phbengo Privacy Policy

phbengo ("phbengo," "we," "us," "our") is committed to protecting the privacy and personal data of all users of the phbengo platform ("Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations.

This Privacy Policy should be read together with phbengo's Terms & Conditions and Responsible Gaming Policy. Capitalized terms not defined herein have the meanings given to them in the Terms & Conditions.

phbengo processes personal data only for legitimate, specified, and explicit purposes. We do not sell your personal data to third parties for their own marketing purposes.

For the purposes of the Data Privacy Act of 2012, phbengo is the personal information controller responsible for your personal data collected through the Platform. phbengo has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws.

If you have any questions about this Privacy Policy or wish to exercise your data subject rights, you may contact our DPO using the contact details provided in Section 13 of this Policy.

phbengo collects personal data from you in the following ways: directly from you when you register an account, make a deposit or withdrawal, contact customer support, or participate in promotions; automatically when you use the Platform; and from third parties such as identity verification providers and payment processors.

Account Registration Data:

• Full legal name, date of birth, and gender;
• Email address and mobile number;
• Residential address (including city, province, and postal code);
• Username and encrypted password;
• Government-issued identification document details (e.g., PhilSys ID, passport, driver's license, UMID) for age and identity verification.

Financial Data:

• GCash or PayMaya account number, BPI, BDO, or Metrobank account details used for deposits and withdrawals;
• Transaction history, deposit amounts, withdrawal amounts, and account balance records;
• Source of funds documentation where required for anti-money laundering compliance.

Usage and Technical Data:

• IP address, device type, operating system, and browser type;
• Pages visited, games played, bets placed, and session duration;
• Geolocation data (country and region level) to verify jurisdictional eligibility;
• Cookies and similar tracking technologies (see Section 10).

Communications Data:

• Records of your communications with phbengo customer support, including chat logs and email correspondence;
• Feedback, survey responses, and promotional opt-in preferences.

phbengo uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your phbengo account, including verifying your identity and age (21+ requirement) and processing your login credentials;
• Service Delivery: To provide access to games, process bets, calculate winnings, and deliver the full range of phbengo platform features;
• Financial Transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to maintain accurate financial records;
• Regulatory Compliance: To comply with Philippine gaming regulations, anti-money laundering laws, tax reporting obligations, and any other applicable legal requirements;
• Responsible Gaming: To monitor gaming behavior, identify potential problem gambling patterns, and administer responsible gaming tools including deposit limits, loss limits, and self-exclusion;
• Customer Support: To respond to your inquiries, resolve disputes, and improve the quality of our support services;
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where permitted by applicable law. You may opt out at any time;
• Platform Improvement: To analyze usage patterns, conduct research, and improve the phbengo platform's features, performance, and user experience.

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

• Contractual Necessity: Processing is necessary for the performance of the contract between you and phbengo (i.e., the Terms & Conditions), including account management, game delivery, and financial transaction processing;
• Legal Obligation: Processing is necessary for phbengo to comply with applicable Philippine laws, including gaming regulations, anti-money laundering requirements, and tax obligations;
• Legitimate Interests: Processing is necessary for phbengo's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms;
• Consent: For marketing communications and non-essential cookies, phbengo relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

phbengo does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your financial transactions;
• Identity Verification Providers: Third-party KYC (Know Your Customer) and age verification service providers engaged to verify your identity and age in compliance with Philippine regulations;
• Game Providers: Third-party game software providers whose games are available on the phbengo platform, to the extent necessary for game delivery and fairness auditing;
• Regulatory Authorities: The Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, as required by law;
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid legal order or where phbengo reasonably believes disclosure is necessary to prevent fraud, illegal activity, or harm;
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by phbengo, subject to professional confidentiality obligations.

Where phbengo engages third-party processors, we require them to process personal data only on our documented instructions and to implement appropriate technical and organizational security measures.

phbengo retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Account data and transaction records are retained for a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations. After the applicable retention period, personal data is securely deleted or anonymized.

Where you have exercised your right to erasure (see Section 9), phbengo will delete your personal data within thirty (30) days, except where retention is required by law or necessary for the establishment, exercise, or defense of legal claims.

phbengo implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the phbengo platform;
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and financial account details;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While phbengo takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your phbengo login credentials.

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

• Right to be Informed: The right to be informed of how your personal data is being collected and processed, as described in this Privacy Policy;
• Right of Access: The right to request a copy of the personal data phbengo 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 applicable legal retention requirements;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phbengo has violated your data privacy rights.

To exercise any of these rights, please contact phbengo's Data Protection Officer using the contact details in Section 13. phbengo will respond to all data subject requests within thirty (30) days of receipt, as required by the DPA.

phbengo uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. Cookies are small text files stored on your device when you visit the phbengo website.

phbengo uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management and security. These cannot be disabled;
• Performance Cookies: Used to collect anonymous information about how visitors use the Platform, helping phbengo improve performance and user experience;
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations;
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the phbengo Platform.

The phbengo Platform is strictly intended for individuals who are at least 21 years of age. phbengo does not knowingly collect personal data from persons under 21 years of age. If phbengo becomes aware that it has inadvertently collected personal data from an underage individual, it will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the phbengo Platform, please contact us immediately at the details provided in Section 13.

phbengo reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered users via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the phbengo Platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phbengo, please contact our Data Protection Officer. Our customer support and DPO team is available daily from 8:00 AM to 12:00 MN Philippine Standard Time (PST).

Email: [email protected]

phbengo will acknowledge receipt of all data subject requests and privacy-related complaints within two (2) business days and will provide a full response within thirty (30) days, as required by the Data Privacy Act of 2012. If you are not satisfied with phbengo's response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.