phmery Privacy Policy

This Privacy Policy ("Policy") describes how phmery ("phmery," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you," "Player," or "User") who access or use the phmery website at https://phmery.com and all associated services (collectively, the "Platform"). This Policy is issued in compliance with the Philippine Data Privacy Act of 2 012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

By registering an account or using the phmery Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the phmery Platform immediately.

1. Introduction

1.1 phmery is committed to protecting the privacy and security of your personal information. This Policy applies to all personal data collected through the phmery Platform, including data collected during registration, account use, payment transactions, customer support interactions, and your general browsing of the phmery website.

1.2 This Policy should be read together with the phmery Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

2.1 phmery is the data controller responsible for your personal information collected through the Platform. As data controller, phmery determines the purposes and means of processing your personal data in accordance with applicable Philippine law.

2.2 phmery has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection legislation. You may contact the phmery DPO using the contact details provided in Section 14 of this Policy.

3. Data We Collect

3.1 phmery collects the following categories of personal data:

3.2 phmery does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law (for example, responsible gaming assessments).

3.3 Data from Third Parties. phmery may receive personal data about you from third-party payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention agencies, and analytics providers, where such data is necessary to operate the Platform and comply with legal obligations.

4. How We Use Your Data

4.1 phmery uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your phmery account, including identity verification and age verification (21+ requirement);
• Service Delivery: To provide access to phmery games, process deposits and withdrawals, and deliver customer support;
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other prohibited conduct on the phmery Platform;
• Legal Compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR regulatory requirements, and tax reporting obligations;
• Responsible Gaming: To monitor gaming activity and identify players who may be at risk, and to administer self-exclusion and limit-setting tools;
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the phmery Platform;
• Marketing Communications: To send promotional offers, bonuses, and news about phmery to players who have opted in to receive such communications;
• Dispute Resolution: To investigate and resolve disputes, complaints, and legal claims relating to your use of the phmery Platform.

5. Legal Basis for Processing

5.1 phmery processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and phmery (i.e., the Terms & Conditions), including account creation, game access, and payment processing;
• Legal Obligation: Processing is required to comply with applicable laws, including AML regulations, PAGCOR licensing requirements, and tax obligations;
• Legitimate Interests: Processing is necessary for phmery's legitimate interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, phmery relies on your freely given, specific, and informed consent, which you may withdraw at any time.

6. Data Sharing and Disclosure

6.1 phmery does not sell, rent, or trade your personal data to third parties for their own commercial purposes. phmery may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and age verification service providers engaged by phmery to verify player identity and age;
• Fraud Prevention and Security Providers: Service providers that assist phmery in detecting and preventing fraud, money laundering, and other prohibited activity;
• Analytics Providers: Service providers that help phmery analyze Platform usage and improve user experience, subject to appropriate data processing agreements;
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other government authorities, where disclosure is required by law or regulatory obligation;
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by phmery, subject to confidentiality obligations.

6.2 All third-party service providers engaged by phmery are required to process your personal data only on phmery's instructions and in accordance with applicable data protection law. phmery does not permit third-party service providers to use your data for their own purposes.

7. Cookies and Tracking Technologies

7.1 phmery uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform. Cookies are small text files placed on your device that help phmery recognize you, maintain your session, and improve your experience.

7.2 phmery uses the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management and security. These cannot be disabled.
• Functional Cookies: Remember your preferences and settings, such as language and display options, to personalize your phmery experience.
• Analytics Cookies: Help phmery understand how players use the Platform, which pages are most visited, and where improvements can be made. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used only with your consent to deliver relevant promotional content within the phmery Platform. phmery does not use marketing cookies to track your activity on third-party websites.

7.3 You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phmery Platform.

8. Data Retention

8.1 phmery retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, as required by AML regulations and PAGCOR licensing conditions;
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Customer support communications are retained for three (3) years from the date of the interaction;
• Marketing preference data is retained until you withdraw your consent or close your account.

8.2 Where phmery no longer has a legal or legitimate basis to retain your personal data, it will be securely deleted or anonymized in accordance with phmery's data retention procedures.

9. Data Security

9.1 phmery implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phmery Platform;
• Encryption of sensitive data at rest, including identity documents and financial information;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of phmery systems;
• Two-factor authentication (2FA) options for player accounts.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phmery will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

9.3 While phmery takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your phmery account credentials confidential and for notifying phmery immediately if you suspect unauthorized access to your account.

10. Your Data Rights

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phmery:

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed by phmery;
• Right of Access: The right to request a copy of the personal data phmery holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data where phmery no longer has a legal basis to retain it;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another data controller;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phmery has violated your data privacy rights.

10.2 To exercise any of the above rights, please contact phmery's Data Protection Officer using the contact details in Section 14. phmery will respond to all verified requests within thirty (30) days. phmery may request proof of identity before processing your request.

11. Children's Privacy

11.1 The phmery Platform is strictly intended for persons who are 21 years of age or older. phmery does not knowingly collect personal data from persons under the age of 21. If phmery becomes aware that personal data has been collected from a person under 21, that account will be immediately closed and all associated data will be deleted, except where retention is required by law.

11.2 If you believe that a person under 21 has registered on the phmery Platform, please contact phmery support immediately so that appropriate action can be taken.

12. International Data Transfers

12.1 phmery primarily stores and processes your personal data within the Philippines. Where it is necessary to transfer your personal data to service providers or partners located outside the Philippines, phmery will ensure that such transfers are made in compliance with the Data Privacy Act of 2012, including by implementing appropriate safeguards such as data processing agreements that require the recipient to provide a level of data protection equivalent to that required under Philippine law.

12.2 By using the phmery Platform, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

13. Updates to This Policy

13.1 phmery reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or phmery's data processing practices. The most current version of this Policy will always be available at https://phmery.com/privacy-policy.

13.2 Where changes to this Policy are material, phmery will notify registered players by email or by a prominent notice on the Platform prior to the changes taking effect. Your continued use of the phmery Platform after the effective date of any update constitutes your acceptance of the revised Policy.

13.3 If you do not agree to any updated Privacy Policy, you must cease using the phmery Platform and may request account closure in accordance with the Terms & Conditions.

14. Contact Us

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or phmery's data processing practices, please contact the phmery Data Protection Officer:

Email: [email protected]

General Support: [email protected]

14.2 phmery aims to respond to all privacy-related inquiries within fifteen (15) business days. For account-specific matters, please contact us from your registered email address to allow for prompt verification.

14.3 If you are not satisfied with phmery's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).