phdrwam Privacy Policy

1. Introduction

phdrwam ("we," "us," or "our") operates the online casino and sports betting platform accessible at https://phdrwam.net. This Privacy Policy describes how phdrwam collects, uses, stores, shares, and protects the personal information of all individuals ("you," "your," or "Player") who access or use our platform, whether through a desktop browser, mobile browser, or any other interface.

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines. It is also consistent with the data handling standards expected of PAGCOR-regulated online gaming operators.

This Privacy Policy should be read in conjunction with phdrwam's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, phdrwam is the Personal Information Controller (PIC) in respect of all personal data processed through the phdrwam platform. As a PIC, phdrwam determines the purpose and means of processing your personal information and is responsible for ensuring that all processing activities comply with RA 10173.

phdrwam has appointed a Data Protection Officer (DPO) in accordance with the requirements of the NPC. The DPO is responsible for overseeing data protection strategy and implementation, and serves as the primary point of contact for all data privacy-related inquiries, complaints, and rights requests from Filipino data subjects. Contact details for the DPO are provided in Section 14 of this Policy.

Where phdrwam engages third-party service providers (such as payment processors, game software providers, or fraud detection services) to process personal data on its behalf, those parties act as Personal Information Processors (PIPs) and are bound by contractual data processing agreements that require them to implement appropriate technical and organizational security measures.

3. Categories of Personal Data We Collect

3.1 Data You Provide Directly

When you register an Account, complete KYC verification, make a transaction, or contact our support team, you provide us with personal information that may include:

• Identity data: Full legal name, date of birth, gender, nationality;
• Contact data: Philippine mobile number, email address, residential address;
• Identity document data: Government-issued ID type and number (e.g., Philippine passport, UMID, driver's license, voter's ID), and copies of those documents where required for KYC;
• Financial data: GCash account number, Maya account number, BPI/BDO/Metrobank account name and number, USDT wallet address — sufficient to process deposits and withdrawals;
• Communications data: Records of your interactions with phdrwam's 24/7 live chat support, including chat transcripts and any emails exchanged.

3.2 Data Collected Automatically

When you access the phdrwam platform, our systems automatically collect certain technical and behavioral data, including:

• Device & technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers;
• Usage data: Pages visited, games played, session duration, click-stream data, login timestamps, and feature interactions;
• Geolocation data: Approximate geolocation derived from your IP address, used to verify geographic eligibility;
• Transaction data: Full records of all deposits, withdrawals, wagers, bonus claims, and game outcomes associated with your Account.

3.3 Data from Third Parties

phdrwam may receive limited personal data about you from trusted third-party sources in the following circumstances:

• From payment partners (GCash, Maya, BPI, BDO) to confirm successful transaction processing;
• From fraud detection and identity verification service providers to assist with KYC compliance;
• From PAGCOR or other Philippine regulatory bodies, where required for compliance with gaming regulations or anti-money laundering obligations.

4. How We Use Your Personal Data

phdrwam uses the personal data we collect for the following clearly defined purposes:

phdrwam does not use your personal data for any purpose not listed above without first obtaining your explicit consent, except where required by Philippine law or a valid order from a competent Philippine authority.

5. Lawful Basis for Processing

Under the Data Privacy Act of 2012, phdrwam relies on the following lawful bases for processing personal data:

• Contractual necessity: Processing required to fulfill our obligations under the phdrwam Terms & Conditions — including Account management, transaction processing, and game delivery — is necessary for the performance of the contract between you and phdrwam;
• Legal obligation: Certain processing activities are required by Philippine law, including KYC verification under PAGCOR regulations, AML transaction monitoring under RA 9160 (Anti-Money Laundering Act), and regulatory reporting obligations;
• Legitimate interests: phdrwam processes certain data (such as usage analytics, fraud detection signals, and responsible gaming monitoring) on the basis of legitimate interests, where those interests are not overridden by your data protection rights;
• Consent: Where phdrwam sends you direct marketing communications (such as promotional email newsletters or bonus SMS notifications), we do so on the basis of your explicit opt-in consent, which you may withdraw at any time through your Account settings or by contacting our support team.

6. Data Sharing & Disclosure

6.1 Who We Share Data With

phdrwam does not sell your personal data. We share your information only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment processors: GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, Metrobank, and other payment partners — to facilitate deposits and withdrawals;
• Game software providers: Licensed third-party game studios including Pragmatic Play, PG Soft, Jili Games, and Evolution Gaming — limited to session and game data required to operate their games on our platform;
• Identity verification providers: Third-party KYC service providers used to verify government-issued IDs and confirm age eligibility (21+);
• Fraud detection & cybersecurity partners: Providers of anti-fraud, device fingerprinting, and platform security services;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government bodies, as required by law;
• Legal and professional advisors: Lawyers, auditors, and compliance consultants engaged by phdrwam, subject to strict confidentiality obligations.

6.2 Business Transfers

In the event that phdrwam undergoes a merger, acquisition, or transfer of substantially all of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer via the email address registered on your Account, and the acquiring entity will be required to honor the terms of this Privacy Policy.

7. Cookies & Tracking Technologies

phdrwam uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and deliver a personalized experience. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function correctly — for example, session authentication cookies that keep you logged in securely during your gaming session. These cannot be disabled.
• Performance & analytics cookies: Used to collect aggregated, anonymized data about how players interact with the platform, which pages are most visited, and where technical errors occur. This data helps us improve the phdrwam experience for all Filipino players.
• Functional cookies: Store your preferences such as language settings, preferred game categories, and responsible gaming limits so that they persist across sessions.
• Marketing cookies: Used, with your consent, to deliver relevant phdrwam promotional communications. These may track your visits to the platform in connection with our own promotional campaigns.

You can manage or withdraw your consent to non-essential cookies at any time through your browser settings or the phdrwam cookie preference panel accessible from the platform footer. Please note that disabling strictly necessary cookies may impair the functionality of the platform.

8. Data Security

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

• 256-bit SSL/TLS encryption on all data in transit between your device and phdrwam's servers;
• AES-256 encryption at rest for all stored personal and financial data;
• Two-factor authentication (2FA) via SMS OTP for all new device logins and withdrawal requests above defined thresholds;
• Role-based access controls (RBAC) ensuring that phdrwam staff access only the data necessary for their specific job function;
• Regular penetration testing and security audits conducted by independent cybersecurity firms;
• 24/7 security monitoring and intrusion detection systems covering all platform infrastructure.

While phdrwam takes all reasonable steps to protect your data, no internet-based system is completely immune to security risks. You are responsible for maintaining the security of your Account credentials and for notifying phdrwam immediately if you suspect unauthorized access.

9. Data Retention

phdrwam retains personal data only for as long as is necessary to fulfill the purpose for which it was collected, or as required by Philippine law and regulatory obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with phdrwam's data disposal procedures. Data subject to ongoing legal proceedings or regulatory investigations will be retained until those matters are resolved.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you — as a Filipino data subject — have the following rights in relation to your personal data held by phdrwam:

To exercise any of the above rights, submit a written request to phdrwam's Data Protection Officer at [email protected] with the subject line "Data Privacy Rights Request." phdrwam will respond within fifteen (15) business days. We may require identity verification before processing your request.

11. Children's Privacy and the 21+ Requirement

The phdrwam platform is strictly for individuals aged 21 years and above, in compliance with Philippine gaming regulations enforced by PAGCOR. phdrwam does not knowingly collect personal data from individuals below the age of 21.

All new Accounts are subject to age verification as part of the KYC process. Where phdrwam discovers that an Account has been created by a person below the age of 21, that Account will be immediately suspended, all real-money balances will be returned (less any bonus amounts), and all personal data associated with that Account will be deleted to the extent permitted by applicable law.

If you believe that a person below the age of 21 has registered an Account on the phdrwam platform, please notify us immediately at [email protected].

12. Cross-Border Data Transfers

The phdrwam platform is operated primarily for the benefit of Filipino players, and personal data is stored on servers located within Southeast Asia. However, certain third-party service providers — including game software providers and cybersecurity vendors — may process data in jurisdictions outside the Philippines.

Where personal data is transferred to a country or territory that does not provide an equivalent level of data protection to the Philippines, phdrwam ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by the NPC or equivalent regulatory authority;
• Data processing agreements that impose equivalent data protection obligations on the recipient;
• Transfer only to countries recognized by the NPC as providing adequate data protection.

You may request further information about cross-border transfer safeguards by contacting phdrwam's Data Protection Officer.

13. Updates to This Privacy Policy

phdrwam reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal or regulatory requirements, or platform features. When material changes are made, we will:

• Post the updated Policy at https://phdrwam.net/privacy-policy with a revised effective date;
• Notify registered Players via the email address on file at least seven (7) calendar days before the changes take effect, where those changes materially affect how we handle your personal data;
• Where required by the NPC, obtain fresh consent for new processing activities not previously disclosed.

We encourage you to review this Policy periodically to stay informed about how phdrwam is protecting your information. Your continued use of the platform after the effective date of any updated Policy constitutes your acceptance of the revised terms.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by phdrwam, please contact our Data Protection Officer using the details below:

• Data Protection Officer: phdrwam DPO
• Email: [email protected] — please use the subject line "Data Privacy Inquiry" or "Data Privacy Rights Request"
• Live Chat: Available 24/7 through the phdrwam platform
• Response Time: We aim to acknowledge all privacy inquiries within two (2) business days and provide a full response within fifteen (15) business days.

If you are not satisfied with phdrwam's response to your data privacy concern, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC)
• 3rd Floor, Core G, DICT Building, C.P. Garcia Avenue, Diliman, Quezon City, Philippines
• Website: privacy.gov.ph