phiery Privacy Policy

📋 1. Introduction

phiery ("phiery," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the phiery platform, accessible at phiery.net. This Privacy Policy describes how phiery collects, processes, stores, shares, and protects personal data in connection with your use of the phiery website, mobile platform, and all related services (collectively, the "Platform").

This Privacy Policy applies to all registered players, visitors, and any individual whose personal data is processed by phiery in connection with the Platform. By registering an account on phiery or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

phiery acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes. phiery is registered with the National Privacy Commission (NPC) of the Philippines in accordance with the requirements of the Data Privacy Act of 2012.

📂 2. Personal Data We Collect

phiery collects the following categories of personal data from users of the Platform:

2.1 Identity and Contact Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (for age verification purposes);
• Registered mobile number;
• Email address (where provided);
• Residential address;
• Government-issued identification number (e.g., SSS, PhilHealth, TIN, passport number).

2.2 Financial Data

• GCash or PayMaya account number linked to your phiery wallet;
• Bank account details (BPI, BDO, Metrobank) where used for deposits or withdrawals;
• Transaction history, including deposit amounts, withdrawal amounts, and dates;
• Wallet balance and bonus balance information.

2.3 Gaming Activity Data

• Game session logs, including games played, wager amounts, and outcomes;
• Bonus usage and wagering history;
• Responsible gaming settings and self-exclusion records;
• Customer support interaction records.

2.4 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session timestamps and login history;
• Cookies and similar tracking technologies (see Section 9).

🔍 3. How We Collect Your Data

phiery collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, log files, and analytics tools;
• Third-party sources: Identity verification data from KYC service providers; payment data from GCash, PayMaya, and banking partners; fraud detection data from security service providers;
• Regulatory sources: Data received from PAGCOR or other competent Philippine authorities in connection with regulatory compliance obligations.

🎯 4. Purpose of Processing

phiery processes your personal data for the following purposes:

⚖️ 5. Legal Basis for Processing

phiery processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform the contract between you and phiery, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulations, AML obligations, and tax reporting requirements;
• Legitimate interests: Processing necessary for phiery's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

🤝 6. Data Sharing and Disclosure

phiery does not sell, rent, or trade your personal data to any third party for commercial purposes. phiery may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

6.1 Service Providers (Personal Information Processors)

phiery engages third-party service providers who process personal data on phiery's behalf, including KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud detection and cybersecurity providers, cloud hosting and infrastructure providers, and customer support platform providers. All such providers are contractually bound to process personal data only as instructed by phiery and in accordance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

phiery may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or any other competent Philippine authority where required by law, court order, or regulatory directive. phiery will notify affected users of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of phiery's assets, personal data held by phiery may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. phiery will notify registered users of any such transfer via the contact information on file.

🗓️ 7. Data Retention

phiery retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AML regulatory requirements;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with BIR and AMLC requirements;
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the activity;
• Customer support records: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter for compliance documentation purposes.

Upon expiry of the applicable retention period, phiery will securely delete or anonymize your personal data in accordance with its data disposal procedures.

🔐 8. Data Security

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

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the phiery Platform;
• Encryption of sensitive data at rest, including financial data and government ID information;
• Multi-factor authentication (OTP) for account access;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• 24/7 monitoring for suspicious activity, unauthorized access attempts, and data breaches;
• Staff training on data protection obligations and security best practices.

In the event of a personal data breach that is likely to result in harm to affected individuals, phiery will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected users without undue delay, in accordance with the Data Privacy Act of 2012.

🍪 9. Cookies and Tracking Technologies

phiery uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and deliver relevant content. The following categories of cookies are used on phiery:

• Strictly necessary cookies: Required for the Platform to function. These cannot be disabled. They include session authentication tokens, security cookies, and load-balancing cookies;
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits you have set;
• Analytics cookies: Collect anonymized data about how users interact with the Platform to help phiery improve performance and user experience;
• Marketing cookies: Used with your consent to deliver relevant promotional content. You may opt out at any time via your account settings.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair the functionality of the phiery Platform. phiery does not use cookies to collect sensitive personal information or to track your activity on third-party websites.

✅ 10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phiery:

To exercise any of the above rights, please contact phiery's Data Protection Officer (DPO) using the contact details in Section 13. phiery will respond to all verified data subject requests within thirty (30) days of receipt.

👶 11. Children's Privacy

If you are a parent or guardian and believe that a minor has registered on phiery or provided personal data to phiery without your consent, please contact phiery support immediately. phiery takes the protection of minors seriously and cooperates fully with PAGCOR's age verification requirements.

📝 12. Changes to This Privacy Policy

phiery reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or phiery's data processing practices. When material changes are made, phiery will notify registered users via in-platform notification or SMS to the registered mobile number, and will update the "Last Updated" date at the top of this page.

Your continued use of the phiery Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. phiery recommends that you review this Policy periodically. If you do not agree to the amended Policy, you must stop using the Platform and may request account closure by contacting support.

📬 13. Contact and Data Protection Officer

phiery has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact the phiery DPO:

phiery will acknowledge all data privacy inquiries within five (5) business days and will provide a substantive response within thirty (30) days. For urgent matters relating to a suspected data breach or unauthorized access to your account, please contact phiery support via live chat on the Platform for the fastest response.