phlargo
Privacy Policy

1. Introduction

phlargo operates an online gaming platform accessible to eligible Filipino players aged 21 and above. In the course of providing our services — including account registration, game access, payment processing, customer support, and promotional activities — phlargo necessarily collects and processes certain personal information about you.

This Privacy Policy applies to all personal data collected through the phlargo website, mobile platform, live chat support, email communications, and any other channel through which you interact with phlargo. It applies to all registered players, prospective players, and visitors to the phlargo platform.

phlargo acts as the Personal Information Controller (as defined under RA 10173) with respect to the personal data described in this Policy. We are responsible for ensuring that your data is processed lawfully, fairly, and transparently.

2. Personal Data We Collect

phlargo collects the following categories of personal data:

2.1 Identity & Contact Information

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify you are 21 years of age or older)
• Philippine mobile number
• Email address
• Residential address (province, city/municipality)
• Nationality

2.2 Identity Verification (KYC) Documents

• Government-issued photo ID (e.g., Philippine passport, driver's license, SSS/GSIS ID, PhilSys National ID, Voter's ID)
• Proof of address (e.g., utility bill, bank statement)
• Proof of payment method (e.g., screenshot of GCash account, bank account details)
• Selfie or live photo for identity verification purposes

2.3 Financial Information

• GCash mobile number or PayMaya / Maya account reference
• Bank account details (bank name, account number) for bank transfer transactions
• Debit card details (card number, expiry — processed securely via our payment partners)
• Transaction history: deposit amounts, withdrawal amounts, dates, and payment methods

2.4 Gaming Activity Data

• Games played, bet amounts, win/loss records, session durations
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

2.5 Technical & Device Data

• IP address and approximate geolocation (to verify Philippine residency and detect fraud)
• Device type, operating system, browser type and version
• Login timestamps and session activity logs
• Cookies and similar tracking technologies (see Section 7)

2.6 Communications Data

• Records of live chat conversations with phlargo support agents
• Email correspondence with phlargo
• Feedback, complaints, and dispute records

3. How We Collect Your Data

phlargo collects your personal data through the following means:

• Direct collection: Information you provide when registering your phlargo account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the phlargo platform, including IP address, device information, and cookies.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; geolocation data from IP intelligence services.
• Payment providers: Transaction confirmation data from GCash, PayMaya / Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank).

4. How We Use Your Personal Data

phlargo uses your personal data for the following purposes:

phlargo will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfill our obligations to you under the phlargo Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving our services — where such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have given your explicit, informed consent. You may withdraw consent at any time by contacting phlargo support.

6. Data Sharing & Disclosure

phlargo does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

6.1 Service Providers

phlargo engages trusted third-party service providers to assist in operating the platform, including KYC and identity verification providers, payment processors (GCash, PayMaya / Maya, Philippine banks), fraud detection services, cloud hosting providers, and customer support software providers. These providers are contractually bound to process your data only on phlargo's instructions and in accordance with applicable data protection laws.

6.2 Regulatory and Law Enforcement Authorities

phlargo may disclose your personal data to the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or other competent Philippine government authorities where required by law, court order, or regulatory directive.

6.3 Game Content Providers

Third-party game studios and software providers whose games are available on phlargo may receive limited technical data (such as player session tokens) necessary to deliver their games. These providers do not receive your full identity or financial data.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of phlargo's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

7. Cookies & Tracking Technologies

phlargo uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit phlargo.

7.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies that keep you logged in to your phlargo account. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game display options, and responsible gaming limit configurations.
• Analytics cookies: Help phlargo understand how players use the platform — which games are most popular, where players encounter issues, and how to improve the overall experience. Data collected is aggregated and anonymized.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts.

7.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling certain cookies may affect the functionality of the phlargo platform. For detailed instructions on managing cookies in your browser, refer to your browser's help documentation.

8. Data Retention

phlargo retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention guidelines:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years after account closure, in compliance with Philippine AML regulations and PAGCOR requirements.
• KYC documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, as required by the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years in accordance with BIR and AMLC record-keeping requirements.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation.

After the applicable retention period expires, phlargo will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

9. Data Security

phlargo implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption in transit: All data transmitted between your device and phlargo's servers is encrypted using TLS 1.2 or higher.
• Encryption at rest: Sensitive personal data, including KYC documents and financial information, is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is restricted to phlargo employees and contractors who require it to perform their job functions. All access is logged and audited.
• Two-factor authentication: phlargo supports two-factor authentication (2FA) for player accounts to prevent unauthorized access.
• Regular security audits: phlargo conducts regular internal and third-party security assessments to identify and remediate vulnerabilities.
• Incident response: phlargo maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, phlargo will notify the National Privacy Commission (NPC) within 72 hours and affected players without undue delay, as required by RA 10173.

10. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by phlargo:

• Right to be informed: You have the right to know what personal data phlargo collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data phlargo holds about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data in your phlargo account.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phlargo's legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe phlargo has violated your data privacy rights.

To exercise any of these rights, please contact phlargo's Data Protection Officer via the contact details in Section 15. phlargo will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

11. Children's Privacy

phlargo's platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations. phlargo does not knowingly collect personal data from individuals under the age of 21.

If phlargo becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the data, and report the matter to the appropriate authorities where required. If you believe a minor has registered on phlargo, please contact our support team immediately.

12. Third-Party Links

The phlargo platform may contain references to third-party services, such as payment providers (GCash, PayMaya / Maya, Philippine banks). When you interact with these third-party services, you are subject to their own privacy policies and terms of service. phlargo is not responsible for the privacy practices of third-party services and encourages you to review their privacy policies before providing any personal data to them.

13. International Data Transfers

phlargo primarily stores and processes your personal data within the Philippines. In some cases, data may be processed by our service providers in other countries — for example, cloud infrastructure providers or game content suppliers with servers located outside the Philippines.

Where personal data is transferred outside the Philippines, phlargo ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses consistent with the requirements of RA 10173 and NPC regulations. phlargo will not transfer your personal data to countries that do not provide an adequate level of data protection without your explicit consent or without implementing appropriate safeguards.

14. Updates to This Privacy Policy

phlargo may update this Privacy Policy from time to time to reflect changes in our data practices, applicable laws, or platform features. When material changes are made, phlargo will notify registered players via email or a prominent notice on the platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. We encourage you to review this Privacy Policy periodically. Your continued use of phlargo after the effective date of any update constitutes your acceptance of the revised Policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or phlargo's data practices, please contact our Data Protection Officer (DPO). Our DPO is responsible for overseeing phlargo's compliance with the Philippine Data Privacy Act of 2012.

You also have the right to file a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. Information about filing a complaint with the NPC is available through official Philippine government channels.