phwerte Privacy Policy 🔒

1. Introduction

1.1 phwerte is committed to protecting the privacy and personal data of all users of the phwerte Platform. We understand that Filipino players entrust us with sensitive personal and financial information, and we take that responsibility seriously.

1.2 This Policy applies to all personal data collected through the phwerte website, mobile platform, customer support channels, and any other services offered by phwerte. It should be read together with our Terms & Conditions and Responsible Gaming policy.

1.3 phwerte complies with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and all implementing rules and regulations issued by the National Privacy Commission (NPC). We are committed to upholding the rights of data subjects under Philippine law.

2. Information We Collect

2.1 Registration Data. When you create a phwerte account, we collect your full name, date of birth, nationality, residential address, email address, mobile number, and a government-issued identification number. This information is required to verify your identity and comply with our regulatory obligations under PAGCOR guidelines.

2.2 Financial Data. To process deposits and withdrawals, phwerte collects payment method details, including GCash account numbers, PayMaya account details, bank account information (BPI, BDO, Metrobank), and transaction histories. We do not store full card numbers or CVV codes on our servers.

2.3 Gaming Activity Data. phwerte records your gaming history, including games played, bets placed, amounts wagered, winnings, and session durations. This data is used to provide our services, detect problem gambling patterns, and comply with anti-money laundering (AML) obligations.

2.4 Technical Data. We automatically collect certain technical information when you access the phwerte Platform, including your IP address, device type, operating system, browser type, referring URLs, and pages visited. This data helps us maintain platform security and improve user experience.

2.5 Communications Data. When you contact phwerte customer support, we retain records of your communications, including emails, chat transcripts, and support tickets, to resolve disputes and improve our services.

2.6 Verification Documents. As part of our Know Your Customer (KYC) process, phwerte may collect copies of government-issued identification documents, proof of address, and proof of payment method ownership.

3. How We Use Your Data

3.1 phwerte uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your phwerte account, including processing deposits, withdrawals, and bonus credits;
• Identity Verification: To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine law;
• Service Delivery: To provide access to phwerte's games, sports betting markets, and all other Platform features;
• Regulatory Compliance: To comply with our legal obligations under Philippine law, including AML reporting, tax obligations, and PAGCOR licensing requirements;
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the Platform;
• Responsible Gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, and to enforce self-exclusion requests;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, subject to your communication preferences;
• Platform Improvement: To analyse usage patterns and improve the functionality, security, and user experience of the phwerte Platform.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide the phwerte Platform and services you have registered for);
• Legal Obligation: Processing is necessary to comply with our legal obligations under Philippine law, including PAGCOR licensing conditions, AML regulations, and tax laws;
• Legitimate Interests: Processing is necessary for our legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

5. Data Sharing & Disclosure

5.1 phwerte 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 below:

• Service Providers: Trusted third-party service providers who assist in operating the phwerte Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting providers, and customer support platforms. All service providers are bound by data processing agreements and are prohibited from using your data for any purpose other than providing services to phwerte;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulation;
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of phwerte's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

5.2 phwerte will not disclose your personal data to any third party for their own marketing purposes without your explicit consent.

6. Cookies & Tracking Technologies

6.1 phwerte uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, remember your preferences, and analyse Platform usage.

6.2 The types of cookies used by phwerte include:

• Essential Cookies: Necessary for the Platform to function correctly, including session management and security cookies. These cannot be disabled;
• Functional Cookies: Used to remember your preferences, such as language settings and display options;
• Analytics Cookies: Used to collect anonymised data about how users interact with the Platform, helping us improve functionality and user experience;
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

6.3 You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phwerte Platform.

7. Data Retention

7.1 phwerte retains your personal data for as long as your account is active and for such additional periods as are required by applicable law or regulation. Specifically:

• Account registration data and KYC documents are retained for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC requirements;
• Financial transaction records are retained for a minimum of five (5) years following the date of the transaction;
• Gaming activity records are retained for a minimum of three (3) years;
• Customer support communications are retained for two (2) years from the date of the last interaction.

7.2 Upon expiry of the applicable retention period, phwerte will securely delete or anonymise your personal data in accordance with our data disposal procedures.

8. Data Security

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

• 256-bit SSL/TLS encryption for all data transmissions between your device and the phwerte Platform;
• Encryption of sensitive data at rest, including financial information and identification documents;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing by independent security professionals;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Comprehensive staff training on data protection and information security.

8.2 While phwerte takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, phwerte will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Rights as a Data Subject

9.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phwerte:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed;
• Right of Access: The right to request a copy of the personal data phwerte 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 our 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 if you believe your data rights have been violated.

9.2 To exercise any of these rights, please contact phwerte's Data Protection Officer at [email protected]. phwerte will respond to all data subject requests within thirty (30) days of receipt.

10. Children's Privacy

10.1 The phwerte Platform is strictly intended for persons aged 21 years and above. phwerte does not knowingly collect personal data from persons under the age of 21. If phwerte becomes aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

10.2 If you are a parent or guardian and believe that your child has provided personal data to phwerte, please contact us immediately at [email protected].

11. Third-Party Links

11.1 The phwerte Platform may contain links to third-party websites or services. phwerte is not responsible for the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

11.2 The inclusion of any link on the phwerte Platform does not imply endorsement by phwerte of the linked website or its content.

12. Changes to This Policy

12.1 phwerte reserves the right to update or amend this Privacy Policy at any time. Any changes will be posted on the Platform with an updated "Last Updated" date. For material changes, phwerte will provide advance notice to registered players via email or an in-platform notification.

12.2 Your continued use of the phwerte Platform following the posting of any amendments to this Policy constitutes your acceptance of the revised Policy. If you do not agree to the amended Policy, you must cease using the Platform and close your account.

13. Contact Us

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

13.2 You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that phwerte has not handled your personal data in accordance with the Data Privacy Act of 2012.