🔒 phqq Privacy Policy

1 Who We Are

phqq is an online casino and sports betting platform operating at phqq.net, serving players across the Philippines — from Manila and Quezon City to Cebu, Davao, Makati, and beyond. phqq operates under PAGCOR regulatory oversight and is committed to responsible, transparent, and legally compliant data practices.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, phqq acts as the Personal Information Controller in respect of all personal data collected through the phqq platform.

If you have any questions about this Policy or wish to exercise your data rights, you may contact our Data Protection Officer (DPO) via the contact details provided in Section 14 of this Policy.

2 Personal Data We Collect

phqq collects personal data in several categories depending on how you interact with our platform. The categories and specific data points we collect are described below:

3 How We Collect Your Data

phqq collects personal data through the following channels and methods:

• Directly from you: When you complete the phqq registration form, submit KYC documents, make deposits or withdrawals, contact customer support, participate in promotions, or update your account profile.
• Automatically: When you visit or use phqq.net, our servers automatically record technical data including your IP address, device information, browser details, session timestamps, and cookie identifiers. This happens regardless of whether you are logged in.
• From payment processors: When you transact via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, or Crypto channels, our payment processing partners share transaction confirmation data and relevant account reference information with phqq to facilitate the transaction and for fraud prevention.
• From KYC and identity verification providers: phqq uses regulated third-party KYC service providers to assist with document verification and age confirmation. These providers share verification outcomes and relevant identity confirmation data with phqq.
• From fraud and risk prevention systems: Automated risk scoring and fraud detection systems may generate data about your account activity that is used to protect both phqq and its players.

4 How We Use Your Personal Data

phqq uses your personal data for the following purposes, each of which is tied to a lawful basis described in Section 5:

• Account creation and management: To register your phqq account, verify your identity and age (21+ requirement), maintain your account profile, and provide access to platform features.
• Payment processing: To facilitate deposits and withdrawals via your chosen payment method, reconcile transactions, and maintain accurate financial records.
• KYC and regulatory compliance: To verify your identity as required under PAGCOR regulations and Philippine anti-money laundering laws, including Republic Act No. 9160 (Anti-Money Laundering Act) as amended.
• Game delivery and platform operation: To deliver casino games, track bets, calculate and credit winnings, manage bonus eligibility, and maintain the integrity of game outcomes.
• Customer support: To respond to your support requests, resolve disputes, and maintain records of communications for quality assurance purposes.
• Promotions and marketing: To send you bonus offers, promotional updates, and personalised recommendations — but only where you have consented to receive such communications. You may withdraw this consent at any time via your account settings.
• Responsible gaming: To monitor gaming behaviour patterns, enforce deposit limits and self-exclusion requests, and proactively identify indicators of problem gambling to enable early intervention.
• Security and fraud prevention: To detect and prevent fraud, money laundering, account takeover, and other prohibited conduct, and to maintain the security of the phqq platform and all player accounts.
• Legal and regulatory obligations: To comply with PAGCOR reporting requirements, court orders, law enforcement requests, and any other legal obligations applicable to phqq's operation as a licensed gaming platform.
• Platform improvement: To analyse aggregated, anonymised usage data to improve the phqq platform's features, performance, and user experience.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, phqq processes your personal data on the following legal bases:

• Contractual necessity: Processing required to create and maintain your phqq account, process payments, and deliver gaming services — i.e., to perform the contract between you and phqq.
• Legal obligation: Processing required to comply with PAGCOR regulations, Philippine anti-money laundering laws, tax reporting obligations, and other applicable legal requirements.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and anonymised analytics — where such interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications and non-essential cookies, where your prior consent has been obtained and can be freely withdrawn at any time.

6 Data Sharing & Disclosure

phqq does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following limited circumstances and only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and Crypto payment partners receive the minimum data required to process your transactions securely.
• KYC and identity verification providers: Regulated third-party KYC service providers receive copies of identity documents solely for the purpose of age and identity verification.
• Fraud prevention and risk services: Specialist fraud detection providers may receive account activity data for the purpose of identifying and preventing fraudulent transactions.
• IT and hosting infrastructure providers: Cloud hosting, database, and cybersecurity service providers that support the technical operation of the phqq platform, subject to strict data processing agreements.
• Customer support platforms: Third-party live chat and support ticketing providers used to deliver phqq's 24/7 customer support service.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), courts, and law enforcement agencies where disclosure is required by law or regulatory directive.
• Business transfers: In the event of a merger, acquisition, or sale of phqq's business or assets, player data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

All third parties with whom phqq shares personal data are contractually required to handle that data securely, use it only for the specified purpose, and comply with applicable Philippine data privacy law.

7 Cookies & Tracking Technologies

phqq uses cookies and similar tracking technologies to operate, secure, and improve the phqq platform. The types of cookies we use are:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and load-balancing identifiers. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and responsible gaming tool configurations to personalise your phqq experience.
• Analytical cookies: Collect anonymised data about how players navigate and use phqq.net, enabling us to identify areas for improvement. Data collected is aggregated and cannot be used to identify individual players.
• Security and fraud prevention cookies: Used to detect suspicious activity, protect against account takeover, and maintain the integrity of phqq's fraud detection systems.

You may manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phqq platform.

8 Data Retention

phqq retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

• Account data and KYC documents: Retained for a minimum of five (5) years from the date of account closure, as required under the Anti-Money Laundering Act.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction for tax, AML, and PAGCOR reporting purposes.
• Customer support records: Retained for a minimum of three (3) years from the date of the final interaction in a support case.
• Responsible gaming records: Self-exclusion records are retained for the duration of the exclusion period plus a minimum of five (5) years thereafter to prevent circumvention.
• Marketing consent records: Retained for as long as the consent is active plus a reasonable period thereafter to demonstrate compliance if challenged.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with phqq's data disposal procedures.

9 Data Security

phqq implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• Transport layer security: All data transmitted between your device and phqq.net is encrypted using TLS 1.2 or higher (256-bit SSL).
• Data encryption at rest: Sensitive personal data and financial records stored on phqq's servers are encrypted at rest using industry-standard AES-256 encryption.
• Access controls: Personal data is accessible only to phqq staff and authorised third parties on a strict need-to-know basis. Role-based access controls and multi-factor authentication are enforced for all internal system access.
• Penetration testing: phqq's platform undergoes regular independent security audits and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Intrusion detection: Real-time monitoring systems are in place to detect and alert on suspicious access patterns and potential security incidents.
• Incident response: phqq maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to players, phqq will notify affected players and the National Privacy Commission (NPC) within the timeframes prescribed by RA 10173.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phqq:

• Right to be informed: The right to be told what personal data phqq collects about you and how it is used — fulfilled by this Privacy Policy.
• Right of access: The right to request a copy of the personal data phqq holds about you, together with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update many details directly through your phqq account profile.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected — subject to legal retention obligations described in Section 8.
• Right to object: The right to object to processing based on legitimate interests, including profiling for responsible gaming monitoring and direct marketing.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format for transfer to another service provider where technically feasible.
• Right to restriction: The right to request that phqq restricts processing of your personal data in certain circumstances, such as while the accuracy of data is being contested.

To exercise any of these rights, please contact phqq's Data Protection Officer via the channels listed in Section 14. phqq will respond to all rights requests within fifteen (15) working days of receipt, as required under RA 10173. Certain rights are subject to limitations where legal retention obligations or PAGCOR regulatory requirements apply.

11 Children & Minors

phqq strictly prohibits the use of its platform by persons under the age of 21 years, in accordance with PAGCOR regulations and Philippine law. phqq does not knowingly collect personal data from individuals under 21 years of age.

As part of our registration and KYC process, all prospective players are required to confirm their age and submit government-issued identity documentation proving they meet the 21+ age requirement. Any account found to belong to a person under 21 will be immediately suspended and all associated personal data will be securely deleted, except to the extent retention is required by applicable law or regulatory obligation.

If you believe that phqq has inadvertently collected personal data from a person under 21, please contact our Data Protection Officer immediately at the details provided in Section 14 so that we can take prompt remedial action.

12 International Data Transfers

phqq primarily stores and processes personal data within the Philippines. However, some of phqq's third-party service providers — including cloud infrastructure providers, KYC verification services, and fraud detection systems — may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, phqq ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under RA 10173. These safeguards include:

• Data processing agreements incorporating standard contractual clauses consistent with NPC guidance;
• Transfer only to jurisdictions recognised as providing an adequate level of data protection; or
• Explicit contractual obligations on the recipient to maintain security and confidentiality standards equivalent to those required under Philippine law.

You may request further information about the safeguards in place for any specific international transfer by contacting our Data Protection Officer.

13 Updates to This Privacy Policy

phqq may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or PAGCOR regulatory requirements. The effective date at the top of this Policy indicates when the most recent revision was made.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — phqq will notify registered players by email to the address associated with their account and/or via a prominent notice on the phqq platform, at least seven (7) days before the changes take effect.

For non-material changes (such as clarifications, formatting updates, or corrections), the Policy will be updated without prior notice and the effective date revised accordingly.

Your continued use of the phqq platform after the effective date of any Policy update constitutes your acknowledgement of the revised Privacy Policy. If you do not agree with changes to the Policy, you may request account closure by contacting our 24/7 support team.

14 Contact & Complaints

For all privacy-related queries, data rights requests, or complaints regarding phqq's handling of your personal data, please contact phqq's Data Protection Officer through any of the following channels:

• 24/7 Live Chat: Available directly on the phqq platform at phqq.net — select "Privacy & Data" from the support menu
• Messenger & Viber: Via phqq's official support pages
• Email: [email protected] (plain text address — do not use mailto links)

phqq's support team is available around the clock, every day of the year. Our Data Protection Officer will handle all privacy-specific requests and aims to acknowledge your request within two (2) working days and provide a substantive response within fifteen (15) working days as required by RA 10173.