phingo Privacy Policy

1. Introduction

Welcome to phingo. This Privacy Policy ("Policy") describes how phingo ("phingo," "we," "us," or "our") collects, uses, discloses, and safeguards the personal information of users ("you" or "your") who access or use the phingo online gaming platform available at phingo.app, including all associated services, features, and content.

phingo is committed to protecting the privacy and personal data of all Filipino players and users of our platform. We operate in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

By registering for a phingo account or using any phingo service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the phingo platform immediately.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, phingo acts as the Personal Information Controller (PIC) with respect to the personal data collected through the phingo platform. phingo determines the purposes and means of processing your personal information.

phingo has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact the phingo DPO at any time using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

phingo collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government-issued ID number	Account registration, KYC verification, age verification
Contact Data	Email address, mobile number, home address	Account communication, support, notifications
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank)	Processing deposits and withdrawals in PHP
Technical Data	IP address, device type, browser type, operating system	Platform security, fraud prevention, analytics
Usage Data	Games played, betting history, session duration, login timestamps	Service improvement, responsible gaming monitoring
Communications Data	Live chat transcripts, support emails, feedback submissions	Customer support, dispute resolution, quality assurance

phingo collects personal data directly from you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or interact with our platform. We may also collect technical data automatically through cookies and similar tracking technologies as described in Section 6.

4. How phingo Uses Your Personal Data

phingo processes your personal data for the following purposes:

• Account Management: To create, maintain, and manage your phingo account, including verifying your identity and age (21+ requirement) in compliance with PAGCOR regulations.
• Service Delivery: To provide you with access to phingo's gaming products, including live casino, slots, bingo, snooker, and American football betting.
• Financial Transactions: To process deposits and withdrawals in Philippine Peso (PHP) via GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment methods.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR licensing requirements, and the Data Privacy Act of 2012.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the phingo platform.
• Responsible Gaming: To monitor gaming behavior and provide responsible gaming tools, including deposit limits, loss limits, session reminders, and self-exclusion, in line with our commitment to player welfare.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support team.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the phingo platform, user experience, and game offerings.

5. Legal Basis for Processing

phingo processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and phingo (i.e., the phingo Terms & Conditions), including account management and transaction processing.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR requirements, and tax obligations.
• Legitimate Interests: Processing is necessary for phingo's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, phingo relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Cookies and Tracking Technologies

phingo uses cookies and similar tracking technologies to enhance your experience on the phingo platform, ensure platform security, and analyze usage patterns. The types of cookies used by phingo include:

• Essential Cookies: Strictly necessary for the phingo platform to function. These cannot be disabled without affecting core functionality, including maintaining your login session and security tokens.
• Analytics Cookies: Used to collect aggregated, anonymized data about how users interact with phingo, helping us improve the platform. These are only set with your consent.
• Preference Cookies: Used to remember your settings and preferences on phingo, such as language and display preferences.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized account access on phingo.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may impair your ability to use certain features of the phingo platform.

7. Data Sharing and Disclosure

phingo does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phingo may share your personal data with the following categories of recipients only to the extent necessary and permitted by law:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment service providers, solely for the purpose of processing your financial transactions.
• Identity Verification Providers: Third-party KYC and identity verification services used to verify your identity and age in compliance with regulatory requirements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or court order.
• Technology Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on phingo's behalf under strict data processing agreements.
• Game Providers: Third-party game software providers who may receive limited technical data necessary to deliver their games on the phingo platform.

All third parties with whom phingo shares personal data are required to maintain appropriate security measures and to process your data only for the specified purposes and in accordance with applicable Philippine data privacy law.

8. Data Retention

phingo retains your personal data for as long as your phingo account is active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specifically:

• Account Data: Retained for the duration of your phingo account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine AML regulations.
• KYC and Identity Documents: Retained for the duration of your phingo account and for five (5) years after account closure or the completion of any related investigation, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing Preferences: Retained until you withdraw your consent or opt out of marketing communications.

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

9. Data Security

phingo implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Industry-standard SSL/TLS encryption for all data transmitted between your device and the phingo platform.
• Encryption at rest for sensitive personal and financial data stored on phingo's servers.
• Strict access controls ensuring that only authorized phingo personnel with a legitimate need can access personal data.
• Regular security audits and penetration testing of the phingo platform and infrastructure.
• Two-factor authentication (2FA) options available to phingo account holders to enhance account security.
• Comprehensive incident response procedures to detect, contain, and notify affected users and the NPC of any personal data breach within the timeframes required by law.

While phingo takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phingo account credentials and for notifying phingo immediately if you suspect any unauthorized access to your account.

10. Your Data Privacy Rights

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

• Right to be Informed: The right to be informed of how phingo collects and processes your personal data, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data phingo holds about you and information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data phingo holds about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phingo's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on phingo's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phingo has violated your data privacy rights.

To exercise any of the above rights, please contact the phingo Data Protection Officer using the contact details in Section 14. phingo will respond to all verified data privacy requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11. Children's Privacy

The phingo platform is strictly intended for users who are 21 years of age or older, in accordance with the minimum legal age for casino-style gambling in the Philippines. phingo does not knowingly collect personal data from individuals under the age of 21.

If phingo becomes aware that personal data has been collected from a person under 21 years of age, phingo will immediately suspend the associated account, delete the personal data, and return any deposits at its sole discretion. If you believe a minor has registered on phingo, please contact our support team immediately.

12. Third-Party Links

The phingo platform may contain references to third-party services, such as payment providers. phingo is not responsible for the privacy practices or content of any third-party websites or services. We encourage you to review the privacy policies of any third-party services you use in connection with phingo, including your chosen payment provider (GCash, PayMaya, BPI, BDO, or Metrobank).

13. Changes to This Privacy Policy

phingo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, phingo will notify registered users via email or a prominent notice on the phingo platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this page. Your continued use of the phingo platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. We recommend reviewing this Policy periodically to stay informed of how phingo protects your data.

14. Contact Us

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

• Email: [email protected]
• Support Email: [email protected]
• Live Chat: Available 24/7 on the phingo platform

For complaints that cannot be resolved directly with phingo, you may contact the National Privacy Commission (NPC) of the Philippines through their official channels.