This Privacy Policy explains how phlein collects, uses, stores, and protects your personal data when you register and play on the phlein platform. It is written in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and the regulations of the National Privacy Commission (NPC).
phlein ("phlein," "we," "us," "our") is committed to protecting the privacy and personal data of every individual who uses the phlein platform. This Policy sets out in clear, plain terms how phlein handles personal data, why we collect it, what we do with it, how long we keep it, and what rights you have under Philippine law.
This Policy applies to all personal data we collect from you as a registered phlein account holder, a visitor to phlein.co who has not yet registered, a former account holder whose data we retain for regulatory compliance purposes, or any individual whose data we process in connection with a phlein transaction or support inquiry.
This Policy should be read together with the phlein Terms & Conditions, which govern the overall legal relationship between you and phlein, and the Responsible Gaming page, which explains how phlein uses certain personal data specifically to support player welfare obligations.
For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA") and applicable National Privacy Commission (NPC) implementing rules and regulations, phlein is the personal information controller ("PIC") responsible for the personal data collected and processed through the phlein platform.
phlein collects only the personal data that is necessary for the purposes described in this Policy. The following categories of data may be collected depending on your level of interaction with the phlein platform:
phlein collects your personal data through the following means:
| Collection Method | Examples |
|---|---|
| Direct provision by you | Account registration form, KYC document upload, deposit / withdrawal requests, support inquiries, survey responses |
| Automated platform collection | Cookies, session logs, IP address recording, device fingerprinting, gameplay event logs |
| Payment processors | Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, Visa / Mastercard processors (phlein receives transaction references and amounts, not full card numbers) |
| KYC and identity verification partners | Identity verification results and fraud screening outputs from accredited KYC service providers |
| Regulatory sources | PAGCOR self-exclusion registry, AML watchlists maintained by the Anti-Money Laundering Council (AMLC) |
| Publicly available sources | Publicly available records used for fraud prevention and AML compliance checks |
Under Section 12 of RA 10173, personal data processing must be based on at least one lawful criterion. The following legal bases apply to phlein's processing activities:
phlein uses your personal data for the following specific purposes:
phlein does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Personal data is shared with third parties only in the following specific circumstances:
phlein is legally required to share personal data and transaction records with PAGCOR as the licensing regulator, the Anti-Money Laundering Council (AMLC) for suspicious transaction reporting under RA 9160, the National Privacy Commission where required by NPC investigation or data breach notification obligations, and Philippine law enforcement authorities where required by valid legal process.
phlein engages third-party service providers who process personal data on our behalf under written data processing agreements that contractually require them to maintain data security standards consistent with RA 10173. These providers include:
Where a player self-excludes from phlein, relevant information may be shared with PAGCOR's responsible gaming registry to prevent re-registration under a different identity, consistent with PAGCOR's player protection mandate.
The phlein platform uses cookies and similar tracking technologies to ensure platform functionality, maintain session security, and improve user experience. The following categories of cookies may be set when you visit phlein.co:
You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your phlein account.
phlein retains personal data only for as long as necessary to fulfill the purpose for which it was collected, to comply with applicable legal retention obligations, or to defend against potential legal claims. The following retention periods apply:
| Data Category | Retention Period | Basis |
|---|---|---|
| Identity and KYC documents | 5 years from account closure | PAGCOR regulatory requirement; RA 9160 AML obligation |
| Financial transaction records | 5 years from transaction date | RA 9160 AML record-keeping requirement |
| Gameplay and betting records | 3 years from account closure | PAGCOR audit requirements; dispute resolution |
| Customer support communications | 3 years from last communication | Legitimate interest: dispute resolution; quality assurance |
| Self-exclusion records | Indefinite (permanent record) | PAGCOR responsible gaming obligation; legal protection |
| Technical / device logs | 12 months | Fraud prevention; security incident investigation |
| Marketing consent records | Until withdrawal of consent + 3 years | Legal evidence of consent basis |
Following the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be associated with an identifiable individual. Anonymized, aggregated data may be retained indefinitely for statistical and analytical purposes.
phlein implements technical and organizational security measures appropriate to the nature and sensitivity of the personal data we process. These include:
As a data subject under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by phlein. To exercise any of these rights, contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Rights Request." phlein will respond within fifteen (15) business days in accordance with NPC guidelines.
phlein enforces the minimum age requirement of 21 years at registration through date-of-birth verification and KYC document review. This is a PAGCOR regulatory requirement. If phlein becomes aware that personal data has been collected from a person under the age of 21, all such data will be deleted without delay, any associated account will be closed, and funds deposited will be returned to the originating payment method where possible. Parents or guardians who believe a minor has registered a phlein account should contact support immediately.
Certain third-party service providers engaged by phlein — including cloud infrastructure providers, game software vendors, and KYC service providers — may process personal data in jurisdictions outside the Philippines. Where such cross-border data transfers occur, phlein ensures that appropriate safeguards are in place consistent with Section 21 of RA 10173, including:
phlein will not transfer personal data to a foreign recipient unless such transfer complies with the DPA and applicable NPC implementing rules.
phlein may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable Philippine law, or NPC regulatory guidance. The effective date at the top of this Policy will be updated with each revision.
Where changes are material — meaning they significantly affect how phlein collects, uses, or shares your personal data — phlein will notify registered account holders by email to the address on record and/or through a prominent notice on phlein.co before the changes take effect. For non-material updates (such as clarifications of existing practices), phlein will update the Policy without individual notification.
Continued use of the phlein platform following notification of a material Policy change constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you may request account closure as described in the phlein Terms & Conditions.
For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phlein, please contact:
phlein Data Protection Officer (DPO)
Email:
[email protected]
(subject: "DPO / Data Privacy Inquiry")
Platform: phlein.co
Regulator: Philippine Amusement and Gaming Corporation (PAGCOR)
Data Privacy Regulator: National Privacy Commission of the Philippines (NPC)
Response Time: Within 15 business days of receipt of a valid request
If you are not satisfied with phlein's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC's contact details and complaint procedures are available through official Philippine government channels.
The Philippine Data Privacy Act gives you real, enforceable rights over your personal data. Here is what you can expect from phlein on each of them.
You can request a copy of all personal data phlein holds about you at any time. Contact our DPO and we will compile and deliver your data within 15 business days. There is no charge for a reasonable access request.
If any personal data phlein holds about you is inaccurate or out of date, you have the right to have it corrected. Contact support with the correct information and supporting documentation where required.
Where phlein has no ongoing legal obligation to retain your data, you may request its deletion. Note that PAGCOR and AML regulations require us to keep certain records for up to 5 years even after account closure.
You can object to phlein's processing of your data where that processing is based on legitimate interests rather than legal obligation. Objections to direct marketing communications are absolute and actioned immediately.
Where technically feasible, you may request your personal data in a structured, machine-readable format — for example, your account transaction history in CSV format. Contact the phlein DPO to make a portability request.
If you believe phlein has not handled your personal data correctly, you have the right to escalate your concern to the National Privacy Commission of the Philippines. phlein will cooperate fully with any NPC investigation.
phlein is built on trust. Your personal data is handled in compliance with RA 10173, overseen by PAGCOR, and never sold to third parties. Sign in to your phlein account and enjoy live Baccarat, Dragon Tiger, Bingo, slots, and sports betting — all on a platform that takes your privacy as seriously as your gameplay. 21+ only.
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