phspin.com Privacy Policy

1. Who We Are

phspin.com (referred to in this policy as "we," "us," "our," or "the Platform") is an online gaming platform operated under the phspincom.org domain, providing casino games, sports betting, and related entertainment services to eligible players in the Philippines.

phspin.com acts as the Personal Information Controller in respect of the personal data collected through the Platform, as defined under the Data Privacy Act of 2012. This means we determine the purposes and means by which your personal data is processed.

For all privacy-related enquiries, you may contact our Data Protection Officer (DPO) at the email address provided in Section 14 of this policy.

2. Personal Data We Collect

phspin.com collects the following categories of personal data from players:

We do not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for identity verification or legal compliance purposes, and only with your explicit consent where required.

3. How We Collect Your Data

phspin.com collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical data collected automatically when you access the Platform, including cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash and Maya.
• Publicly available sources: In limited circumstances, we may verify information against publicly available records for compliance purposes.

4. How We Use Your Personal Data

phspin.com uses your personal data for the following purposes:

• Account management: To register and maintain your phspin.com account, verify your identity, and manage your account settings and preferences.
• Service delivery: To provide access to games, process deposits and withdrawals, award bonuses, and deliver the core gaming experience on phspin.com.
• Legal and regulatory compliance: To fulfil obligations under Philippine law, including Anti-Money Laundering (AML) requirements, Know Your Customer (KYC) obligations, and PAGCOR regulatory requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, and other illegal or prohibited activities on the Platform.
• Responsible gaming: To monitor gaming behaviour, identify signs of problem gambling, and apply responsible gaming tools where appropriate.
• Customer support: To respond to your enquiries, resolve disputes, and improve the quality of our support services.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and security of phspin.com.
• Marketing communications: To send you promotional offers, newsletters, and updates about phspin.com — only where you have provided consent or where we have a legitimate interest to do so, and always with an easy opt-out mechanism.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and applicable data protection principles, phspin.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account registration, game access, and payment processing.
• Legal obligation: Processing required to comply with Philippine law, including AML regulations, tax obligations, and PAGCOR licensing requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement — where these interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and certain cookie-based tracking, where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

phspin.com does not sell or rent your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist with document verification and liveness checks to comply with our KYC obligations.
• Fraud prevention and AML partners: Services that help us detect and prevent money laundering, fraud, and other financial crimes.
• IT and infrastructure providers: Cloud hosting, database, and security service providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Where required by Philippine law, court order, or regulatory directive — including PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC).
• Professional advisers: Lawyers, auditors, and accountants where necessary for legal, compliance, or financial purposes, subject to professional confidentiality obligations.

All third parties with whom phspin.com shares personal data are required to handle that data in accordance with applicable data protection law and our contractual requirements.

7. Cookies & Tracking Technologies

phspin.com uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage, and support security functions. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled as they are required for login sessions, security tokens, and core functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and game history to personalise your experience on phspin.com.
• Analytics cookies: Collect anonymised data about how players use the Platform — such as pages visited and session duration — to help us improve performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorised login attempts.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of phspin.com. Strictly necessary cookies cannot be disabled without impacting your ability to use the Platform.

8. Data Retention

phspin.com retains personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and PAGCOR record-keeping requirements.
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Gaming history: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes.
• Support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

When personal data is no longer required, phspin.com will securely delete or anonymise it in accordance with our data disposal procedures.

9. Your Data Protection Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phspin.com:

• Right to be informed: The right to know what personal data we collect, how we use it, and with whom we share it — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your phspin.com account settings.
• 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 our legal retention obligations.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing. Where you object to marketing, we will cease processing your data for that purpose immediately.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format, and to transmit it to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 14. We will respond to all verified requests within thirty (30) days, as required by the Data Privacy Act.

10. Children's Privacy

phspin.com is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 21 years. The minimum age to register and use phspin.com is 21, in accordance with Philippine gambling regulations.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the data, and take appropriate action in accordance with our legal obligations. If you believe a minor has registered on phspin.com, please contact us immediately at the address in Section 14.

11. Security Measures

phspin.com implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and phspin.com servers.
• AES-256 encryption for sensitive data stored at rest, including financial information and identity documents.
• Multi-factor authentication (MFA) options for player accounts.
• Regular security audits, penetration testing, and vulnerability assessments.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Automated fraud detection and anomaly monitoring systems operating 24/7.
• Secure data disposal procedures for data that has reached the end of its retention period.

While phspin.com takes all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. We encourage you to use a strong, unique password for your phspin.com account and to enable any available security features.

12. Third-Party Links

The phspin.com Platform may contain references to third-party services, such as payment processors. Once you leave the phspin.com Platform and access a third-party service, this Privacy Policy no longer applies. phspin.com is not responsible for the privacy practices or content of third-party websites or services.

We encourage you to review the privacy policies of any third-party services you use in connection with your phspin.com account, particularly payment providers such as GCash and Maya.

13. Updates to This Privacy Policy

phspin.com reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When we make material changes, we will notify you by posting a prominent notice on the Platform and, where appropriate, by sending an email to your registered address.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically. Your continued use of phspin.com following the posting of changes constitutes your acceptance of the revised policy.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way phspin.com handles your personal data, please contact our Data Protection Officer (DPO):

Data Protection Officer — phspin.com
Email (plain text — not a clickable link):
privacy@phspincom.org

We aim to acknowledge all privacy-related enquiries within two (2) business days and to provide a substantive response within thirty (30) days of receipt, as required under the Data Privacy Act of 2012.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Data Privacy Act.