phskt Privacy Policy

1. Who We Are and How to Contact Us

phskt ("we", "us", "our", or the "Operator") is the operator of the online gaming platform accessible at https://phskt.cam. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, phskt acts as the Personal Information Controller in respect of the personal data of players and visitors collected through the phskt Platform.

Our designated Data Protection Officer (DPO) is responsible for overseeing this Policy and ensuring phskt's data processing activities comply with applicable Philippine data protection law. You may contact the phskt DPO at any time by emailing [email protected] with the subject line "Data Privacy Request — Attention DPO". All data privacy inquiries are logged and responded to within fifteen (15) calendar days of receipt.

2. Personal Data We Collect

2.1 Registration and Identity Data

When you register an account on phskt, we collect the following information that you provide directly:

• Full legal name as it appears on your government-issued identification;
• Date of birth (collected for mandatory age verification under PAGCOR regulations);
• Residential address within the Philippines;
• Valid Philippine mobile number;
• Email address;
• Username and encrypted password (passwords are never stored in plaintext).

2.2 Identity Verification (KYC) Data

As required by PAGCOR and Philippine anti-money laundering laws, phskt is legally obligated to verify the identity of all players before processing withdrawal requests. For KYC compliance, we collect:

• Copies of valid Philippine government-issued identification documents (PhilSys ID, passport, driver's license, UMID, PRC ID, voter's ID, or other PAGCOR-accepted identifiers);
• Selfie photographs taken while holding the identification document;
• Proof of current residential address (utility bill, bank statement, or government correspondence);
• Source of funds documentation when required by AML compliance thresholds;
• Tax Identification Number (TIN) where applicable under Philippine tax regulations.

2.3 Financial and Transaction Data

phskt collects and processes the following financial data in connection with deposit and withdrawal transactions:

• GCash mobile number or Maya account identifier used for transactions;
• Bank account details (account name, account number, bank name) provided for bank transfer transactions;
• Transaction amounts, dates, timestamps, and reference numbers;
• Cryptocurrency wallet addresses where USDT transactions are used;
• Complete transaction history associated with your phskt account.

2.4 Gameplay and Platform Activity Data

phskt automatically collects data about your activity on the Platform, including:

• Games played, bet amounts, game outcomes, and session durations;
• Login timestamps and account access history;
• Device type, operating system, screen resolution, and browser type;
• IP address and approximate geolocation data (used to verify Philippine-based access);
• Pages visited on the Platform and navigation behaviour;
• Customer support interactions, including chat transcripts and email correspondence.

3. How We Use Your Personal Data

phskt processes your personal data only for lawful, specified, and legitimate purposes. The table below summarises the primary processing activities and their purposes:

Processing Activity	Purpose	Data Categories Used
Account creation and management	To create and maintain your phskt player account	Registration data, contact information
Identity verification (KYC)	PAGCOR and AMLC legal compliance obligation	KYC documents, selfie photographs
Payment processing	To process deposits, withdrawals, and transaction records	Financial data, transaction history
Fraud prevention and AML monitoring	Legal obligation under RA 9160 (AMLA) and PAGCOR rules	All categories, gameplay data, IP data
Responsible gaming monitoring	Player protection and PAGCOR compliance	Gameplay data, session duration, deposit history
Customer support	To resolve queries, complaints, and disputes	Account data, support correspondence
Platform security and integrity	To detect, prevent, and respond to fraud and abuse	Device data, IP data, behavioural data
Legal and regulatory compliance	To comply with PAGCOR, NPC, AMLC, and BIR requirements	All categories as required by law
Service communications	Account notifications, security alerts, policy updates	Contact information, account data

phskt does not use your personal data to build profiles for sale to third-party advertisers, and we do not engage in the sale, rental, or brokerage of player personal data under any circumstances.

4. Legal Basis for Processing

4.1 Contractual Necessity

The majority of phskt's data processing activities are necessary for the performance of the contract between you and phskt (i.e., your player account agreement and these Terms & Conditions). Without processing your registration data, payment information, and account activity, phskt cannot provide the gaming services you have agreed to receive.

4.2 Legal Obligation

phskt is subject to mandatory data processing obligations under several Philippine laws, including the Anti-Money Laundering Act of 2001 (RA 9160 as amended), PAGCOR's operator licensing conditions, the Bureau of Internal Revenue's (BIR) tax reporting requirements, and the Data Privacy Act of 2012 (RA 10173). Processing activities required for compliance with these obligations are carried out under the legal basis of legal obligation.

4.3 Legitimate Interests

Certain processing activities — including fraud detection, platform security monitoring, and abuse prevention — are carried out on the basis of phskt's legitimate interests in maintaining a secure, fair, and compliant gaming platform. phskt has assessed that these legitimate interests are not overridden by the privacy rights and interests of data subjects, given the proportionate and targeted nature of the processing.

4.4 Consent

Where phskt relies on consent as a legal basis for processing (for example, for optional marketing communications), such consent is obtained separately, clearly, and freely. You have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Withdrawal of consent for optional processing will not affect your ability to use phskt's core services.

5. Cookies and Tracking Technologies

5.1 Types of Cookies Used

phskt uses cookies and similar tracking technologies on the Platform to ensure proper functionality, improve security, and analyse Platform usage. The categories of cookies we use include:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings and display options. These improve your experience but are not essential to Platform operation.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate and interact with the Platform. This data helps phskt identify usability issues and improve the Platform experience.
• Security and Fraud Prevention Cookies: Used to detect and prevent suspicious activity, including bot traffic, account takeover attempts, and fraudulent transactions.

5.2 Managing Cookies

You may control or disable non-essential cookies through your browser settings at any time. Instructions for managing cookies are available in the help documentation of all major browsers. Please note that disabling certain cookies may affect the functionality or performance of the phskt Platform. phskt's cookie consent manager, accessible through the Platform's settings interface, allows you to review and adjust your cookie preferences at any time.

6. Sharing Your Personal Data

6.1 Authorised Third-Party Service Providers

phskt shares personal data with carefully selected third-party service providers who process data on our behalf under strict contractual data processing agreements. These providers include:

• Payment processors: GCash (GXI Inc.), Maya (Voyager Innovations Inc.), and Philippine banking partners for processing deposits and withdrawals;
• KYC and identity verification providers: Third-party services that assist phskt in verifying government-issued identification documents;
• Game content providers: Licensed game studios (such as JILI, PG Soft, Evolution Gaming, and Pragmatic Play) that provide the games available on phskt — these providers receive only the minimum data required to deliver game services;
• Cloud infrastructure providers: Hosting and data storage services that maintain phskt's Platform infrastructure under data processing agreements that prohibit independent use of player data;
• Fraud prevention and security services: Third-party providers that assist phskt in identifying and preventing fraudulent activity on the Platform.

All third-party data processors are contractually prohibited from using phskt player data for any purpose other than the specific service they have been engaged to provide. phskt conducts due diligence on all data processors before engagement and reviews compliance on an ongoing basis.

6.2 Regulatory and Law Enforcement Disclosure

phskt is legally required to disclose player data to regulatory bodies and law enforcement agencies in certain circumstances. Mandatory disclosures may be made to PAGCOR as part of licensing and compliance oversight, the Anti-Money Laundering Council (AMLC) as required under the Anti-Money Laundering Act, the National Privacy Commission (NPC) in the event of a reportable personal data breach, the Bureau of Internal Revenue (BIR) for applicable tax reporting obligations, and Philippine law enforcement agencies pursuant to lawful court orders or subpoenas.

phskt will disclose only the minimum data required to satisfy its legal obligations and will, where legally permissible, notify affected players of any such disclosure.

6.3 No Sale of Personal Data

phskt does not, under any circumstances, sell, rent, lease, or broker player personal data to third parties for commercial, marketing, or advertising purposes. This prohibition is absolute and applies regardless of the jurisdiction of the potential recipient.

7. Data Retention Periods

phskt retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to overriding legal retention obligations. The primary retention periods applicable to phskt player data are:

• Account and identity data: Retained for the duration of the active account relationship, plus five (5) years following account closure, as required by PAGCOR licensing conditions and Philippine AML regulations;
• KYC documentation: Retained for a minimum of five (5) years from the date of the most recent transaction, in compliance with the Anti-Money Laundering Act;
• Financial and transaction records: Retained for five (5) years following the transaction date, as required by AMLC regulations and BIR record-keeping requirements;
• Gameplay activity data: Retained for three (3) years for responsible gaming monitoring, fraud prevention, and dispute resolution purposes;
• Customer support records: Retained for three (3) years from the date of the final interaction;
• Security and access logs: Retained for twelve (12) months for platform security monitoring purposes.

Following the expiry of applicable retention periods, phskt will securely delete or irreversibly anonymise the relevant data in accordance with recognised data destruction standards.

8. Your Rights Under Philippine Law

The Philippine Data Privacy Act of 2012 grants you the following rights in respect of your personal data held by phskt. You may exercise any of these rights by contacting phskt's Data Protection Officer:

• Right to be Informed: The right to be notified of how your personal data is being collected and processed before collection occurs or as soon as practicable thereafter;
• Right to Access: The right to request a copy of the personal data phskt holds about you, together with information about how it is being processed;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by phskt;
• Right to Erasure or Blocking: The right to request deletion or blocking of personal data that is no longer necessary, was collected unlawfully, or has been processed in breach of this Policy — subject to overriding legal retention obligations;
• Right to Object: The right to object to phskt processing your personal data based on legitimate interests, including processing for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format, and to transmit that data to another personal information controller where technically feasible;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phskt has violated your data privacy rights.

phskt will respond to all data subject rights requests within fifteen (15) calendar days. Where requests are complex or numerous, phskt may extend this period by a further thirty (30) days and will notify you of any extension within the initial fifteen-day response window.

9. Data Security Measures

phskt implements a comprehensive suite of technical and organisational security measures to protect player personal data against unauthorised access, disclosure, alteration, and destruction. Our security infrastructure includes:

• 256-bit TLS/SSL encryption for all data transmitted between your device and phskt's servers;
• AES-256 encryption at rest for all sensitive player data stored in phskt's databases;
• One-time password (OTP) two-factor authentication for account login;
• Role-based access control (RBAC) restricting internal access to player data on a strict need-to-know basis;
• Comprehensive audit logging of all internal access to player personal data;
• Regular third-party penetration testing and vulnerability assessments of the Platform;
• 24/7 security monitoring and automated threat detection systems;
• Incident response procedures compliant with NPC data breach notification requirements.

In the event of a personal data breach that is likely to result in risk to the rights and freedoms of affected players, phskt will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players as soon as practicable thereafter, in accordance with NPC Circular 16-03.

10. Children's Privacy

The phskt Platform is strictly intended for adults aged twenty-one (21) years and older, as mandated by PAGCOR regulations. phskt does not knowingly collect or process personal data relating to individuals under the age of 21. If phskt becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account.

Parents and guardians who believe that their minor child has registered an account or provided personal data to phskt are encouraged to contact our Data Protection Officer immediately. phskt will investigate and act upon such reports within five (5) business days.

11. Changes to This Policy

phskt reserves the right to update or modify this Privacy Policy at any time in response to changes in Philippine law, PAGCOR regulations, NPC guidance, or phskt's data processing practices. Material changes to this Policy will be communicated to registered players via email to the address associated with their account, and a notice will be displayed on the phskt Platform homepage.

The "Last Updated" date at the top of this Policy indicates the effective date of the most recent version. We encourage players to review this Policy periodically to remain informed of how phskt handles their personal data. Continued use of the phskt Platform following notification of material changes constitutes acceptance of the updated Policy.

Previous versions of this Privacy Policy are archived and available upon request by contacting the phskt Data Protection Officer.

12. Contact Our Data Protection Officer

For all data privacy inquiries, rights requests, or complaints related to phskt's handling of your personal data, please contact our designated Data Protection Officer using the details below:

Data Protection Officer, phskt
Email: [email protected]
Subject Line: "Data Privacy Request — Attention DPO"
Response Time: Within 15 calendar days of receipt

If you are not satisfied with phskt's response to a data privacy inquiry or believe that we have violated your rights under the Philippine Data Privacy Act, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines through its official complaint channels.