phspin8 Privacy Policy

1 Introduction

phspin8 ("we", "us", "our", "the Platform") operates the online gaming and sports betting platform accessible at phspin8.net. We are committed to protecting the privacy and personal data of all registered players, visitors, and users of our platform ("you", "your").

This Privacy Policy has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations (IRR), as administered and enforced by the National Privacy Commission (NPC). It applies to all personal data collected through the phspin8 website, mobile platform, and any related communications.

As a platform serving Filipino players across Metro Manila, Cebu, Davao, Quezon City, Makati, and all other regions of the Philippines, phspin8 takes its obligations as a Personal Information Controller (PIC) under Philippine law seriously. We process your personal data only to the extent necessary and always with appropriate safeguards in place.

This policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of your overall agreement with phspin8.

2 Personal Data We Collect

phspin8 collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with the platform, and from third-party sources as part of our regulatory compliance obligations.

2.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, residential address, email address, and mobile number.
• Identity verification (KYC) documents: Government-issued photo ID (e.g., Philippine National ID, passport, driver's licence), proof of address, and proof of payment method ownership.
• Financial data: GCash account details, Maya account details, BPI or BDO account numbers, and other payment method identifiers used for deposits and withdrawals.
• Communications data: Records of your correspondence with our support team via live chat or email.
• Preferences and settings: Language preferences, notification settings, and responsible gaming limits you configure within your account.

2.2 Data Collected Automatically

• Technical data: IP address, browser type and version, operating system, device type, screen resolution, and time zone.
• Usage data: Pages visited, games played, session duration, bet history, deposit and withdrawal transactions, and clickstream data.
• Cookie data: Session identifiers, authentication tokens, and analytics data collected via cookies and similar technologies (see Section 6).
• Geolocation data: Approximate location derived from your IP address, used for regulatory compliance and fraud prevention purposes.

2.3 Data from Third Parties

• Identity verification providers: Third-party KYC and AML screening services may share verification results and watchlist screening data with us.
• Payment processors: GCash, Maya, BPI, BDO, GrabPay, and other payment partners share transaction confirmation data and, where required, account ownership verification.
• Fraud prevention partners: Risk scoring and device fingerprinting data shared by our fraud detection service providers.

3 How We Use Your Personal Data

phspin8 uses the personal data we collect for the following specific purposes. We do not use your data for any purpose beyond what is described in this policy without first obtaining your consent or establishing a separate lawful basis.

Where phspin8 relies on your consent as the legal basis for processing (e.g., sending you promotional offers), you may withdraw that consent at any time by updating your notification preferences within your phspin8 account or by contacting our support team.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), phspin8 processes your personal data on the following lawful bases:

• Contractual necessity: Processing is necessary to perform our contract with you — i.e., to provide the phspin8 gaming platform, manage your account, and process your financial transactions.
• Legal obligation: Processing is required to comply with applicable Philippine law, including the Anti-Money Laundering Act (AMLA), PAGCOR licensing conditions, and data retention requirements.
• Legitimate interest: Processing is necessary for phspin8's legitimate business interests, such as fraud prevention, platform security, and service analytics, provided such interests are not overridden by your data protection rights.
• Consent: For certain processing activities (such as direct marketing communications), we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Vital interests: In limited circumstances, phspin8 may process data where it is necessary to protect the vital interests of a data subject, such as in the context of a responsible gaming emergency referral.

5 Data Sharing and Disclosure

phspin8 does not sell your personal data to any third party. We may share your personal data with the following categories of recipients strictly on a need-to-know basis and always under appropriate legal agreements:

5.1 Service Providers and Processors

phspin8 engages regulated third-party service providers to assist with platform operations. These include identity verification and KYC providers, payment processing partners (GCash, Maya, BPI, BDO, GrabPay, USDT processors, and 7-Eleven cash-in services), game software providers, cloud hosting and infrastructure providers, customer support platform operators, and fraud detection and cybersecurity services. All such providers are bound by data processing agreements that restrict them from using your data for any purpose other than providing services to phspin8.

5.2 Regulatory and Law Enforcement Authorities

phspin8 is required by Philippine law to disclose personal data to competent authorities in certain circumstances, including:

• The Anti-Money Laundering Council (AMLC) — for Suspicious Transaction Reports (STRs) and covered transaction reports required under the AMLA.
• PAGCOR and other gaming regulatory bodies — for licensing compliance, audit, and investigation purposes.
• Philippine law enforcement agencies — where required by court order, subpoena, or applicable legal process.
• The National Privacy Commission (NPC) — in the event of a personal data breach, as required under RA 10173.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of phspin8's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material change to this Privacy Policy that results from it.

6 Cookies and Tracking Technologies

The phspin8 platform uses cookies and similar technologies to ensure the proper functioning of the site, maintain your login session, remember your preferences, and gather anonymised analytics data to help us improve the platform experience for Filipino players.

6.1 Types of Cookies We Use

• Strictly necessary cookies: These are essential for the phspin8 platform to function. They include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Functional cookies: These remember your preferences such as language settings, display options, and responsible gaming reminder intervals.
• Analytics cookies: These collect anonymised data about how players use the phspin8 platform — such as which games are most popular and how players navigate between sections. This data is used solely to improve the platform.
• Security cookies: These assist in fraud detection and prevention by identifying unusual patterns in session behaviour and device characteristics.

6.2 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. However, disabling strictly necessary cookies may prevent certain features of the phspin8 platform from working correctly, including your ability to log in or maintain an active session. Please refer to your browser's help documentation for instructions on managing cookie settings.

7 Data Retention

phspin8 retains your personal data only for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account plus a minimum of 5 years following account closure, as required under AMLA and PAGCOR regulations.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, in accordance with anti-money laundering reporting obligations.
• KYC documents: Retained for the same period as account and identity data, subject to any extended retention requirements arising from an ongoing regulatory investigation or legal proceeding.
• Customer support communications: Retained for 3 years from the date of the last interaction, for dispute resolution and service improvement purposes.
• Analytics and usage data: Retained in anonymised or aggregated form for up to 2 years. Non-anonymised usage logs are typically deleted after 12 months.
• Marketing consent records: Retained for as long as you remain opted in, plus a reasonable period thereafter as evidence of your consent history.

When your data is no longer required, phspin8 will securely delete or anonymise it in accordance with our internal data disposal procedures.

8 Data Security

phspin8 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes the following measures:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the phspin8 platform is encrypted in transit using TLS 1.2 or higher.
• Encryption at rest: Sensitive personal data and financial information stored on phspin8 servers is encrypted using industry-standard encryption algorithms.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. All phspin8 staff and contractors who handle personal data are bound by confidentiality obligations.
• Multi-factor authentication (MFA): phspin8 supports MFA for player accounts to provide an additional layer of account security beyond password protection.
• Regular security audits: phspin8 conducts periodic penetration testing and security assessments of its platform infrastructure.
• Incident response: phspin8 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights, we will notify the National Privacy Commission (NPC) within 72 hours and affected individuals without undue delay, as required under RA 10173.

9 Your Data Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by phspin8. To exercise any of these rights, contact our Data Protection Officer at [email protected] with your request. We will respond within 30 days of receiving a verified request.

If you are not satisfied with phspin8's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10 Children and Minors

The phspin8 platform is strictly intended for adults aged 21 years and above, in accordance with the minimum legal gambling age under applicable Philippine gaming regulations. phspin8 does not knowingly collect, process, or store personal data from individuals under the age of 21.

During the account registration process, phspin8 collects date of birth information and conducts age verification checks. Any account where the registered user is found to be under 21 years of age will be immediately closed and all associated data will be handled in accordance with our data retention and deletion procedures.

If you are a parent or guardian and believe that a minor has registered on the phspin8 platform or submitted personal data without appropriate consent, please contact us immediately at [email protected]. We will investigate and take prompt corrective action.

11 Cross-Border Data Transfers

phspin8 primarily stores and processes your personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers, game software suppliers, and fraud detection services — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, phspin8 ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that required under Philippine law. These safeguards may include:

• Data processing agreements incorporating standard contractual clauses approved by the NPC or equivalent data protection authority.
• Transfers to jurisdictions recognised by the NPC as providing an adequate level of data protection.
• Binding corporate rules applicable to our group of entities, where relevant.

By using the phspin8 platform and accepting this Privacy Policy, you consent to the transfer of your personal data to third-party processors in other jurisdictions for the purposes described in this policy, subject to the safeguards described above.

12 Policy Updates

phspin8 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. The most current version of this policy will always be accessible at phspin8.net/privacy-policy.

Where a material change is made to this Privacy Policy — for example, a change to the categories of data we collect, a new sharing arrangement with a third party, or a change to your rights — phspin8 will notify registered players via email or via a prominent notice on the platform prior to the change taking effect.

Your continued use of the phspin8 platform after a Privacy Policy update has been communicated constitutes your acceptance of the revised policy. If you do not agree with any update, you should discontinue use of the platform and contact support to arrange account closure.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way phspin8 handles your personal data, please contact our Data Protection Officer through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week, via the live chat widget on the phspin8 platform.

We aim to respond to all privacy-related requests and enquiries within 30 days. For complex requests, we may require additional time, in which case we will notify you of the extended timeframe.

If you are not satisfied with our handling of a privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines.