phmova Privacy Policy

This Privacy Policy ("Policy") describes how phmova ("phmova," "we," "us," "our") collects, uses, discloses, and safeguards personal information obtained from users ("you," "Player") of the phmova online gaming platform at phmova.net and all associated services (collectively, the "Platform"). This Policy forms part of phmova's Terms & Conditions and should be read alongside them. By registering an account or using the Platform, you consent to the data practices described in this Policy.

phmova is committed to protecting your privacy in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). We take our obligations as a Personal Information Controller seriously and have implemented appropriate technical and organizational measures to protect your data.

1. Who We Are

phmova is an online gaming platform operating under PAGCOR's regulatory framework, serving Filipino players across the Philippines including Metro Manila, Cebu, Davao, Quezon City, and Makati. For the purposes of the Data Privacy Act of 2012, phmova acts as the Personal Information Controller in respect of the personal data you provide when using the Platform.

If you have any questions or concerns about how phmova handles your personal data, please contact our Data Protection Officer using the details provided in Section 13 of this Policy.

2. Personal Data We Collect

phmova collects personal data that is necessary for the provision of our services, compliance with legal and regulatory obligations, and the improvement of the Platform. The categories of personal data we collect include:

2.1 Registration and Identity Data

• 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 and email address;
• Username and encrypted password;
• Residential address in the Philippines.

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., PhilSys National ID, Philippine passport, driver's license, SSS/GSIS ID, Voter's ID);
• Proof of address documents (e.g., utility bills, bank statements);
• Source of funds documentation where required by PAGCOR AML regulations;
• Selfie or facial verification image where required for identity confirmation.

2.3 Financial and Transaction Data

• GCash account number or PayMaya/Maya account details used for deposits and withdrawals;
• Bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) where bank transfer is used;
• Debit card details (card number, expiry, billing address) where debit card is used;
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method used;
• Account balance and wagering history.

2.4 Gaming and Behavioral Data

• Game session data including games played, bets placed, outcomes, and session duration;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status);
• Customer support interaction records.

2.5 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Cookies and similar tracking technologies (see Section 6);
• Login timestamps and session activity logs.

3. How We Use Your Personal Data

phmova uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your phmova account, including verifying your identity and age (21+) as required by PAGCOR regulations;
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the core features of the phmova Platform;
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Data Privacy Act of 2012, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine laws;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account abuse, and other prohibited conduct;
• Responsible Gaming: To monitor gaming behavior, enforce responsible gaming tools, and identify players who may be at risk of gambling-related harm;
• Customer Support: To respond to your inquiries, complaints, and support requests;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time;
• Platform Improvement: To analyze usage patterns, improve game offerings, and enhance the overall user experience on the phmova Platform.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform the contract between you and phmova (i.e., to provide the gaming services you have registered for);
• Legal Obligation: Processing is required to comply with PAGCOR regulations, AMLA obligations, NPC requirements, and other applicable Philippine laws;
• Legitimate Interests: Processing is necessary for phmova's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights;
• Consent: For marketing communications and certain non-essential cookies, processing is based on your explicit consent, which you may withdraw at any time.

5. Sharing Your Personal Data

phmova does not sell your personal data to third parties. We may share your personal data with the following categories of recipients in the circumstances described:

• PAGCOR and Regulatory Authorities: phmova is required to share player data with PAGCOR and other Philippine regulatory bodies as part of our licensing obligations and in response to lawful regulatory requests;
• Law Enforcement and Government Agencies: phmova may disclose personal data to the Anti-Money Laundering Council (AMLC), National Bureau of Investigation (NBI), Philippine National Police (PNP), or other government agencies where required by law or court order;
• Payment Service Providers: We share necessary financial data with GCash, PayMaya/Maya, and partner banks to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations;
• KYC and Identity Verification Providers: We may use third-party identity verification services to assist with KYC compliance. These providers process your data solely for verification purposes under strict data processing agreements;
• Technology and Infrastructure Providers: phmova uses cloud hosting, cybersecurity, and analytics service providers who may process personal data on our behalf as data processors under binding contractual obligations;
• Game Software Providers: Game providers may receive anonymized or pseudonymized session data for game performance and fairness auditing purposes.

All third parties with whom phmova shares personal data are required to handle that data in accordance with applicable Philippine data protection law and phmova's data processing standards.

6. Cookies and Tracking Technologies

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

Types of cookies we use:

• Strictly Necessary Cookies: Required for the Platform to function, including session management, login authentication, and security features. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings and responsible gaming tool configurations;
• Analytics Cookies: Help us understand how players use the Platform so we can improve it. Analytics data is aggregated and anonymized where possible;
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality. For strictly necessary cookies, no consent is required as they are essential to service delivery.

7. Data Retention

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

• Account and KYC Data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AMLA obligations;
• Transaction Records: Retained for a minimum of five (5) years in compliance with AMLA record-keeping requirements;
• Gaming Session Data: Retained for up to three (3) years for dispute resolution and regulatory audit purposes;
• Marketing Data: Retained until you withdraw consent or for up to two (2) years of inactivity, whichever is earlier;
• Support Records: Retained for up to three (3) years following resolution of the relevant inquiry.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with phmova's data disposal procedures.

8. Your Data Privacy Rights

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

• Right to Be Informed: The right to be informed of how your personal data is being processed, as set out in this Policy;
• Right of Access: The right to request a copy of the personal data phmova holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to phmova's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact phmova's Data Protection Officer using the contact details in Section 13. We will respond to all verified requests within thirty (30) days in accordance with NPC guidelines.

9. Data Security

phmova implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the phmova Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of Platform infrastructure;
• Multi-factor authentication options for player accounts;
• Incident response procedures for detecting and responding to data security breaches.

In the event of a personal data breach that is likely to result in harm to affected individuals, phmova will notify the NPC and affected players in accordance with the Data Privacy Act of 2012 and NPC Circular 16-03.

10. Children's Privacy

The phmova Platform is strictly for persons aged 21 years and older. phmova does not knowingly collect personal data from persons under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will immediately close the relevant account and delete the associated personal data. If you believe a person under 21 has registered on the phmova Platform, please contact us immediately using the details in Section 13.

11. Third-Party Links

The phmova Platform may contain links to third-party websites or services. This Privacy Policy applies solely to the phmova Platform. phmova is not responsible for the privacy practices of third-party websites and encourages you to review the privacy policies of any third-party sites you visit.

12. Changes to This Privacy Policy

phmova reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered players via email or in-platform notification at least fourteen (14) days before the changes take effect. The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

13. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or phmova's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Data Privacy Request – [Your Full Name]
• Response Time: Within 30 days of receipt of a verified request

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with phmova's response to your data privacy concern.