🔐 phdarna Privacy Policy

1. Introduction & Scope

phdarna ("phdarna," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the phdarna online gaming platform at phdarna.app (the "Platform"). This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, sharing, and protection of personal data in connection with your use of the Platform and all related services.

This Policy applies to all registered users ("Players"), visitors who browse the Platform without registering, and any individual who contacts phdarna's customer support team. By accessing the phdarna Platform or submitting any personal data to us, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2. Data Controller Information

phdarna operates as the data controller responsible for your personal data collected through the Platform. As data controller, phdarna determines the purposes and means by which personal data is processed. For all privacy-related concerns, requests, or complaints, you may contact our designated Data Protection Officer (DPO) using the contact information provided in Section 15 of this Policy.

phdarna operates within the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR). As a PAGCOR-licensed operator, phdarna is subject to data governance requirements applicable to licensed online gaming platforms in the Philippines.

3. Personal Data We Collect

phdarna collects the following categories of personal data, depending on your level of interaction with the Platform:

Identity & Contact Data:

• Full legal name as it appears on a valid government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Philippine mobile number (primary contact and OTP verification channel);
• Email address (for account communications and notifications);
• Residential address (required for KYC verification).

Identity Verification & KYC Data:

• Copies or photographs of government-issued identification documents (e.g., PhilSys National ID, passport, UMID, driver's license);
• Proof of address documents where required;
• Selfie or facial image for biometric identity verification where applicable.

Financial & Transaction Data:

• GCash number, Maya account reference, bank account details (BPI, BDO, Metrobank), or other payment method identifiers used for deposits and withdrawals;
• Transaction history including deposit amounts, withdrawal requests, game wagering records, and bonus activity;
• Source of funds declarations where requested by compliance.

Technical & Usage Data:

• IP address, device type, browser type and version, operating system;
• Session timestamps, pages visited, game sessions, and clickstream data;
• Geolocation data (at the region level) used for regulatory compliance and fraud prevention.

Communications Data:

• Records of live chat, email, and support ticket communications with phdarna's customer service team.

4. How We Collect Your Data

phdarna collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make deposits or withdrawals, contact support, or participate in promotions on the phdarna Platform;
• Automatically — through cookies, web beacons, server logs, and similar tracking technologies as you browse and interact with the Platform (see Section 10);
• From third parties — including payment processors (GCash, Maya, BPI, BDO), identity verification service providers, fraud prevention partners, and game suppliers integrated within the phdarna Platform, where applicable.

5. How We Use Your Personal Data

phdarna uses the personal data it collects for the following purposes:

• Account creation and management: To register your phdarna account, verify your identity, and maintain your player profile;
• Age and identity verification: To confirm that all players are 21 years of age or older, as required under PAGCOR regulations;
• Payment processing: To process deposits, withdrawals, and refunds through your chosen payment methods including GCash and Maya;
• Regulatory compliance: To fulfill phdarna's obligations under PAGCOR licensing requirements, anti-money laundering (AML) laws, and the Data Privacy Act;
• Fraud prevention and platform security: To detect, investigate, and prevent unauthorized access, fraudulent activity, money laundering, and other illegal conduct;
• Customer support: To respond to your inquiries, resolve disputes, and improve the quality of phdarna's support services;
• Personalization and promotions: To deliver relevant bonus offers, tailor your gaming experience on phdarna, and communicate updates about the Platform — where you have provided consent or where phdarna has a legitimate interest;
• Responsible gaming: To monitor gaming behavior, enforce deposit limits, and proactively identify players who may be at risk of problem gambling.

6. Legal Basis for Processing

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

• Contractual necessity: Processing necessary to perform the agreement between you and phdarna (account creation, payment processing, gameplay);
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, and other applicable Philippine legislation;
• Legitimate interests: Processing necessary for fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Where phdarna relies on your explicit consent, such as for marketing communications — you may withdraw consent at any time by contacting support.

7. Sharing & Disclosure of Personal Data

phdarna does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purposes:

• Payment processors: GCash (G-Xchange Inc.), Maya (Voyager Innovations Inc.), banks, and other financial service providers used to process your transactions;
• Identity verification providers: Third-party KYC and AML service providers engaged by phdarna for identity and document verification;
• Game suppliers: Software providers whose games are integrated within the phdarna Platform may receive limited session and wager data for game integrity and RTP audit purposes;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies, where phdarna is legally required to disclose data;
• Service providers: Hosting, IT security, analytics, and customer support service providers operating under data processing agreements with phdarna.

8. Data Retention

phdarna retains personal data for as long as necessary to fulfill the purposes outlined in this Policy, or as required by applicable law. In particular:

• Account and KYC records are retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements;
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Marketing preference data is retained until you withdraw consent;
• Support communications are retained for a period of two (2) years from the date of the last interaction.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized.

9. Data Security

phdarna implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, disclosure, alteration, and destruction. These measures include 256-bit SSL/TLS encryption for all data transmitted to and from the Platform, encrypted storage of sensitive data at rest, role-based access controls limiting internal access to personal data on a need-to-know basis, and regular security audits and penetration testing of Platform systems.

While phdarna takes reasonable precautions to secure your personal data, no system is completely infallible. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phdarna will notify the National Privacy Commission and affected individuals in accordance with the Data Privacy Act and NPC Circular No. 16-03.

10. Cookies & Tracking Technologies

phdarna uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used include:

• Strictly necessary cookies: Required for the Platform to function, including session management and login state maintenance. These cannot be disabled;
• Performance cookies: Used to collect anonymous analytics data about how players use phdarna, helping us identify and fix performance issues;
• Functional cookies: Used to remember your preferences such as language settings and game display options;
• Analytics cookies: Used to understand aggregate user behavior patterns on the phdarna Platform.

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

11. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phdarna:

• Right to be informed: The right to know how phdarna collects and uses your personal data (addressed by this Policy);
• Right of access: The right to request a copy of the personal data phdarna holds about you;
• Right to rectification: The right to have inaccurate or incomplete personal data corrected;
• Right to erasure: The right to request deletion of your personal data, subject to phdarna's legal retention obligations;
• Right to object: The right to object to processing based on legitimate interests or for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission at privacy.gov.ph if you believe your data rights have been violated.

To exercise any of these rights, please contact phdarna's Data Protection Officer using the contact information in Section 15. We will respond to verifiable requests within fifteen (15) calendar days.

12. Children's Privacy

The phdarna Platform is strictly intended for individuals who are 21 years of age or older. phdarna does not knowingly collect personal data from anyone under 21. If phdarna discovers that personal data has been collected from a person under the age of 21, such account will be immediately suspended and all associated data will be deleted in accordance with applicable law and PAGCOR requirements.

13. Cross-Border Data Transfers

Some of phdarna's service providers, game suppliers, and infrastructure partners may be located outside the Philippines. Where personal data is transferred to a recipient in a foreign country, phdarna ensures that appropriate safeguards are in place — including contractual data processing agreements that impose obligations equivalent to those required under Philippine law — prior to any such transfer. phdarna does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing the protections described herein.

14. Changes to This Policy

phdarna may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or Platform features. Material changes will be communicated to registered Players through in-Platform notifications or via the contact information registered on your phdarna account. The "Last Updated" date at the top of this page will always reflect the most recent revision. Continued use of the phdarna Platform after the effective date of any changes constitutes acceptance of the revised Policy.

15. Contact & DPO Information

For privacy-related requests, complaints, or questions regarding this Policy or phdarna's data practices, please contact phdarna's Data Protection Officer. You may reach us via email at (plain text only, not a link): [email protected]

Please include "Privacy Request" in the subject line along with your registered phdarna account details. phdarna's support team is available 24 hours a day, 7 days a week.