phspain Privacy Policy — How We Handle Your Data

1. Overview and Scope

This Privacy Policy applies to all personal data processed by phspain in connection with the platform accessible at phspain.app. It covers data collected when you visit the platform, create an account, make a deposit, place a wager, contact support or use any other phspain service.

phspain operates as a data controller in respect of the personal data you provide and the data generated through your use of the platform. As a Filipino player, the data protection principles reflected in this policy align with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules.

• This policy applies to all phspain account holders and registered players regardless of the device or connection used to access the platform.
• By creating a phspain account, you acknowledge that you have read and understood this policy and agree to the processing described in it.
• If you do not agree with any part of this policy, do not create an account or use phspain services.
• This policy should be read together with the phspain Terms and Conditions, which set out the broader contractual framework governing your use of the platform.

2. Personal Data We Collect

phspain collects personal data in several ways: directly from you when you register and use the platform, automatically through technical systems, and in some cases from third-party verification or payment providers. The categories of data collected are described below.

3. How phspain Uses Your Data

phspain uses personal data for specific, legitimate purposes connected to operating the platform for Filipino players. We do not use your data for unrelated commercial purposes, and we do not sell your personal information to third parties for their own marketing use.

• Account management: Creating and maintaining your phspain account, verifying your identity and managing your login credentials and account preferences.
• Processing transactions: Facilitating PHP deposits and withdrawals through supported payment methods including GCash, Maya, GrabPay, InstaPay, PESONet and bank transfers.
• Regulatory compliance and KYC: Meeting know-your-customer obligations, age verification requirements and anti-money laundering checks as required by applicable regulations.
• Responsible gaming: Monitoring gaming activity to identify patterns that may indicate problem gambling and making responsible gaming tools available to your account.
• Customer support: Responding to queries, resolving disputes and processing complaints submitted through phspain support channels.
• Platform security: Detecting and preventing fraud, unauthorised access, money laundering and other prohibited activity on the phspain platform.
• Service improvement: Analysing aggregated and anonymised usage data to understand how Filipino players use the platform and to guide improvements to the user experience.
• Legal obligations: Retaining records and cooperating with regulatory or law enforcement authorities where required by applicable Philippine law or applicable international obligations.

4. Legal Basis for Processing

phspain processes your personal data on one or more of the following legal bases, consistent with the Philippine Data Privacy Act of 2012 and related regulations:

• Contractual necessity: Processing required to fulfil the phspain Terms and Conditions — including account registration, transaction processing and service delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including age and identity verification, AML obligations and record-keeping requirements.
• Legitimate interests: Processing for purposes including fraud prevention, platform security and aggregated service analytics, where those interests are not overridden by your rights and interests.
• Consent: Where phspain relies on your consent for a specific processing activity — such as optional promotional communications — you may withdraw that consent at any time through your account settings or by contacting support.

5. Sharing Your Personal Data

phspain shares personal data only in circumstances that are necessary, proportionate and consistent with this Privacy Policy. phspain does not sell, rent or trade your personal data to third parties for their own commercial or marketing purposes.

• Payment processors: Data necessary to process PHP deposits and withdrawals is shared with the relevant payment service providers — such as GCash operators, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank and Visa/Mastercard — to the minimum extent required to complete the transaction.
• Identity verification providers: Personal data including government ID information may be shared with regulated third-party KYC verification services to fulfil age and identity verification obligations.
• Game content providers: Technical session data is shared with licensed game studios and live dealer operators to enable the game services available in the phspain lobby.
• Regulatory and law enforcement authorities: phspain may disclose personal data to competent Philippine authorities or relevant international bodies where required by law, court order or regulatory direction.
• Fraud prevention services: Data may be shared with specialist fraud detection services to protect the phspain platform and its players from financial crime.
• Business transfers: In the event of a merger, acquisition or sale of assets, personal data held by phspain may form part of the transferred assets, subject to confidentiality obligations and applicable data protection requirements.

6. How Long We Keep Your Data

phspain retains personal data for as long as necessary to fulfil the purposes described in this policy, to maintain the platform, to meet regulatory requirements and to resolve disputes or enforce our Terms and Conditions.

• Account data and gaming history are retained for the duration of your active phspain account and for a period after closure as required by applicable law and regulatory guidance.
• Financial transaction records are retained for the period required under applicable anti-money laundering regulations, which may be five years or longer from the date of each transaction.
• KYC verification documents are retained for the minimum period required by applicable regulatory requirements, which may extend beyond account closure.
• Communications data — including support correspondence — is retained for a period sufficient to resolve related queries and for a reasonable period thereafter.
• Technical and security logs are retained for a limited period consistent with their purpose, after which they are deleted or anonymised.

When data is no longer required for any of the above purposes, phspain will delete, anonymise or securely destroy it in accordance with applicable standards and procedures.

7. How We Protect Your Data

phspain implements technical and organisational security measures appropriate to the type of data processed and the risks involved. No system is entirely free of risk, but phspain takes its data security obligations seriously and reviews security practices on a continuing basis.

• Transmission of personal data between your device and phspain systems is protected using current encryption protocols.
• Access to personal data within phspain is limited to staff and systems that require it to perform their functions. Access rights are reviewed regularly.
• Payment card data is not stored in phspain's primary systems. Card transactions are directed through certified payment gateways operating their own security standards.
• phspain conducts periodic reviews of its security procedures and updates them in response to emerging risks.

8. Cookies and Tracking Technologies

phspain uses cookies and similar technologies on the platform. A cookie is a small file stored on your device that helps the platform remember your session and preferences. The types of cookies used by phspain fall into the following categories.

• Strictly necessary cookies: Required for the platform to function. These enable your login session, maintain your account state and support security features. They cannot be disabled without affecting platform functionality.
• Functional cookies: Store preferences you have set — such as language or display choices — so you do not have to reset them on each visit to phspain.
• Analytics cookies: Collect anonymised information about how Filipino players use the phspain platform. This data is used in aggregate form to improve the platform and does not identify individual users.
• Session security cookies: Support fraud detection and security monitoring during your active session on phspain.

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may prevent parts of the phspain platform from working correctly. Disabling analytics or functional cookies will not prevent access to core platform features.

9. Your Privacy Rights

As a registered phspain player based in the Philippines, you have rights under the Philippine Data Privacy Act of 2012 in relation to your personal data. phspain will respond to valid rights requests within a reasonable timeframe and in accordance with applicable requirements.

• Right to access: You may request a copy of the personal data phspain holds about you and information about how it is processed.
• Right to correction: If any personal data phspain holds is inaccurate or incomplete, you may request that it be corrected. You can update some information directly through your phspain account settings.
• Right to erasure: You may request the deletion of your personal data where it is no longer required for the purposes described in this policy, subject to phspain's legal and regulatory retention obligations.
• Right to object: You may object to the processing of your personal data where that processing is based on legitimate interests. phspain will consider your objection and respond accordingly.
• Right to data portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that your data be provided in a commonly used, machine-readable format.
• Right to withdraw consent: Where phspain processes your data based on your consent, you may withdraw that consent at any time without affecting processing that occurred before withdrawal.

To exercise any of the above rights, contact phspain through the verified support channel at support@phspain.app. phspain may request identity verification before processing a rights request to protect your account security.

10. Minors and Age Verification

phspain is strictly for adults aged 21 and above. The platform does not knowingly collect personal data from persons under 21 years of age. Age verification is conducted as part of the account registration and KYC process.

• If phspain discovers that an account was registered by a person under 21, the account will be closed immediately, all funds will be reviewed in accordance with applicable procedures, and personal data collected will be deleted except where retention is required for regulatory or security reasons.
• If you believe a minor has registered a phspain account, contact support at support@phspain.app immediately.

11. Cross-Border Data Transfers

Some of phspain's service providers and technical partners may be located in countries outside the Philippines. Where personal data is transferred to a third country, phspain takes steps to ensure that appropriate safeguards are in place consistent with the requirements of the Philippine Data Privacy Act.

• Cross-border transfers are limited to what is necessary for the specific service being provided, such as game platform hosting or fraud detection.
• phspain requires third-party recipients of personal data in other countries to maintain appropriate data protection standards as a condition of their engagement.
• Where applicable, phspain relies on contractual arrangements, adequacy determinations or other recognised safeguards to legitimise cross-border transfers of Filipino players' data.

12. Updates to This Privacy Policy

phspain reviews this Privacy Policy periodically and will update it when necessary to reflect changes in the platform, applicable law or our data processing practices.

• When material changes are made, phspain will notify registered players through their registered contact details — email address or mobile number — before the updated policy takes effect.
• The updated policy will be posted on the phspain platform with a revised effective date.
• Continued use of phspain after the effective date of an updated policy constitutes acceptance of the changes. If you do not agree with a proposed change, you should stop using phspain and request account closure before the update takes effect.
• It is your responsibility to keep your registered contact details current so that phspain can reach you with important policy communications.

13. Contact phspain About Privacy

If you have questions about this Privacy Policy, want to exercise your rights, have a concern about how phspain has handled your personal data, or need to report a potential data security incident, please use the following contact.

If you are not satisfied with phspain's response to a privacy concern, you have the right to raise the matter with the National Privacy Commission of the Philippines.