request deletion of your data when it is no longer needed, subject to legal retention requirements.
Right to Object
Object to processing based on legitimate interest, including direct marketing at any time.
Right to Portability
Receive your data in a structured, machine-readable format for transfer to another controller.
To exercise any of these rights, email our Data Protection Officer at privacy@phhsky.net with the subject line "Data Rights Request" and your registered account email. We will acknowledge your request within 5 business days and resolve it within 15 business days. If you are unsatisfied with our response, you may file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.
9. Protection of Minors
phhsky strictly prohibits the use of our platform by anyone under the age of 21. We do not knowingly collect personal data from individuals below this age. As part of our KYC verification process, we verify the age of all registrants using government-issued identification.
If we discover that a person under 21 has registered an account, we will immediately suspend the account, forfeit any associated balance, and delete all personal data collected from that individual. If you believe a minor has registered on phhsky, please report it immediately to privacy@phhsky.net.
10. Changes to This Privacy Policy
phhsky may update this Privacy Policy periodically to reflect changes in our data practices, new regulatory requirements, or improvements to our platform. When we make material changes, we will:
- Update the "Last Updated" date at the top of this page.
- Send an email notification to your registered phhsky email address at least 7 days before significant changes take effect.
- Display a notice on your account dashboard if the changes affect how we process your existing data.
Your continued use of phhsky after the effective date of any update constitutes your acceptance of the revised Privacy Policy. We recommend bookmarking this page and reviewing it occasionally.
