phrelx Privacy Policy

This Privacy Policy is issued by phrelx ("phrelx," "we," "us," or "our"), the operator of the phrelx online gaming platform accessible at phrelx.app. phrelx acts as the data controller in respect of the personal data of players and visitors to the platform.

phrelx is committed to protecting the privacy and personal data of all individuals who interact with our platform. This Privacy Policy describes our practices in relation to the collection, use, storage, disclosure, and protection of personal data in connection with the phrelx Service, in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

By registering an account on phrelx or otherwise using the Service, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with this Privacy Policy, please do not use the phrelx platform.

phrelx collects personal data from you in the following ways: directly when you provide it to us, automatically when you use the platform, and from third parties where permitted by law. The categories of personal data we collect include:

We do not collect sensitive personal information (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless specifically required for responsible gaming or regulatory compliance purposes, and only with your explicit consent where required by law.

phrelx uses the personal data we collect for the following purposes:

• Account Registration and Management: To create and maintain your phrelx account, verify your identity and age (21+ requirement), and manage your account settings and preferences.
• Service Delivery: To provide you with access to phrelx games, process your deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods, and deliver the features of the platform.
• Regulatory Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and reporting requirements to relevant regulatory authorities.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit and loss limits, process self-exclusion requests, and fulfil our responsible gaming obligations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, bonus abuse, and other prohibited conduct on the phrelx platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance through our Filipino support team.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the phrelx platform.

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

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide the phrelx gaming service, process transactions, and manage your account.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML legislation, KYC requirements, and gaming regulatory obligations.
• Legitimate Interests: Processing is necessary for phrelx's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and interests.
• Consent: For marketing communications and certain non-essential cookies, we rely on your consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

phrelx does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable data protection laws.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged by phrelx to verify your identity and age in compliance with regulatory requirements.
• Game Software Providers: Licensed game developers and content providers whose games are available on the phrelx platform. Only the minimum data necessary for game delivery and fairness auditing is shared.
• Regulatory Authorities: Philippine regulatory bodies, law enforcement agencies, and other government authorities, where disclosure is required by law, court order, or regulatory direction.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged by phrelx to operate and secure the platform. All such providers are contractually bound to process data only on phrelx's instructions.
• Professional Advisers: Legal, accounting, and compliance advisers, where necessary for phrelx to obtain professional advice or to defend legal claims.

Any third party with whom phrelx shares personal data is required to implement appropriate technical and organisational measures to protect that data and to process it only for the purposes for which it was shared.

phrelx uses cookies and similar tracking technologies on the platform to enhance your experience, maintain your session, and analyse platform usage. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged in to your phrelx account. These cannot be disabled.
• Performance and Analytics Cookies: Used to collect anonymised information about how players use the phrelx platform, such as which games are most popular and how long sessions last. This helps us improve the platform.
• Functionality Cookies: Used to remember your preferences, such as language settings and display options, to personalise your phrelx experience.
• Marketing Cookies: Used to deliver relevant promotional content about phrelx to you. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phrelx platform. For strictly necessary cookies, no consent is required as they are essential to the Service.

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

Specifically:

• Account and identity data is retained for the duration of your phrelx account and for a minimum of five (5) years following account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity logs are retained for a minimum of three (3) years.
• Customer support communications are retained for two (2) years from the date of the last interaction.
• Marketing consent records are retained for the duration of your consent and for one (1) year following withdrawal of consent.

When personal data is no longer required, phrelx will securely delete or anonymise it in accordance with our data disposal procedures.

phrelx implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the phrelx platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls ensuring that phrelx staff can only access personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the phrelx platform.
• Multi-factor authentication requirements for phrelx staff accessing systems that process personal data.
• Incident response procedures to detect, report, and address personal data breaches promptly.

While phrelx takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your phrelx login credentials. If you suspect that your account has been compromised, please contact our support team immediately.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phrelx:

• Right to be Informed: The right to be informed of how your personal data is being processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phrelx holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most account information directly through your phrelx account settings.
• Right to Erasure: The right to request deletion of your personal data, subject to phrelx's legal and regulatory retention obligations. Note that we may be required to retain certain data even after account closure.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, subject to phrelx's overriding legitimate grounds.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that phrelx has not handled your personal data in accordance with the DPA.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 12. phrelx will respond to all verified requests within thirty (30) days, or within such extended period as permitted by applicable law.

The phrelx platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. phrelx does not knowingly collect personal data from individuals under the age of 21.

If phrelx becomes aware that personal data has been collected from a person under 21 years of age, we 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 phrelx, please contact our support team immediately so that we can take appropriate action.

phrelx employs age verification procedures during the registration process and reserves the right to request documentary proof of age at any time. Providing false information about your age to circumvent these controls constitutes a breach of the phrelx Terms & Conditions.

phrelx reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, phrelx will notify registered players via the email address associated with their account and/or by displaying a prominent notice on the platform.

The date of the most recent revision is displayed at the top of this page. Your continued use of the phrelx platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this Privacy Policy periodically.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phrelx, please contact our Data Protection Officer. Our Filipino support team is available 24 hours a day, 7 days a week, Philippine Standard Time (PST, UTC+8).

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have not been respected. For responsible gaming concerns, please visit our Responsible Gaming page.