Privacy Policy — How phlov3 Protects Your Personal Data

1 Definitions

The following terms have the meanings set out below throughout this Privacy Policy:

• "Personal Data" means any information that identifies or could reasonably identify an individual, including but not limited to name, mobile number, email address, date of birth, government ID details, device identifiers, and financial information.
• "Processing" means any operation performed on Personal Data, including collection, recording, organisation, storage, updating, retrieval, use, disclosure, transfer, or destruction.
• "Data Controller" means phlov3, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on phlov3's behalf, under phlov3's instructions and a binding data processing agreement.
• "Data Subject" means the natural person whose Personal Data is processed — in this context, you as a phlov3 Player or website visitor.
• "KYC Data" means the identity documents and verification information submitted during the Know Your Customer process, including government-issued ID images and selfie verification.
• "NPC" means the National Privacy Commission of the Philippines, the regulatory body overseeing compliance with the Data Privacy Act of 2012.
• "DPO" means phlov3's designated Data Protection Officer, responsible for overseeing compliance with this Policy and Philippine data privacy law.

2 Data Controller Identity

phlov3 is the Data Controller for all Personal Data collected through phlov3.club and related services. phlov3 is registered with and regulated by PAGCOR for online casino and gaming operations in the Philippines.

phlov3 has appointed a Data Protection Officer (DPO) in compliance with the Data Privacy Act of 2012. The DPO is responsible for overseeing phlov3's data protection compliance, handling data subject requests, managing data breach response, and serving as the primary contact point with the National Privacy Commission.

phlov3's Data Protection Officer may be contacted at [email protected] with the subject line "Data Privacy — DPO Inquiry". Formal written correspondence regarding data privacy matters should be directed to the same address, clearly marked as "Data Privacy Notice".

3 Personal Data We Collect

phlov3 collects Personal Data through multiple channels: directly from you during registration and account use, automatically through your device and browser interactions with phlov3.club, and from third parties such as payment processors and KYC verification services.

phlov3 does not collect sensitive personal data beyond what is required for identity verification (government IDs). phlov3 does not collect biometric data beyond selfie images used solely for KYC liveness checks. No payment card numbers or full bank credentials are stored on phlov3 infrastructure.

4 Legal Basis for Processing

phlov3 processes your Personal Data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform the phlov3 Terms & Conditions you have accepted, including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, Philippine Anti-Money Laundering Act obligations (RA 9160 as amended), the Data Privacy Act of 2012, and other applicable Philippine laws.
• Legitimate Interests: Processing necessary for phlov3's legitimate business interests, including fraud prevention, security monitoring, responsible gaming compliance, and service improvement — where those interests do not override your fundamental rights.
• Consent: Where phlov3 seeks your consent for specific processing activities — such as optional marketing communications — such consent will be sought separately, clearly, and may be withdrawn at any time without affecting your account status.

5 How phlov3 Uses Your Personal Data

5.1 Account and Service Delivery

Your registration and KYC data are used to create and manage your phlov3 Account, verify your identity and age (21+ requirement), enable deposit and withdrawal functionality in Philippine Pesos, and provide access to all phlov3 games and services.

5.2 Regulatory Compliance

phlov3 is legally required by PAGCOR and Philippine law to collect and retain certain Personal Data. This includes KYC verification for all real-money accounts, transaction monitoring for AML purposes, reporting obligations to PAGCOR and the AMLC, and age verification to prevent access by persons under 21 years of age.

5.3 Fraud Prevention and Security

phlov3 uses device and behaviour data to detect fraudulent account activity, multi-accounting, bonus abuse, and suspicious transactions. This processing is necessary to protect the integrity of phlov3's services and the interests of all legitimate players.

5.4 Responsible Gaming

Gameplay and account activity data is used to support phlov3's responsible gaming obligations under PAGCOR regulations, including identifying patterns that may indicate problem gambling and enabling phlov3 to proactively offer responsible gaming tools or impose protective limits as required.

5.5 Service Improvement

Anonymised and aggregated gameplay and usage data is used to improve phlov3's game library, platform performance, and user experience. This processing uses de-identified data wherever possible and does not involve direct marketing profiling.

5.6 Communications

phlov3 uses your registered email and mobile number to send account notifications, security alerts, transaction confirmations, and — with your separate consent — promotional communications about phlov3 offers. You may opt out of promotional communications at any time without affecting your account access.

6 Cookies & Similar Technologies

phlov3.club uses cookies and similar tracking technologies to operate the Platform, maintain login sessions, and collect analytics data. The following categories of cookies are used:

• Essential / Strictly Necessary Cookies: Required for phlov3.club to function. These enable login session persistence, security token validation, and core platform functionality. These cannot be disabled without breaking core features.
• Functional Cookies: Remember your preferences such as language settings, last-visited game categories, and responsible gaming settings.
• Analytics Cookies: Collect anonymised data about how Players use phlov3.club to help phlov3 improve navigation, performance, and game discovery. No personally identifiable data is shared with analytics providers.
• Security Cookies: Used by phlov3's fraud prevention and login anomaly detection systems. These are strictly necessary for platform security.

phlov3 does not use third-party advertising cookies or allow third-party ad networks to place cookies on phlov3.club. You may manage cookie preferences through your browser settings. Disabling essential cookies will impair or prevent access to phlov3 services.

7 Data Sharing & Third-Party Disclosure

phlov3 does not share your Personal Data with third parties except in the following circumstances:

• PAGCOR and Regulatory Authorities: phlov3 is required to share player data with PAGCOR upon request as part of its licensing obligations. This may include account details, transaction history, and KYC documentation.
• Anti-Money Laundering Council (AMLC): phlov3 is required under the Philippine Anti-Money Laundering Act to report suspicious transactions and share relevant player data with the AMLC where legally mandated.
• Payment Processors: Transaction data is shared with GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners solely to process deposits and withdrawals. These providers act as Data Processors under binding agreements and may not use your data for their own commercial purposes in relation to your phlov3 transactions.
• KYC Verification Services: Identity document data may be shared with authorised KYC verification service providers who process this data solely for the purpose of identity verification on behalf of phlov3.
• Game Providers: Limited gameplay data (session identifiers, bet values) may be shared with game providers such as JILI, PG Soft, and Evolution Gaming solely for the purpose of game delivery, dispute resolution, and RNG integrity verification.
• Legal Authorities: phlov3 will disclose Personal Data to courts, law enforcement, or other competent authorities upon receipt of a valid legal order, warrant, or lawful request under Philippine law.
• IT and Hosting Providers: phlov3's infrastructure and cloud hosting partners may have access to encrypted personal data as part of platform operations. All such providers are bound by data processing agreements.

8 Data Security Measures

phlov3 implements technical, organisational, and administrative security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, or disclosure. Key measures include:

• Transit Encryption: All data transmitted between your device and phlov3.club is encrypted using TLS 1.2 or higher (256-bit SSL).
• Data-at-Rest Encryption: Personal Data and KYC documents stored on phlov3 systems are encrypted using AES-256 encryption.
• Access Controls: Access to Personal Data within phlov3 is restricted on a strict need-to-know basis. Staff with access to Personal Data undergo mandatory data privacy training.
• Password Security: Player passwords are stored using industry-standard one-way cryptographic hashing (bcrypt). phlov3 does not store plaintext passwords.
• Two-Factor Authentication: phlov3 offers 2FA to all players and recommends its activation to reduce unauthorised account access risk.
• Penetration Testing: phlov3 conducts periodic security assessments and vulnerability testing of its platform and data infrastructure.
• Data Breach Response: phlov3 maintains a documented data breach response procedure. In the event of a personal data breach affecting your rights, phlov3 will notify the NPC within 72 hours and affected Players without undue delay, as required by the Data Privacy Act of 2012.

While phlov3 implements robust security measures, no internet-based platform can guarantee absolute security. Players should also take reasonable steps to protect their own Account credentials, including enabling 2FA and using a unique, strong password for phlov3.

9 Data Retention

phlov3 retains Personal Data for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, and resolve disputes. Specific retention periods are as follows:

• Account and Registration Data: Retained for the duration of your Account plus a minimum of five (5) years following Account closure, as required by PAGCOR and Philippine AML regulations.
• KYC / Identity Documents: Retained for the full statutory retention period required under Philippine AML law — currently a minimum of five (5) years from the date of the relevant transaction or Account closure, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years following each transaction, as required by PAGCOR and the Anti-Money Laundering Act.
• Support Communications: Retained for three (3) years following resolution of the relevant inquiry or dispute.
• Analytics Data: Anonymised and aggregated analytics data may be retained indefinitely as it does not constitute Personal Data.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years following withdrawal, to demonstrate compliance.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Players may request early deletion of non-regulatory data through the process described in Section 10.

10 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your Personal Data held by phlov3:

• Right to be Informed: You have the right to be informed about how phlov3 collects, uses, and shares your Personal Data, which this Policy fulfils.
• Right of Access: You have the right to request a copy of the Personal Data phlov3 holds about you, together with information about how it is used.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete Personal Data. You may update most registration information directly from your phlov3 Account settings.
• Right to Erasure: You have 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 retention obligations under PAGCOR and Philippine AML regulations, which phlov3 cannot override.
• Right to Object: You have the right to object to processing of your Personal Data for direct marketing purposes at any time. You may also object to other processing activities based on legitimate interests, subject to phlov3's overriding legitimate grounds.
• Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, machine-readable format where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phlov3 has processed your Personal Data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, contact phlov3's Data Protection Officer at [email protected] with the subject line "Data Privacy — Rights Request". phlov3 will respond within thirty (30) calendar days of receiving a verified request. Identity verification will be required before processing rights requests to protect against unauthorised disclosures.

11 Minors & Age Verification

phlov3 services are strictly intended for individuals aged 21 years or older, in compliance with PAGCOR regulations. phlov3 does not knowingly collect Personal Data from individuals under 21 years of age. Age verification is conducted during registration and KYC as a mandatory process.

If phlov3 discovers that Personal Data has been collected from an individual who is under 21 years of age, phlov3 will:

• Immediately suspend the Account pending review;
• Notify PAGCOR as required by phlov3's licensing obligations;
• Delete or anonymise the relevant Personal Data to the extent permitted by applicable law;
• Refund any deposited funds to the original payment source following a compliance review.

If you have reason to believe that an individual under 21 years of age has registered on phlov3, please contact phlov3 support or the DPO immediately at [email protected]. phlov3 will investigate and act promptly.

12 Changes to This Privacy Policy

phlov3 reviews and updates this Privacy Policy periodically to reflect changes in our data practices, platform features, regulatory requirements, or applicable law. Material changes to this Policy will be communicated to registered Players via email to their registered address and/or a prominent notice on phlov3.club at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of phlov3 services following the effective date of an updated Policy constitutes your acknowledgement of and agreement to the revised terms. Players who do not accept revised Policy terms should contact phlov3 to discuss account closure options before the effective date.

All previous versions of this Privacy Policy are retained by phlov3 and are available upon written request to the DPO.

13 Contact Information & Data Protection Officer

For all Privacy Policy queries, data subject rights requests, data breach notifications, or concerns about phlov3's data practices, please contact:

• Data Protection Officer (DPO): phlov3 Data Privacy Office
• Email: [email protected] — Subject line: "Data Privacy — [Your Request Type]"
• Live Chat: Available 24/7 on phlov3.club — for general privacy queries and account data requests
• Response Time: Up to 30 calendar days for formal written requests; under 3 minutes via live chat for general inquiries