phmery Privacy Policy

1 Introduction

phmery ("phmery," "we," "us," or "our") operates the online gaming platform accessible at phmery.net. We understand that your personal information is important to you, and we take our responsibility as a Personal Information Controller seriously. This Privacy Policy describes how phmery collects, processes, stores, shares, and protects personal data in connection with your use of the phmery Platform and all associated services.

This Privacy Policy applies to all registered players, visitors to the phmery website, and any individual whose personal data is processed by phmery in connection with the Platform. By registering an account on phmery or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read alongside phmery's Terms and Conditions and Responsible Gaming Policy.

2 Personal Data We Collect

phmery collects personal data that is necessary for the operation of the Platform, compliance with legal and regulatory obligations, and the delivery of a safe and personalised gaming experience. The categories of personal data we collect include:

When you create a phmery account, we collect your full legal name, date of birth, nationality, Philippine mobile number or email address, and a username and password of your choosing. This information is required to create and maintain your account.

To comply with PAGCOR regulations and Philippine anti-money laundering (AML) laws, phmery may require you to submit government-issued identification documents, proof of address, and other supporting documentation. This may include a copy of your Philippine National ID, passport, driver's licence, or other PAGCOR-accepted identification.

phmery collects information related to your financial transactions on the Platform, including deposit and withdrawal amounts, transaction dates, and the payment methods used (e.g., GCash account reference, bank account details for bank transfer). phmery does not store full payment card numbers or GCash PINs.

We collect records of your gaming activity on phmery, including games played, wagers placed, outcomes, session durations, and bonus usage. This data is used for account management, responsible gaming monitoring, and regulatory reporting.

When you access the phmery Platform, we automatically collect certain technical data, including your IP address, device type, operating system, browser type and version, and session timestamps. This data is used for security monitoring, fraud prevention, and Platform optimisation.

If you contact phmery's support team, we retain records of those communications, including the content of messages, timestamps, and the resolution of any issues raised. This data is used for quality assurance and to maintain a record of your interactions with phmery.

3 How phmery Uses Your Personal Data

phmery processes your personal data only for legitimate, specified purposes. The primary purposes for which phmery uses your personal data are as follows:

• Account Management: To create, maintain, and administer your phmery player account, including processing deposits and withdrawals and managing your gaming activity.
• Identity Verification and KYC: To verify your identity and age in compliance with PAGCOR regulations and Philippine AML laws, including the Anti-Money Laundering Act (AMLA) and its amendments.
• Regulatory Compliance: To fulfil phmery's obligations under applicable Philippine laws and PAGCOR regulations, including reporting requirements and the maintenance of required records.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: To respond to your enquiries, resolve disputes, and provide assistance with your phmery account.
• Platform Improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the phmery Platform.
• Marketing Communications: To send you promotional offers, bonuses, and updates about phmery, where you have provided consent to receive such communications. You may withdraw this consent at any time.

4 Legal Basis for Processing

phmery processes your personal data on the following legal bases under the Data Privacy Act of 2012 (Republic Act No. 10173):

• Contractual Necessity: Processing is necessary for the performance of the contract between you and phmery (i.e., the Terms and Conditions), including account management and payment processing.
• Legal Obligation: Processing is required for phmery to comply with its legal and regulatory obligations under Philippine law, including PAGCOR regulations and AML requirements.
• Legitimate Interests: Processing is necessary for phmery's legitimate interests in operating a secure, fair, and compliant gaming platform, including fraud prevention and Platform security.
• Consent: For certain processing activities, such as marketing communications, phmery relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Sharing of Personal Data

phmery does not sell your personal data to third parties. phmery may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Regulatory Authorities: PAGCOR and other Philippine government agencies, where required by law or regulation.
• Payment Processors: GCash, PayMaya / Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), solely for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged by phmery to assist with age and identity verification in compliance with PAGCOR requirements.
• Technology and Hosting Providers: Cloud hosting, data storage, and Platform infrastructure providers who process data on phmery's behalf under strict data processing agreements.
• Game Software Providers: Licensed game developers whose software is integrated into the phmery Platform may receive limited technical data necessary for game operation and fairness certification.
• Law Enforcement: Philippine law enforcement agencies or courts, where phmery is legally required to disclose personal data in connection with a lawful investigation or legal proceeding.

6 Cookies and Tracking Technologies

phmery uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit the phmery website. They help us recognise your device, maintain your session, and understand how you interact with the Platform.

• Strictly Necessary Cookies: These cookies are essential for the operation of the phmery Platform, including maintaining your login session and enabling secure transactions. These cookies cannot be disabled without affecting Platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymised information about how visitors use the phmery Platform, such as which pages are visited most frequently. This data helps phmery improve the Platform experience.
• Functionality Cookies: These cookies remember your preferences, such as your preferred language and display settings, to provide a more personalised experience on phmery.
• Marketing Cookies: With your consent, phmery may use cookies to deliver relevant promotional content. You may withdraw consent for marketing cookies at any time through your browser settings.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phmery Platform. For more information on managing cookies, refer to your browser's help documentation.

7 Data Retention

phmery retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and reporting obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your phmery account and for a minimum of five (5) years following account closure, in accordance with PAGCOR regulations and Philippine AML requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Gaming Activity Records: Retained for a minimum of three (3) years from the date of the activity, or longer where required by applicable regulations.
• Communications Data: Retained for a minimum of two (2) years from the date of the communication, or longer where relevant to an ongoing dispute or investigation.
• Technical and Device Data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, phmery will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8 Data Security

phmery implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit 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 records;
• Role-based access controls limiting access to personal data to authorised phmery personnel on a strict need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning of the phmery Platform;
• Multi-factor authentication requirements for access to systems containing personal data;
• Staff training on data protection obligations and information security best practices.

While phmery takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phmery will notify you and the National Privacy Commission (NPC) in accordance with the requirements of the Data Privacy Act of 2012.

9 Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights in relation to your personal data held by phmery:

• Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed by phmery, as set out in this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data that phmery holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request that phmery correct any inaccurate or incomplete personal data held about you.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phmery's legal and regulatory retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, subject to phmery's overriding legal obligations.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that phmery has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact phmery's Data Protection Officer using the contact details provided in Section 12 of this Privacy Policy. phmery will respond to all verified data subject requests within thirty (30) days of receipt.

10 Children's Privacy and Age Restriction

The phmery Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. phmery does not knowingly collect personal data from individuals under the age of 21.

phmery employs age verification procedures during the registration process to prevent underage access to the Platform. If phmery becomes aware that personal data has been collected from an individual under the age of 21, phmery will immediately suspend the relevant account, delete the associated personal data, and return any deposits in accordance with applicable regulations.

11 Changes to This Privacy Policy

phmery reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When material changes are made to this Privacy Policy, phmery will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect.

The updated Privacy Policy will be posted on this page with a revised effective date. Your continued use of the phmery Platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how phmery protects your personal data.

12 Contact and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or phmery's processing of your personal data, please contact phmery's Data Protection Officer:

phmery is committed to resolving all data privacy concerns promptly and transparently. If you are not satisfied with phmery's response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.