phdram Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") is issued by phdram ("we," "us," "our," or the "Company"), the operator of the online gaming platform at phdram.vip. This Policy applies to all personal data processed in connection with your registration, use, and interaction with the phdram Platform, including via any mobile browser session, live chat, email correspondence, or customer support interaction.

phdram is committed to processing your personal data in a lawful, fair, and transparent manner, in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. Where applicable, phdram also observes the anti-money laundering data obligations prescribed by the Anti-Money Laundering Act (AMLA) as administered by the Anti-Money Laundering Council (AMLC).

2 Legal Basis for Processing

phdram processes your personal data on the following legal bases as recognized under Republic Act No. 10173:

• Contractual necessity: Processing required to create and operate your phdram account, process deposits and withdrawals, and deliver the gaming services you have requested.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLC anti-money laundering obligations, KYC/CDD requirements, and other applicable Philippine law.
• Legitimate interests: Processing necessary for fraud prevention, security monitoring, platform improvement, and responsible gaming enforcement, where such interests are not overridden by your fundamental rights.
• Consent: Processing for optional purposes such as marketing communications, where we have obtained your explicit consent and where you retain the right to withdraw that consent at any time.

3 Personal Data We Collect

The categories of personal data phdram may collect and process are set out in the table below. Collection is limited to what is necessary for the specified purpose.

4 How We Collect Your Data

phdram collects your personal data through the following channels:

• Direct submission: Data you provide when registering a phdram account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated technical collection: Data collected automatically when you visit or interact with phdram.vip, including your IP address, browser type, operating system, referral URL, and session activity logs. This collection occurs via server logs, session tokens, and standard web analytics tools.
• Cookies and local storage: phdram uses cookies and similar tracking technologies as described in Section 7 of this Policy.
• Third-party identity verification providers: Where phdram uses a third-party KYC platform to assist with identity document verification, that provider may transmit verified identity data to phdram's systems upon completion of the verification process.
• Payment service providers: phdram receives transaction confirmation data from GCash, Maya, BPI, BDO, UnionBank, and other payment processors sufficient to reconcile your deposit and withdrawal records.

5 Purposes of Processing

phdram processes your personal data for the following specific, explicit, and legitimate purposes:

1. To register and maintain your phdram account;
2. To verify your age (21+ requirement) and identity in compliance with PAGCOR and AMLC requirements;
3. To process financial transactions including GCash, Maya, and bank deposits and withdrawals, and to maintain accurate wallet balance records;
4. To deliver the gaming services, promotional offers, and platform features you have requested or are entitled to under your account;
5. To detect, investigate, and prevent fraud, money laundering, unauthorized account access, bonus abuse, and other prohibited conduct;
6. To enforce phdram's Terms & Conditions and responsible gaming policies, including monitoring play patterns that may indicate problem gambling;
7. To provide customer support and to resolve disputes or complaints;
8. To send you service notifications, security alerts, and account-related communications that are necessary for your use of the Platform;
9. To send you marketing and promotional communications where you have given explicit consent and have not subsequently withdrawn it;
10. To analyze aggregated usage patterns for the purpose of improving platform performance, game selection, and user experience;
11. To comply with any court order, regulatory directive, or applicable Philippine law.

6 Disclosure to Third Parties

phdram does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your data only in the following limited and controlled circumstances:

• Payment service providers: GCash, Maya, BPI, BDO, UnionBank, 7-Eleven (Cliqq), Coins.ph, and USDT exchange providers — solely to the extent necessary to process your financial transactions.
• KYC and identity verification providers: Third-party platforms engaged to assist phdram with identity document verification and liveness detection, subject to contractual data processing agreements.
• Game software providers: Licensed game studios and aggregation platforms whose games are available on phdram. Player identifiers required for game session management may be transmitted; no name or contact data is shared with these providers beyond what is technically necessary.
• Regulatory authorities: PAGCOR, AMLC, the NPC, the Bureau of Internal Revenue (BIR), and any other Philippine government authority with a lawful basis to request player data.
• Legal and law enforcement: Philippine courts, law enforcement agencies, and legal counsel where disclosure is required by a valid court order, subpoena, or regulatory investigation.
• Service providers operating on our behalf: Cloud hosting, analytics, cybersecurity, and customer support platform providers engaged under data processing agreements that prohibit secondary use of your data.

7 Cookies & Tracking Technologies

phdram.vip uses cookies and similar local storage technologies to operate the Platform, maintain your login session, prevent fraud, and understand how players interact with the site. The following categories of cookies are used:

phdram does not use third-party advertising cookies or behavioral tracking cookies for retargeting purposes. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will prevent your phdram account from functioning.

8 Data Retention

phdram retains your personal data for the minimum period necessary to fulfill the purpose for which it was collected, subject to the following retention standards:

• Active account data: Retained for the duration of your active phdram account plus five (5) years following permanent account closure, to comply with PAGCOR record-keeping obligations and AMLC transaction reporting requirements.
• KYC documents and identity verification records: Retained for a minimum of five (5) years from the date of account closure, as required under AMLC regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLA record-keeping requirements and BIR tax record obligations.
• Customer support communications: Retained for three (3) years following the resolution of the relevant support interaction.
• Marketing consent records: Retained for the duration of the marketing relationship plus two (2) years following withdrawal of consent.
• Technical/security logs: Retained for twelve (12) months, after which they are purged or anonymized.

Upon expiry of the applicable retention period, phdram securely destroys or anonymizes your personal data using industry-standard methods that render the data unrecoverable.

9 Data Security Measures

phdram implements a layered security program designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Key security measures include:

• Encryption in transit: All data transmitted between your device and phdram's servers is encrypted using TLS 1.2 or higher (256-bit SSL).
• Encryption at rest: Sensitive personal data, including government ID information, financial account numbers, and KYC documents, is encrypted at rest using AES-256 encryption.
• Access controls: Personal data is accessible only to phdram staff and contractors on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication for administrative systems.
• Intrusion detection and monitoring: phdram's infrastructure employs continuous security monitoring, anomaly detection, and DDoS mitigation.
• Password security: phdram stores account passwords using industry-standard one-way hashing with salt. Plain-text passwords are never stored or transmitted by phdram's systems.
• Penetration testing: phdram engages independent security professionals to conduct periodic penetration testing of Platform systems.

10 International Data Transfers

Some of phdram's third-party service providers — including cloud infrastructure providers and KYC platform vendors — may process or store data on servers located outside the Philippines. Where such international transfers occur, phdram implements appropriate safeguards to ensure your data receives a level of protection equivalent to that required under RA 10173, including:

• Contractual data processing agreements incorporating standard data protection clauses approved by the NPC or equivalent international standards;
• Transfer only to jurisdictions that maintain an adequate level of data protection as assessed by the NPC or by relevant international frameworks;
• Technical measures including end-to-end encryption of data transmitted to international processors.

phdram's primary data hosting infrastructure is located within data centers that serve the Asia-Pacific region, minimizing unnecessary international transfers of Philippine player data.

11 Your Privacy Rights

As a data subject under Republic Act No. 10173, you hold the following rights with respect to your personal data processed by phdram:

12 Children's Privacy

The phdram Platform is strictly intended for individuals aged 21 years and above in accordance with PAGCOR's minimum age requirements for online gambling participation in the Philippines. phdram does not knowingly collect personal data from any person under 21 years of age.

If phdram discovers or is notified that personal data of a person under 21 has been collected — whether through a false declaration during registration or any other means — that account will be immediately closed, all associated personal data will be securely deleted (subject to any mandatory retention obligations under Philippine law), and any real-money funds will be handled in accordance with applicable PAGCOR procedures.

13 Marketing Communications

phdram may send you promotional communications — including bonus offers, new game announcements, tournament invitations, and platform updates — via SMS, push notification, or email, but only where you have explicitly opted in to receive such communications.

You may opt out of marketing communications at any time by:

• Updating your notification preferences in the phdram account settings under "Marketing & Notifications;"
• Contacting phdram's support team via live chat or at [email protected] with the subject line "Marketing Opt-Out."

Opting out of marketing communications does not affect your receipt of service communications that are necessary for your use of the Platform, such as deposit confirmations, withdrawal notifications, OTP messages, and security alerts.

14 Changes to This Privacy Policy

phdram reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, PAGCOR regulatory requirements, or phdram's data processing practices. When material changes are made, phdram will:

• Update the "Last Revised" date at the top of this Policy;
• Display a prominent notification banner on phdram.vip informing players of the update;
• Where practicable, send an email notification to registered account holders summarizing the key changes.

Your continued use of the phdram Platform after the effective date of any revised Policy constitutes your acknowledgment of the changes. Where changes materially affect the basis on which phdram processes data that was previously collected with your consent, phdram will seek fresh consent before proceeding with the new processing.

15 Contact & Data Protection Officer Details

For all privacy-related inquiries, data subject requests, or concerns regarding this Policy, please contact phdram's designated Data Protection Officer (DPO):