phmanalo Privacy Policy

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, the data controller responsible for the personal information collected through the phmanalo platform at phmanalo.net is the operator of phmanalo ("phmanalo," "we," "us," or "our").

As data controller, phmanalo determines the purposes and means by which your personal data is processed, and bears the corresponding obligations under Philippine data protection law. phmanalo has designated a data protection officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection regulations.

phmanalo collects personal data across several categories, depending on the nature of your interaction with the platform. The following table summarises the categories of data collected and the primary purpose of collection:

phmanalo does not intentionally collect sensitive personal information beyond what is necessary for KYC compliance, unless expressly required by PAGCOR or the Anti-Money Laundering Council (AMLC). Where sensitive data is collected (e.g., facial images on government IDs), it is processed solely for identity verification purposes and is not used for biometric profiling.

phmanalo collects personal data through the following means:

• Directly from you — when you register an account on phmanalo, complete your profile, submit KYC documents, deposit or withdraw funds, contact phmanalo Support, or otherwise actively interact with the platform.
• Automatically through platform use — when you browse, log in to, or use the phmanalo platform, certain technical data is automatically generated and collected, including IP address, device identifiers, session data, and browser characteristics. This collection occurs through server logs, cookies, and similar tracking technologies described in Section 7.
• From payment service providers — when you initiate a deposit or withdrawal via GCash, Maya, or a Philippine bank, phmanalo receives transaction reference data from the payment provider to confirm and reconcile the transaction. phmanalo does not receive or store your full GCash PIN, bank passwords, or other payment authentication credentials.
• From identity verification services — phmanalo may use third-party KYC verification providers to validate government-issued Philippine identification documents. These providers are contractually bound to process data only for verification purposes and in compliance with Philippine data protection law.
• From regulatory authorities — phmanalo may receive information from PAGCOR, the AMLC, or other Philippine regulatory bodies as part of licensing, compliance monitoring, or investigation processes.

phmanalo processes your personal data on one or more of the following legal bases, as recognised under the Data Privacy Act of 2012 and its Implementing Rules:

• Contractual Necessity. Processing that is necessary for the performance of the Terms & Conditions you agreed to when creating your phmanalo account — including account management, deposit and withdrawal processing, game delivery, and customer support.
• Legal Obligation. Processing required to comply with phmanalo's obligations under Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and any applicable PAGCOR circulars and directives.
• Legitimate Interests. Processing necessary for phmanalo's legitimate business interests, including fraud prevention, platform security, technical improvement, and responsible gaming monitoring — where these interests are not overridden by your data subject rights.
• Consent. Processing based on your freely given, specific, and informed consent — primarily for optional marketing communications. You may withdraw consent for marketing at any time without affecting the lawfulness of prior processing.

phmanalo uses your personal data for the following specific purposes:

• Account Management: To create, maintain, and administer your phmanalo account, including processing your login, managing your wallet balance, and maintaining your gaming history.
• Identity and Age Verification: To verify that you are at least 21 years of age and to confirm your identity in compliance with PAGCOR requirements and the Anti-Money Laundering Act.
• Transaction Processing: To process deposits received via GCash, Maya, GrabPay, QR Ph, BPI, BDO, Metrobank, InstaPay, PesoNet, and 7-Eleven CLiQQ, and to process withdrawal requests to your nominated Philippine payment method.
• Regulatory Compliance: To maintain the transaction, identity, and gaming activity records required by PAGCOR, the AMLC, and other applicable Philippine regulatory authorities, and to respond to regulatory inquiries or investigations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, multi-accounting, money laundering, use of automated bots, and other security threats to the phmanalo platform and its players.
• Responsible Gaming: To monitor gaming activity patterns that may indicate problem gambling behaviour, and to apply responsible gaming tools (such as deposit limits or self-exclusion) in accordance with your instructions or phmanalo's responsible gaming obligations.
• Customer Support: To provide assistance, investigate complaints, and resolve disputes related to your phmanalo account, transactions, or gameplay.
• Marketing Communications (with consent): To send you promotional offers, bonus notifications, and platform updates via email or SMS, where you have consented to receive such communications.
• Platform Improvement: To analyse aggregated and anonymised usage data for the purpose of improving the phmanalo platform, enhancing the user experience, and making informed product decisions.

phmanalo does not sell, rent, or trade your personal data to any third party for their own commercial or marketing purposes. phmanalo shares your data only in the following circumstances:

• Service Providers (Data Processors). phmanalo engages third-party service providers who process personal data on our behalf, strictly for the purposes of providing services to phmanalo — including KYC verification providers, payment processing partners (GCash, Maya, BPI, BDO, Metrobank, etc.), platform hosting and cloud infrastructure providers, and customer support technology providers. All such third parties are contractually required to implement appropriate data security measures and to process data only according to phmanalo's instructions.
• Game Providers. phmanalo's third-party game studios (e.g., Pragmatic Play, NetEnt) may receive limited session data necessary to deliver and manage the game experience. Game providers do not receive your identity documents, financial details, or contact information.
• Regulatory and Law Enforcement Authorities. phmanalo is required by Philippine law to disclose personal data and transaction records to PAGCOR, the AMLC, the National Privacy Commission, the Bureau of Internal Revenue (BIR), and other Philippine regulatory or law enforcement authorities when required by law, legal process, or an official regulatory directive.
• Business Transfers. In the event of a merger, acquisition, or transfer of the phmanalo business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections set out in this Policy. phmanalo will notify affected users of any such transfer in advance where practicable.
• With Your Consent. In any other circumstances not described above, phmanalo will share your data only with your express prior consent.

The phmanalo platform uses cookies and similar tracking technologies to support platform functionality, security, and analytics. Cookies are small text files stored on your device when you access phmanalo.net. The following categories of cookies are used on the phmanalo platform:

• Strictly Necessary Cookies. These cookies are essential for the phmanalo platform to function. They maintain your login session, process deposits and withdrawals, and enable core security features. The platform cannot function without these cookies, and they cannot be disabled.
• Functional Cookies. These cookies remember your preferences — such as your preferred language or display settings — to provide a more personalised phmanalo experience. They are not used for advertising purposes.
• Analytics Cookies. phmanalo uses anonymised analytics data to understand how players navigate and use the platform. This information is used solely to improve platform performance and user experience. Analytics data is aggregated and does not identify individual users.
• Security Cookies. phmanalo uses session and device fingerprinting data to detect unauthorised access attempts, account takeovers, and suspicious login patterns. This is a security feature and cannot be disabled without affecting account security.

You may manage cookie settings through your browser. Disabling strictly necessary cookies will prevent you from accessing the phmanalo platform. Disabling functional or analytics cookies will not prevent access but may affect your user experience.

phmanalo retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable Philippine law and regulatory requirements. The following indicative retention periods apply:

Upon expiry of the applicable retention period, phmanalo will securely delete or anonymise your personal data in a manner that prevents its reconstruction or re-identification.

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

• Industry-standard SSL/TLS encryption for all data transmitted between your device and phmanalo's servers;
• Encryption of sensitive data at rest, including financial data and KYC documents;
• Hashing of all account passwords using modern cryptographic algorithms — phmanalo personnel cannot read your password;
• Role-based access controls ensuring that phmanalo personnel can only access personal data necessary for their specific job function;
• Multi-factor authentication and privileged access management for phmanalo's internal systems;
• Continuous monitoring of platform infrastructure for security threats and intrusion attempts;
• Regular security assessments and penetration testing of the phmanalo platform;
• Staff training on data protection obligations and information security best practices.

The phmanalo platform may engage third-party service providers — including game studios, cloud infrastructure providers, and KYC verification services — whose systems are located outside the Republic of the Philippines. In such cases, your personal data may be processed or stored in countries other than the Philippines.

Where personal data is transferred outside the Philippines, phmanalo ensures that appropriate safeguards are in place in accordance with the Data Privacy Act and NPC issuances. These safeguards may include:

• Data processing agreements with receiving parties that impose data protection obligations equivalent to those under Philippine law;
• Transfers to recipients located in countries that the NPC has recognised as providing an adequate level of personal data protection;
• Binding corporate rules or equivalent contractual arrangements that ensure consistent data protection standards across the receiving entity's operations.

phmanalo does not transfer your financial data, KYC documents, or sensitive personal information to international recipients except where strictly necessary for the purposes described in this Policy and subject to the safeguards described above.

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phmanalo:

• Right to Be Informed. The right to be informed of the details of how phmanalo collects, processes, and retains your personal data — which this Privacy Policy fulfils.
• Right to Access. The right to obtain a copy of the personal data phmanalo holds about you, and information about how it is processed. Requests for data access may be submitted to phmanalo Support at [email protected].
• Right to Correction. The right to request correction of any inaccurate or incomplete personal data phmanalo holds about you. You may update basic account information directly through your phmanalo account settings.
• Right to Erasure or Blocking. The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, or where processing is unlawful. This right is subject to phmanalo's legal retention obligations under Philippine regulatory law.
• Right to Object. The right to object to phmanalo's processing of your personal data where processing is based on legitimate interests, including the right to object to direct marketing communications at any time.
• Right to Data Portability. The right to receive a structured, machine-readable copy of personal data you have provided to phmanalo, where technically feasible and processing is based on consent or contract.
• Right to Damages. The right to be indemnified for any damages sustained as a result of phmanalo's violation of the Data Privacy Act.
• Right to Complain. The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phmanalo has violated your data privacy rights.

To exercise any of these rights, please submit a written request to phmanalo's Data Protection Officer at [email protected]. phmanalo will acknowledge your request within 5 business days and provide a substantive response within 30 days. Complex requests may require additional time, in which case phmanalo will notify you of the extended timeline.

The phmanalo platform is strictly restricted to individuals who are at least 21 years of age, in accordance with PAGCOR's minimum age requirements for online gaming in the Philippines. phmanalo does not knowingly collect personal data from or about any person under the age of 21.

If phmanalo becomes aware that personal data has been collected from a person under 21 years of age — whether through misrepresentation during registration or any other means — the associated account will be immediately suspended, all data will be reviewed in accordance with applicable law, and any funds held in the account will be handled in accordance with PAGCOR's guidance on underage gambling.

If you are a parent or guardian and believe that a minor in your household has accessed or registered on the phmanalo platform using your or another person's credentials, please contact phmanalo Support immediately at [email protected].

The phmanalo platform does not contain links to external third-party websites for general browsing purposes. Any third-party integrations that appear on the platform — such as game launchers from third-party studios or payment provider interfaces — are operated under separate privacy policies maintained by those respective providers.

phmanalo is not responsible for the privacy practices of third-party game studios, payment service providers, or any other external entities whose services are accessed through or in connection with the phmanalo platform. Players are encouraged to review the privacy policies of any third-party service they interact with during their use of phmanalo.

phmanalo may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, PAGCOR requirements, or platform features. The effective date at the top of this page will always indicate when the Policy was last revised.

Where changes are material — meaning they significantly affect your rights or how phmanalo uses your data — phmanalo will notify registered players by email to the address on file, or by a prominent notice displayed upon next login to the phmanalo platform, at least 15 days before the changes take effect.

Continued use of the phmanalo platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of and agreement to the changes. If you do not agree to the revised Privacy Policy, you must cease using the platform and may request account closure by contacting phmanalo Support.

For all privacy-related inquiries, data subject access requests, consent withdrawals, or complaints regarding phmanalo's data processing practices, please contact phmanalo's Data Protection Officer:

If you are not satisfied with phmanalo's response to your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government authority responsible for administering and enforcing the Data Privacy Act of 2012 in the Philippines.