Privacy Policy of phdream 22

1. Introduction & Scope

phdream 22 ("phdream 22," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the phdream 22 online gaming platform, including all associated websites, mobile interfaces, applications, games, promotions, and support services (collectively, the "Platform").

This Privacy Policy ("Policy") describes how phdream 22 collects, uses, stores, shares, and protects your personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It applies to all current and former registered players, visitors to the Platform, and any individual whose personal data is processed by phdream 22 in connection with the Platform.

By accessing the Platform, completing the registration process, or otherwise providing your personal data to phdream 22, 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 this Policy, you must not use the Platform.

This Policy should be read together with the phdream 22 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, phdream 22 acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes through the Platform. As PIC, phdream 22 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

phdream 22 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws. Contact details for the DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

phdream 22 collects the following categories of personal data from and about you:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — you must be at least 21 years old);
• Residential address, including barangay, city or municipality, and province;
• Email address and Philippine mobile number;
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license, SSS/GSIS number) where required for KYC verification.

3.2 Financial Data

• GCash or PayMaya mobile wallet number;
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where provided for withdrawal purposes;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references;
• Source of funds declarations where required by anti-money laundering regulations.

3.3 Gaming & Account Data

• Username and encrypted password;
• Game play history, including games played, wager amounts, win/loss records, and session durations;
• Bonus and promotion usage history;
• Responsible gaming settings, including deposit limits, cooling-off periods, and self-exclusion status;
• Customer support communications and complaint records.

3.4 Technical & Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type and version;
• Pages visited, features used, and time spent on the Platform;
• Referring URLs and search terms used to find the Platform;
• Cookie identifiers and similar tracking technology data (see Section 8).

4. How We Collect Your Data

phdream 22 collects your personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in promotions, or update your account settings;
• Automatically — through cookies, web beacons, server logs, and similar technologies when you access and interact with the Platform (see Section 8);
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud detection services, and regulatory bodies where required by law;
• From publicly available sources — where necessary for fraud prevention or regulatory compliance purposes.

5. How We Use Your Personal Data

phdream 22 uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, and account data
Age and identity verification (KYC)	Identity data, government ID, date of birth
Processing deposits and withdrawals	Financial data, identity data
Delivering and improving gaming services	Gaming data, technical and usage data
Fraud prevention and security monitoring	All categories, including technical data
Anti-money laundering (AML) compliance	Identity, financial, and transaction data
Responsible gaming monitoring and intervention	Gaming data, account data
Customer support and dispute resolution	Identity, account, and communication data
Sending service notifications and updates	Contact data
Sending promotional communications (with consent)	Contact data, gaming preferences
Regulatory reporting and legal compliance	All categories as required by law

phdream 22 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

6. Legal Basis for Processing

phdream 22 processes your personal data on the following legal bases under RA 10173:

• Consent — where you have given your explicit, informed consent to the processing of your personal data for a specific purpose, such as receiving promotional communications;
• Contractual necessity — where processing is necessary for the performance of the contract between you and phdream 22 (i.e., the Terms & Conditions), including account management, payment processing, and game delivery;
• Legal obligation — where processing is required to comply with a legal obligation applicable to phdream 22, including KYC/AML obligations, tax reporting, and regulatory requirements;
• Legitimate interests — where processing is necessary for the legitimate interests of phdream 22 or a third party, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.

7. Data Sharing & Disclosure

7.1 Service Providers

phdream 22 shares your personal data with carefully selected third-party service providers who assist us in operating the Platform. These include identity verification providers, payment processors (including GCash, PayMaya, BPI, BDO, and Metrobank), cloud hosting providers, fraud detection services, customer support platforms, and game software providers. All service providers are contractually required to process your data only on our instructions and in accordance with applicable data privacy laws.

7.2 Regulatory & Law Enforcement Authorities

phdream 22 may disclose your personal data to regulatory authorities, law enforcement agencies, and government bodies where required by Philippine law. This includes disclosures to the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent authorities. Such disclosures are made only to the extent required by law and are not subject to your consent.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of phdream 22's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and the privacy practices of the successor entity prior to the transfer taking effect.

7.4 No Sale of Personal Data

phdream 22 does not sell, rent, lease, or otherwise transfer your personal data to third parties for their own independent marketing or commercial purposes. Any sharing of data is limited to the purposes described in this Policy.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit the Platform. phdream 22 uses cookies and similar technologies (such as web beacons and local storage) to operate the Platform, remember your preferences, analyze usage patterns, and support security functions.

8.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming limits, to provide a more personalized experience.
• Analytics Cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats.

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use the Platform, including logging in to your phdream 22 account. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

9. Data Retention

phdream 22 retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Active account data: Retained for the duration of your account's active status plus five (5) years following account closure, in accordance with AML record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act;
• KYC documentation: Retained for five (5) years following the end of the business relationship;
• Customer support records: Retained for three (3) years from the date of the last interaction;
• Technical and usage data: Retained for up to twelve (12) months, after which it is aggregated or deleted;
• Marketing consent records: Retained until you withdraw your consent, plus one (1) year for compliance documentation purposes.

Upon expiry of the applicable retention period, phdream 22 will securely delete or anonymize your personal data in accordance with our data disposal procedures.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phdream 22. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

phdream 22 will respond to all verified data subject requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, and you will be notified of the extension and the reason for it. There is no fee for exercising your rights, except where requests are manifestly unfounded or excessive.

If you are not satisfied with our response to your request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Data Security

phdream 22 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption at rest for sensitive personal data stored on our servers, including financial data and government ID information;
• Access controls limiting access to personal data to authorized personnel on a strict need-to-know basis;
• Multi-factor authentication for administrative access to systems containing personal data;
• Regular security audits and penetration testing conducted by independent security professionals;
• Intrusion detection and prevention systems monitoring for unauthorized access attempts in real time;
• Staff training on data privacy and security obligations conducted on a regular basis.

12. Children's Privacy

The phdream 22 Platform is strictly intended for individuals who are at least 21 years of age. phdream 22 does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the registration and KYC process to enforce this restriction.

If phdream 22 becomes aware that personal data has been collected from an individual under the age of 21, we will immediately suspend the relevant account, delete the personal data in question, and take appropriate action in accordance with our legal obligations. If you believe that a minor has registered on the Platform, please contact our support team immediately.

13. Changes to This Privacy Policy

phdream 22 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, phdream 22 will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how phdream 22 protects your personal data.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phdream 22, please contact our Data Protection Officer (DPO):

Data Protection Officer, phdream 22
Email: [email protected]

For general support inquiries unrelated to data privacy, you may contact our customer support team at: [email protected]

Our support and DPO teams are available 24 hours a day, 7 days a week. We aim to acknowledge all data privacy inquiries within two (2) business days and to resolve them within fifteen (15) business days.

If you wish to lodge a complaint about our data processing practices with the Philippine data protection authority, you may contact the National Privacy Commission (NPC) directly. Information about the NPC and how to file a complaint is available through official Philippine government channels.