phrus Privacy Policy

01 Introduction

This Privacy Policy ("Policy") is issued by phrus ("phrus," "we," "us," or "our"), the operator of the online gaming platform accessible at phrus.cam. This Policy describes the manner in which phrus collects, uses, stores, discloses, and protects personal data provided by or collected from registered players, visitors, and any other individuals who interact with the phrus platform or its support channels.

phrus operates in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. Additionally, phrus adheres to data processing obligations applicable under PAGCOR's online gaming regulatory framework.

By creating an account on phrus, making a deposit, placing a wager, using live chat support, or otherwise interacting with the phrus platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not use the phrus platform.

02 Personal Data We Collect

phrus collects the following categories of personal data from players and platform users:

2.1 Identity Data

Full legal name, date of birth, nationality, gender, and copies of government-issued identification documents (e.g., PhilSys National ID, UMID, SSS card, passport, driver's license) submitted during KYC verification.

2.2 Contact Data

Email address, mobile phone number, and residential or mailing address in the Philippines (including city, province, and postal code).

2.3 Account Data

Username, hashed password credentials, account registration date, account status, login history, session timestamps, and two-factor authentication configuration.

2.4 Financial & Transaction Data

Deposit and withdrawal transaction records, payment method identifiers (e.g., GCash account number, PayMaya number, BPI/BDO/Metrobank account reference), transaction amounts in Philippine Peso (PHP / ₱), transaction timestamps, and balance history.

2.5 Gaming Activity Data

Game session records, bet history across all product verticals (live casino, sports betting, slots, bingo), wager amounts, game outcomes, bonus utilization records, and responsible gaming tool settings.

2.6 Technical & Device Data

IP address, device type and model, operating system, browser type and version, screen resolution, and geolocation data (at country and city level, where available).

2.7 Communications Data

Records of correspondence with phrus support staff via live chat, email, or any other communication channel, including the content of support queries and their resolution.

03 How We Collect Your Data

phrus collects personal data through the following means:

• Direct submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting support, or filling in any phrus platform form.
• Automated collection: Technical and device data collected automatically when you access the phrus platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from licensed KYC service providers; fraud and AML screening data from compliance service partners; payment data transmitted by Philippine payment processors (GCash, Maya, BPI, BDO, Metrobank) in connection with your transactions.
• Gaming activity: Data generated automatically by the phrus gaming engine as a result of your in-platform activity, including every bet placed, game session opened, and bonus activated.

04 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, phrus processes your personal data on the following lawful bases:

• Contract performance: Processing necessary to provide you with the phrus gaming platform, process transactions, manage your account, and deliver all services described in the Terms & Conditions.
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), and NPC data handling obligations.
• Legitimate interest: Processing for fraud detection, account security, platform improvement, and responsible gaming enforcement, where such processing does not override your privacy rights.
• Consent: Processing for optional communications such as promotional emails or SMS notifications, where you have given specific and informed consent. You may withdraw consent for marketing communications at any time through your account settings.

05 How We Use Your Personal Data

phrus uses collected personal data strictly for the following purposes:

• Creating and managing your phrus player account.
• Verifying your identity and age (21+ requirement) in accordance with PAGCOR guidelines.
• Processing deposits, withdrawals, and all financial transactions through Philippine payment channels.
• Detecting, investigating, and preventing fraud, money laundering, and unauthorized account access.
• Delivering live casino, sports betting, slot, and bingo gaming services to your device.
• Administering bonuses, promotions, and loyalty rewards to eligible accounts.
• Enforcing phrus's Responsible Gaming policies, including monitoring for problem gambling indicators and applying deposit limits or self-exclusion settings at your request or when required by policy.
• Providing customer support and resolving disputes through live chat and email.
• Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) that are necessary to your account.
• Sending promotional communications where you have provided consent – you may opt out at any time.
• Complying with applicable Philippine regulatory reporting obligations, including AMLC suspicious transaction reporting.
• Improving, testing, and optimizing the phrus platform based on aggregated, anonymized usage data.

06 Data Sharing & Third-Party Disclosure

phrus may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to binding data processing agreements:

6.1 Service Providers

Licensed third-party providers engaged to deliver components of the phrus service, including identity verification (KYC) providers, payment processors (GCash/Maya/BPI/BDO/Metrobank), cloud hosting infrastructure providers, live casino game streaming partners, RNG-certified slot game providers, fraud prevention technology vendors, and customer support software platforms. All such providers are required to process your data only as instructed by phrus and in accordance with applicable Philippine data privacy law.

6.2 Regulatory Authorities

phrus is legally required to disclose personal and financial data to relevant Philippine regulatory bodies including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent government agencies when required by applicable law, court order, or lawful regulatory directive.

6.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of phrus's assets, personal data held by phrus may be transferred to the successor entity, subject to the same privacy protections as described in this Policy. Affected players will be notified via email prior to any such transfer.

6.4 Protection of Rights

phrus may disclose personal data where it reasonably believes disclosure is necessary to protect the rights, property, or safety of phrus, its players, or the public; to enforce the Terms & Conditions; or to respond to valid legal process.

07 Data Retention

phrus retains your personal data for as long as necessary to fulfill the purposes for which it was collected, and in accordance with applicable Philippine legal and regulatory requirements. Specific retention periods include:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under RA 9160.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity data: Retained for ninety (90) days in active form for player reference; archived for a minimum of three (3) years for regulatory audit purposes.
• Support communications: Retained for two (2) years from the date of the last communication in a support thread, or longer where required for ongoing dispute resolution.
• Cookie and technical data: Retained per the cookie retention periods described in Section 9 of this Policy.

Once the applicable retention period has expired, phrus will securely delete or anonymize your personal data such that it can no longer be linked to you as an identifiable individual.

08 Security Measures

phrus implements a comprehensive set of technical, organizational, and administrative security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and the phrus platform is protected by 256-bit Transport Layer Security (TLS/SSL) encryption. Sensitive data at rest, including payment credentials and ID document images, is encrypted using AES-256.
• Access controls: Strict role-based access controls ensure that phrus staff can only access personal data that is necessary for their specific job function. All internal data access is logged and audited.
• Two-factor authentication: phrus provides two-factor authentication (2FA) for all player accounts and mandates it for internal staff systems.
• Fraud monitoring: Automated real-time monitoring systems flag unusual account activity, suspicious login attempts, and anomalous transaction patterns for immediate review.
• Regular security audits: The phrus platform undergoes regular penetration testing and security audits conducted by qualified third-party cybersecurity firms.
• Staff training: All phrus staff who handle personal data receive regular data privacy and security training in accordance with NPC guidelines.

09 Cookies & Tracking Technologies

phrus uses cookies and similar tracking technologies to operate and improve the platform experience for Filipino players. A cookie is a small text file stored by your browser on your device when you visit phrus.cam. Cookies are not used to collect personal data beyond what is necessary for platform functionality and security.

9.1 Types of Cookies Used

• Strictly necessary cookies: Required for the phrus platform to function, including session management (keeping you logged in), security token validation, and load balancing. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, last-used payment method, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymized, aggregated data about how players navigate the platform, which pages are most visited, and where errors occur. Used solely to improve platform performance.
• Security cookies: Used to detect and prevent fraudulent activity, such as identifying unusual login patterns or device fingerprinting for multi-accounting detection.

9.2 Cookie Management

You may control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Note that disabling strictly necessary cookies will impair your ability to use core phrus platform features, including logging in and processing transactions. phrus does not use third-party advertising cookies or share cookie data with external marketing platforms.

10 Your Privacy Rights Under Philippine Law

As a data subject under the Philippine Data Privacy Act of 2012, you are entitled to the following rights with respect to your personal data held by phrus. To exercise any of these rights, contact the phrus Data Protection Officer at [email protected].

phrus will respond to all verified data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice provided to the requesting party. Requests must be submitted in writing and accompanied by sufficient information to verify the identity of the requester.

11 Minors & Age Verification

The phrus platform is strictly intended for individuals who are 21 years of age or older, consistent with PAGCOR's mandatory age requirements for online gaming in the Philippines. phrus does not knowingly collect personal data from individuals below the age of 21.

Age verification is conducted as part of the account registration and KYC process. Where phrus has reasonable grounds to believe that personal data has been submitted by or on behalf of a minor, the relevant account will be immediately suspended, all associated personal data will be reviewed, and any data found to belong to a minor will be promptly deleted unless retention is required for regulatory reporting purposes.

12 Cross-Border Data Transfers

The phrus platform may utilize cloud infrastructure, game servers, or third-party service providers that are located outside of the Philippines. In such cases, phrus ensures that any cross-border transfer of personal data is conducted in compliance with Section 21 of the Data Privacy Act of 2012 and the NPC's rules on cross-border data flows. Specifically, phrus ensures that:

• The receiving country provides an adequate level of data protection as recognized by the NPC, or
• Appropriate contractual safeguards – including standard contractual clauses – are in place with the receiving entity to ensure your data is protected to the same standard as required by Philippine law, or
• The transfer is necessary for the performance of your contract with phrus (e.g., enabling live casino game delivery via an internationally hosted game server).

In all cases, cross-border transfers are subject to the same access controls, encryption standards, and retention limitations described elsewhere in this Policy.

13 Changes to This Privacy Policy

phrus reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidance, PAGCOR regulatory requirements, or phrus's own data practices. The effective date at the top of this Policy will be updated to reflect the date of any revision.

Where a material change is made to this Policy – meaning a change that materially affects your privacy rights or the way phrus uses your data – phrus will notify registered players via the email address on file and/or through an in-platform notification at least fourteen (14) days prior to the effective date of the change.

Your continued use of the phrus platform following the effective date of a revised Privacy Policy constitutes your acknowledgment of and agreement to the updated terms. If you object to any changes, you may contact phrus to discuss your options or request account closure.

14 Contact & Data Protection Officer

phrus has designated a Data Protection Officer (DPO) in compliance with Section 21 of the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy, the processing of your personal data, or the exercise of your data subject rights, please contact the phrus DPO through the following channels:

• Email: [email protected] — plaintext, not a clickable link
• Subject line: Include "Privacy Request" or "Data Subject Right" in your subject line for expedited routing to the DPO.
• Live Chat: Available 24/7 to logged-in phrus players via the platform dashboard. For formal privacy requests, written correspondence via email is recommended to ensure a proper audit trail.
• Response time: phrus aims to acknowledge all privacy requests within forty-eight (48) hours and to provide a substantive response within thirty (30) days.

If you are not satisfied with phrus's response to a privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data privacy matters in the Philippines.