Privacy Policy

1.1. phww Casino, operating at phww.vu, is a PAGCOR-licensed online gaming and sports betting platform serving Filipino players throughout the Republic of the Philippines. phww is the data controller responsible for the personal information collected and processed through the phww platform and website.

1.2. This Privacy Policy applies to all personal data collected in connection with: the registration and maintenance of player Accounts; the use of any game, sportsbook, or betting service offered by phww; deposits, withdrawals, and other financial transactions; customer support interactions; marketing communications; and any other use of the phww website at phww.vu.

1.3. This Policy is published in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC) of the Philippines. phww is registered with the NPC as a personal information controller.

1.4. By creating an Account on phww or by continuing to use the phww platform after this Policy becomes effective, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, you must not register an Account or use the Services.

2.1. phww collects the following categories of personal data, depending on how you interact with the platform:

2.2. phww does not collect sensitive personal information beyond what is strictly necessary for PAGCOR KYC compliance and responsible gaming obligations. Specifically, phww does not collect health information, religious affiliation, or political views unless such information is voluntarily disclosed in a support interaction, in which case it will be handled with heightened care and not used for profiling or marketing purposes.

3.1. phww collects personal data through the following means:

• Direct collection at registration: Information you provide when creating your phww Account, including name, mobile number, email, and date of birth.
• KYC verification process: Identity documents and selfies submitted through phww's secure KYC portal, which is operated in partnership with a certified third-party identity verification provider.
• Payment transactions: Transaction data generated when you deposit or withdraw using GCash, Maya, BPI, BDO, Metrobank, InstaPay, PesoNet, 7-Eleven CLiQQ, Coins.ph, or USDT TRC20.
• Platform activity: Game session data, betting history, and account activity automatically recorded by the phww platform infrastructure during your use of the Services.
• Technical collection: IP addresses, device fingerprints, and session identifiers collected automatically through phww's servers and security systems for fraud detection and access control purposes.
• Cookies and similar technologies: As described in Section 9 of this Policy.
• Third-party sources: In limited circumstances, phww may receive data from PAGCOR (regulatory flags), fraud prevention services, or payment processors to supplement its own records for compliance purposes.

4.1. phww processes personal data under the following legal bases as recognised by the Data Privacy Act of 2012 and the National Privacy Commission:

• Performance of a contract: Processing necessary to operate your phww Account, deliver the Services, process payments, and fulfil our contractual obligations to you as set out in the phww Terms and Conditions.
• Compliance with a legal obligation: Processing required to comply with phww's PAGCOR licence conditions, Republic Act No. 9160 (the Anti-Money Laundering Act), Republic Act No. 10365 (AMLA amendments), and other applicable Philippine statutes and regulations. This includes mandatory KYC verification, transaction monitoring, and AMLC (Anti-Money Laundering Council) reporting.
• Legitimate interests: Processing for fraud detection, platform security, abuse prevention, responsible gaming monitoring, and improvement of the Services, where those interests are not overridden by your data protection rights.
• Consent: Processing for optional marketing communications, where you have expressly opted in. Consent may be withdrawn at any time as described in Section 13.

5.1. phww uses the personal data it collects for the following specific purposes:

1. Account registration and management: Creating and maintaining your phww Account, verifying your identity and eligibility, and delivering the Services you have requested.
2. KYC and age verification: Confirming that you are 21 years of age or above, as required by PAGCOR and Philippine gambling law, before enabling real-money play or financial transactions.
3. Payment processing: Facilitating deposits and withdrawals through your selected payment method (GCash, Maya, bank transfer, etc.), and maintaining accurate financial records of all transactions.
4. Regulatory compliance: Meeting phww's obligations under its PAGCOR licence, the Anti-Money Laundering Act, and related regulations — including filing Suspicious Transaction Reports (STRs) and Covered Transaction Reports (CTRs) with the AMLC where legally required.
5. Responsible gaming: Monitoring account activity for signs of problem gambling behaviour, enforcing player-set deposit and loss limits, processing cooling-off and self-exclusion requests, and complying with PAGCOR's responsible gaming requirements.
6. Fraud prevention and security: Detecting and preventing fraudulent activity, bonus abuse, account takeover attempts, and other security threats to the platform and its players.
7. Customer support: Responding to your support requests, complaints, and inquiries, and maintaining records of those interactions for quality assurance and dispute resolution purposes.
8. Platform improvement: Analysing aggregated and anonymised usage data to improve game selection, user experience, payment options, and platform performance.
9. Marketing and promotions: Sending you information about phww promotions, bonuses, and new games, only where you have consented to receive such communications.

6.1. phww shares personal data only in the following limited and controlled circumstances:

• PAGCOR: As phww's licensing authority, PAGCOR has the right to access player data as part of its audit and regulatory oversight functions. phww is legally obligated to provide such access upon request.
• Anti-Money Laundering Council (AMLC): phww is required by law to file Covered Transaction Reports for cash transactions exceeding ₱500,000 and Suspicious Transaction Reports for transactions that exhibit indicators of money laundering or terrorist financing, regardless of amount.
• KYC / Identity verification providers: phww uses a PAGCOR-approved third-party identity verification platform to process KYC document submissions. This provider operates under a data processing agreement with phww and is prohibited from using phww player data for any purpose other than identity verification.
• Payment processors: GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment service providers receive transaction data necessary to process your deposits and withdrawals.
• Game software providers: phww's game providers (including live dealer studios) receive the minimum data necessary to deliver the game to your account — typically an anonymised session token. They do not receive your full personal profile unless you are playing in a specifically branded live table environment.
• Fraud prevention and security services: phww uses third-party fraud detection platforms that receive IP addresses, device fingerprints, and transaction metadata to identify suspicious patterns. These services are bound by contractual obligations not to use phww data for unrelated purposes.
• Law enforcement and courts: phww will disclose personal data to Philippine law enforcement agencies, courts, or other public authorities where required by a valid legal order, subpoena, or applicable law.
• Professional advisers: phww's lawyers, auditors, and regulatory consultants may access personal data to the minimum extent necessary to provide their professional services, subject to professional confidentiality obligations.

6.2. All third-party service providers who process phww player data do so under written data processing agreements that require them to maintain appropriate technical and organisational security measures and restrict use of the data to the specified purpose only.

7.1. phww retains personal data for the minimum period necessary to fulfil the purpose for which it was collected and to comply with applicable legal and regulatory obligations. The following retention schedule applies:

7.2. Where a legal obligation requires retention beyond the periods stated above (for example, in the event of an ongoing investigation or legal proceeding), data will be retained for the duration of that obligation. phww will not retain personal data beyond what is legally required or what is necessary for legitimate operational purposes.

7.3. Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

8.1. phww implements technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your device and phww's servers is encrypted using TLS 1.3 with 256-bit AES encryption — the same standard used by major Philippine banks for online banking.
• Encryption at rest: Sensitive personal data including KYC documents and financial records stored on phww's servers is encrypted at rest using AES-256.
• Access controls: Strict role-based access controls limit phww staff access to personal data to the minimum necessary for each role. Access is logged and audited regularly.
• Two-factor authentication: phww offers and recommends 2FA for all player accounts to reduce the risk of unauthorised account access.
• Session management: Automatic session timeout after 30 minutes of inactivity, with re-authentication required to resume.
• Penetration testing: Regular independent security audits and penetration tests of phww's platform infrastructure.
• Data breach response plan: phww maintains a documented personal data breach response procedure in accordance with NPC requirements, including notification obligations within 72 hours of discovery of a breach that poses a real risk to data subjects.

8.2. While phww takes reasonable and appropriate security measures, no online system is completely immune from security incidents. Players are encouraged to use a strong, unique password for their phww Account, enable 2FA, and report any suspected unauthorised access to [email protected] immediately.

9.1. phww uses cookies and similar technologies (local storage, session tokens) on the phww.vu website and platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function — authentication session cookies, security tokens, load balancing identifiers. These cannot be disabled without preventing you from using the platform.
• Functional cookies: Remember your preferences such as language settings, game lobby display preferences, and responsible gaming settings within a session.
• Analytical cookies: Collect anonymised data about how players navigate the platform — which pages are visited, which games are opened, session duration — to help phww improve the user experience. This data is aggregated and does not identify individual players.
• Security cookies: Used by phww's fraud detection and bot prevention systems to distinguish legitimate human users from automated scripts.

9.2. phww does not use third-party advertising or retargeting cookies. Cookies set on phww.vu are exclusively for platform operation, security, and analytics purposes — not for advertising networks or data brokers.

9.3. Players may manage cookie preferences through their browser settings. Note that disabling strictly necessary cookies will impair or prevent your use of the phww platform. Analytics cookies may be disabled without affecting platform functionality.

10.1. Under the Data Privacy Act of 2012, phww players have the following rights in relation to their personal data. To exercise any of these rights, submit a written request to phww's Data Protection Officer at [email protected]. Requests will be acknowledged within five (5) business days and fulfilled within thirty (30) days, subject to identity verification and any applicable legal exceptions.

10.2. phww may be required to retain certain personal data notwithstanding an erasure request where retention is mandated by PAGCOR licence conditions, the Anti-Money Laundering Act, or other applicable Philippine law. In such cases, phww will notify you of the specific legal ground for continued retention.

11.1. The phww platform is intended exclusively for adults aged 21 years or above. phww does not knowingly collect, process, or retain personal data from persons under the age of 21. The mandatory KYC process, which requires a valid Philippine government-issued ID, is specifically designed to prevent underage access.

11.2. If phww becomes aware that personal data belonging to a person under 21 has been collected — whether through a registration bypass, false ID, or any other means — phww will immediately close the associated Account, void all transactions, and securely delete the personal data involved, subject only to any overriding legal reporting obligation.

11.3. If you believe that a person under the age of 21 has registered on phww or that phww holds personal data of a minor, please notify phww immediately at [email protected]. phww will investigate the report promptly.

12.1. phww's primary data processing infrastructure is located within the Philippines. Some of phww's third-party service providers, including game software providers and identity verification platforms, may process data in other jurisdictions including Singapore, Malta, Gibraltar, or the Isle of Man — jurisdictions commonly used by regulated gaming operators.

12.2. Where personal data is transferred outside the Philippines, phww ensures that such transfers are made only to countries with adequate data protection frameworks or, alternatively, only to recipients bound by contractual data protection clauses that require protection equivalent to that provided under the Data Privacy Act of 2012. phww does not transfer personal data to any country that cannot provide such assurances.

12.3. All cross-border data transfer arrangements are subject to review and approval by phww's Data Protection Officer and, where required, are registered with the National Privacy Commission.

13.1. phww sends marketing communications — including bonus offers, promotional emails, and new game announcements — only to players who have expressly opted in to receive such communications at the time of registration or through their Account settings.

13.2. You may withdraw consent to marketing communications at any time by:

• Clicking the unsubscribe link in any phww marketing email;
• Updating your communication preferences in your phww Account settings under "Notifications"; or
• Contacting phww support at [email protected] with an unsubscribe request.

13.3. Withdrawal of marketing consent will be processed within five (5) business days. Note that opting out of marketing communications does not affect transactional communications — phww will continue to send you Account-related emails regarding deposits, withdrawals, security alerts, and required regulatory notices regardless of your marketing preference.

13.4. phww does not engage in cold marketing to non-registered individuals or purchase marketing lists. All phww marketing is directed exclusively at its own registered player base who have consented to receive it.

14.1. phww reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, phww's data processing practices, or platform functionality. The current version of the Policy is always accessible at phww.vu/privacy-policy and displays the effective date of the most recent revision.

14.2. For material changes that significantly affect how phww processes your personal data, phww will provide advance notice of at least fourteen (14) days via email to your registered Account address and through a prominent notice on the phww platform login screen.

14.3. Your continued use of the phww platform after the effective date of any amended Privacy Policy constitutes your acknowledgement of and agreement to the updated terms. If you do not accept the amended Policy, you should close your Account and cease using the Services before the effective date.

15.1. phww has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. The DPO is the primary point of contact for all personal data-related inquiries, access requests, erasure requests, and complaints.

15.2. To contact phww's Data Protection Officer:

• Email (plain text — not a clickable link): [email protected] — Subject line: "Data Privacy Request"
• Live Chat: Available 24/7 through the phww platform at phww.vu — identify your query as a privacy request
• Response time: All privacy-related requests acknowledged within five (5) business days; substantively addressed within thirty (30) days

15.3. If you are not satisfied with phww's response to your privacy request or complaint, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines. Information on the NPC complaint process is available on the NPC's official website.

15.4. This Privacy Policy was last updated on 1 January 2026 and supersedes all prior versions published by phww. In the event of any inconsistency between this Policy and a prior version, this Policy governs.