phearn Privacy Policy

1.1 For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, phearn is the personal information controller in respect of all personal data collected through the Platform.

1.2 phearn operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). In fulfilling its PAGCOR compliance obligations, phearn may be required to share certain player data with PAGCOR as mandated by regulation.

1.3 phearn has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. The DPO may be contacted at the email address provided in Section 13 of this Policy.

phearn collects the following categories of personal data from players and visitors:

2.1 Account Registration Data

When you create a phearn account, we collect:

2.2 KYC Verification Data

To comply with PAGCOR regulations and anti-money laundering requirements, phearn collects the following during KYC verification:

• Full legal name (as appearing on government-issued ID);
• Government-issued Philippine ID number and document type (PhilSys, UMID, Driver's License, Passport, SSS/GSIS ID, or Voter's ID);
• ID document image (front and back where applicable);
• Selfie or live photograph for liveness verification;
• Proof of address documentation where required.

2.3 Financial Data

For deposit and withdrawal processing, phearn collects:

• GCash or PayMaya mobile number;
• Bank account name, number, and branch for bank transfer transactions (BDO, BPI, Metrobank, UnionBank);
• Transaction reference numbers and amounts;
• Deposit and withdrawal history.

2.4 Gaming Activity Data

• Game history, bet amounts, win/loss records, and session duration;
• Active bonuses, wagering progress, and promotion participation;
• Responsible gaming settings, including deposit limits and self-exclusion status.

2.5 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Session timestamps and login history;
• Cookie identifiers and similar tracking data (see Section 7).

2.6 Communications Data

• Content of live chat sessions with phearn support staff;
• Email correspondence and support ticket content;
• Feedback, complaint records, and dispute documentation.

phearn collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to a survey;
• Automatically — through cookies, server logs, and similar tracking technologies as you navigate the Platform;
• From third-party payment providers — GCash, PayMaya, and banking partners transmit transaction confirmation data to phearn upon successful payment processing;
• From identity verification services — phearn may use third-party KYC platforms to verify government-issued ID documents and conduct liveness checks;
• From PAGCOR and regulatory authorities — where legally required, phearn may receive or be directed to collect specific data by its regulator.

phearn processes your personal data on the following legal bases as provided under the Data Privacy Act of 2012 and its implementing rules:

• Contractual necessity — processing your account registration, deposits, withdrawals, and gaming activity is necessary to fulfill our service contract with you;
• Legal obligation — PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act require phearn to collect, verify, and retain certain categories of data;
• Legitimate interests — phearn has a legitimate interest in detecting fraud, maintaining platform security, and analyzing aggregate usage data to improve services, provided these interests do not override your fundamental privacy rights;
• Consent — where required by law or where we seek to use your data for optional purposes (such as direct marketing communications), we will seek your explicit consent and honor your right to withdraw it at any time.

phearn uses the personal data it collects for the following purposes:

• To create, manage, and maintain your player Account;
• To verify your identity and age in compliance with PAGCOR requirements (21+ enforcement);
• To process deposits and withdrawals via GCash, PayMaya, BDO, BPI, Metrobank, and UnionBank;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activity;
• To operate and improve the Platform, including personalization of game recommendations and user interface;
• To administer bonuses, promotions, and the phearn loyalty program;
• To provide customer support and resolve disputes;
• To send transactional communications, including deposit confirmations, withdrawal notifications, and security alerts;
• To comply with applicable law, PAGCOR directives, and court orders;
• To operate responsible gaming tools, including deposit limit enforcement and self-exclusion management;
• To send promotional communications where you have provided consent and have not opted out.

6.1 phearn does not sell your personal data. We share your personal data only with the categories of third parties described below, and only to the extent necessary for the stated purpose.

6.2 Categories of third parties with whom phearn shares data:

• Payment processors — GCash, PayMaya, BDO, BPI, Metrobank, and UnionBank receive transaction data necessary to execute deposits and withdrawals;
• KYC and identity verification providers — third-party services that assist phearn in verifying government-issued IDs and performing liveness checks during the KYC process;
• Game software providers — JILI Games, Pragmatic Play, and other certified studios receive anonymized or session-level data necessary to deliver game services and RNG audits;
• Cloud hosting and infrastructure providers — phearn's servers and data are hosted on cloud infrastructure operated by certified third-party providers under data processing agreements;
• PAGCOR and law enforcement — phearn shares data with PAGCOR as required by its operating license, and with Philippine law enforcement agencies where legally compelled by valid court order or lawful demand;
• Professional advisors — lawyers, auditors, and compliance consultants engaged by phearn under strict confidentiality obligations.

6.3 All third parties engaged by phearn as personal information processors are required to enter into data processing agreements obligating them to process data only as instructed by phearn, maintain appropriate security measures, and comply with applicable Philippine data protection law.

6.4 phearn does not transfer your personal data outside the Philippines without ensuring that equivalent data protection standards are in place, as required by the NPC.

7.1 phearn uses cookies and similar technologies on phearn.asia to operate the Platform, maintain session state, detect fraud, and analyze usage patterns. Cookies are small data files placed on your device when you access the Platform.

7.2 phearn uses the following categories of cookies:

• Strictly necessary cookies — essential for the Platform to function, including authentication session management and security token storage. These cannot be disabled without preventing Platform access;
• Functional cookies — store your preferences such as language settings, game display options, and lobby layout to improve your experience;
• Analytical cookies — collect anonymized aggregate data about how visitors interact with the Platform, used to identify technical issues and improve service design;
• Security cookies — assist in detecting unusual login patterns, unauthorized access attempts, and fraudulent activity.

7.3 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to and using the Platform. phearn does not use third-party advertising cookies or cross-site tracking for external advertising purposes.

8.1 phearn implements technical and organizational security measures commensurate with the sensitivity of the personal data processed and the risks associated with the Platform's financial services context. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between the user's device and phearn's servers;
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records;
• Salted cryptographic hashing of all account passwords — no plaintext password storage;
• Multi-factor authentication (OTP via SMS) for account login from new or unrecognized devices;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments conducted by qualified third-party security firms;
• Incident response procedures aligned with NPC notification requirements in the event of a personal data breach.

8.2 Notwithstanding the above, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. phearn maintains appropriate safeguards and will notify affected players and the NPC without undue delay in the event of a breach that poses a real risk of serious harm.

9.1 phearn retains personal data for the periods described below, after which data is securely deleted or irreversibly anonymized:

• Account and KYC data — retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Financial transaction records — retained for a minimum of five (5) years following the transaction date in compliance with AMLA requirements;
• Gaming activity logs — retained for three (3) years from the date of each session for dispute resolution and regulatory audit purposes;
• Support communications — retained for two (2) years from the date of last communication;
• Technical and security logs — retained for ninety (90) days for security monitoring purposes, except where specific records are preserved as evidence in an active investigation.

9.2 Where a legal hold, active investigation, or unresolved dispute requires extended retention, phearn will retain relevant data beyond the standard periods described above until the matter is fully resolved.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phearn. These rights may be exercised by contacting phearn's Data Protection Officer using the details in Section 13.

11.1 phearn's services are strictly restricted to individuals who are twenty-one (21) years of age or older, in compliance with PAGCOR regulations governing online casino gaming in the Philippines. phearn does not knowingly collect personal data from individuals under the age of 21.

11.2 If phearn discovers or is notified that personal data has been collected from a person under 21 years of age, phearn will immediately close the associated Account, delete the personal data collected, and report the incident in accordance with its PAGCOR compliance obligations.

11.3 If you are a parent or guardian and believe your minor child has registered on phearn, please contact the Data Protection Officer immediately using the contact details provided in Section 13. phearn will investigate and take all necessary remedial action promptly.

12.1 phearn reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision.

12.2 For material changes that significantly affect how we process your personal data, phearn will provide advance notice via in-platform notification or SMS to your registered mobile number at least seven (7) days before the changes take effect.

12.3 Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically.

For any questions, concerns, or requests relating to this Privacy Policy or phearn's handling of your personal data, please contact our Data Protection Officer:

If you are not satisfied with phearn's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority for data protection matters in the country.