Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by phmarry ("phmarry," "we," "us," or "our") and applies to all personal data collected through the phmarry website, mobile application, and all associated services (collectively, the "Platform"). This Policy explains how phmarry collects, uses, stores, shares, and protects your personal data, and describes the rights you have in relation to that data.

phmarry is committed to protecting the privacy of all users of the Platform, including registered players and visitors. We process personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as well as all other applicable data protection laws.

            By registering for a phmarry account or using 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. If you
            do not agree to this Policy, please do not use the phmarry Platform.
          

This Policy should be read together with our Terms & Conditions, which govern your use of the phmarry Platform and are incorporated herein by reference.

2 Personal Data We Collect

phmarry collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government ID number	Account registration, age and identity verification (KYC)
Contact Data	Email address, mobile number, home address	Account communication, support, notifications
Financial Data	GCash number, bank account details, transaction history	Processing deposits and withdrawals, fraud prevention
Technical Data	IP address, device type, browser, operating system	Platform security, fraud detection, service improvement
Usage Data	Pages visited, games played, betting history, session duration	Personalisation, responsible gaming monitoring, analytics
Communications Data	Support chat logs, email correspondence	Customer support, dispute resolution, quality assurance

phmarry does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law or where you voluntarily provide such information in the context of a responsible gaming self-assessment.

3 How We Collect Your Data

phmarry collects personal data through the following means:

Direct Collection: Information you provide when registering for a phmarry account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
Automated Collection: Technical and usage data collected automatically when you access and use the phmarry Platform, including through cookies, web beacons, and similar tracking technologies.
Third-Party Sources: Identity and fraud verification data from third-party KYC and anti-money laundering service providers; payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank; and publicly available information where relevant to fraud prevention or regulatory compliance.

4 How We Use Your Personal Data

phmarry uses your personal data only for legitimate, specified purposes. The table below sets out the primary purposes for which we process your data and the legal basis for each:

Account Management: To create, maintain, and administer your phmarry account, including verifying your identity and age in compliance with Philippine gaming regulations.
Service Delivery: To process your bets, deposits, and withdrawals, and to provide you with access to all games and features available on the phmarry Platform.
Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activities on the phmarry Platform.
Regulatory Compliance: To comply with our obligations under Philippine law, including anti-money laundering regulations, gaming regulations, and tax reporting requirements.
Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
Responsible Gaming: To monitor your gaming activity and identify potential signs of problem gambling, and to administer self-exclusion and other responsible gaming tools you have requested.
Marketing and Promotions: To send you information about phmarry promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out at any time.
Platform Improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the phmarry Platform.

            phmarry will never use your personal data for purposes that are incompatible
            with those described in this Policy without first obtaining your explicit
            consent or as otherwise required by law.
          

5 Legal Basis for Processing

phmarry processes your personal data on the following legal bases, as recognised under the Philippine Data Privacy Act of 2012:

Contractual Necessity: Processing is necessary to perform our contract with you — that is, to provide you with the phmarry Platform and its services as described in our Terms & Conditions.
Legal Obligation: Processing is necessary to comply with our legal obligations under Philippine law, including anti-money laundering laws, gaming regulations, and tax legislation.
Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests.
Consent: Where we rely on your consent as the legal basis for processing — for example, for direct marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

phmarry 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 and subject to appropriate data protection safeguards:

Service Providers: Third-party companies that provide services on our behalf, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification providers, IT infrastructure and hosting providers, customer support platforms, and analytics providers. These parties are contractually bound to process your data only on our instructions and in accordance with this Policy.
Regulatory and Law Enforcement Authorities: Philippine government agencies, regulators, law enforcement bodies, and courts where disclosure is required by law or necessary to protect the rights, property, or safety of phmarry, its players, or the public.
Anti-Money Laundering Bodies: The Anti-Money Laundering Council (AMLC) and other relevant Philippine authorities, where we are legally required to report suspicious transactions or activity.
Business Transfers: In the event of a merger, acquisition, or sale of all or part of phmarry's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

Important: phmarry will never share your personal data with third parties for their own marketing or advertising purposes without your explicit prior consent.

7 Data Retention

phmarry retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

Account Data: Retained for the duration of your active phmarry account, and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering and gaming regulatory requirements.
Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine law.
KYC and Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
Customer Support Records: Retained for up to three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal obligations.

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

8 Data Security

phmarry takes the security of your personal data seriously and implements appropriate technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

Encryption: All data transmitted between your device and the phmarry Platform is encrypted using Transport Layer Security (TLS). Sensitive data stored on our servers is encrypted at rest.
Access Controls: Access to personal data is restricted to phmarry employees and service providers who have a legitimate need to access it in the course of their duties. All such personnel are subject to confidentiality obligations.
Fraud Detection Systems: phmarry employs automated fraud detection and monitoring systems to identify and respond to suspicious activity on the Platform in real time.
Regular Security Audits: Our systems and processes are subject to regular security reviews and penetration testing to identify and address potential vulnerabilities.
Incident Response: phmarry maintains a data breach response procedure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the National Privacy Commission (NPC) as required by Philippine law.

            While phmarry takes all reasonable steps to protect your data, no online
            platform can guarantee absolute security. You are responsible for keeping
            your phmarry account credentials confidential and for notifying us
            immediately if you suspect any unauthorised access to your account.
          

9 Cookies and Tracking Technologies

phmarry uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, to analyse usage patterns, and to support our security and fraud prevention measures.

The types of cookies used by phmarry include:

Essential Cookies: Strictly necessary for the operation of the phmarry Platform, including session management and security functions. These cookies cannot be disabled without affecting Platform functionality.
Performance Cookies: Used to collect anonymous information about how visitors use the Platform, helping us identify areas for improvement. No personally identifiable information is collected by these cookies.
Functional Cookies: Used to remember your preferences and settings on the phmarry Platform, such as your preferred language and display options.
Analytics Cookies: Used to understand aggregate user behaviour on the Platform to improve our services and user experience.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phmarry Platform.

10 Your Data Rights

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

Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy.
Right of Access: The right to request a copy of the personal data phmarry 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 phmarry 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 our legal obligations to retain certain data.
Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact the phmarry Data Privacy Officer using the contact details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days, as required by Philippine law.

11 Children's Privacy

The phmarry Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. phmarry does not knowingly collect personal data from any person under the age of 21.

If phmarry becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the phmarry Platform, please contact our support team immediately.

Age Restriction: phmarry employs age verification procedures during registration and reserves the right to request documentary proof of age at any time. Accounts where age cannot be verified will be suspended pending verification.

12 Changes to This Privacy Policy

phmarry reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the features and services offered on the Platform. When we make material changes to this Policy, we will:

Post the updated Policy on this page with a revised effective date.
Where appropriate, notify you by email to the address associated with your phmarry account, or by a prominent notice on the Platform.

We encourage you to review this Privacy Policy periodically to stay informed about how phmarry protects your personal data. Your continued use of the phmarry Platform following the posting of any changes constitutes your acceptance of the updated Policy.

13 Contact Us & Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way phmarry handles your personal data, please contact our Data Privacy Officer. We are committed to addressing all privacy-related enquiries promptly and transparently.

phmarry Data Privacy Officer
Email: [email protected]
General Support: [email protected]
Response Time: Within 30 days as required by Philippine law
Available: Monday to Friday, 9:00 AM – 6:00 PM (Philippine Standard Time)

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with our response to your privacy concern. For more information about your rights under Philippine data protection law, please refer to the NPC's official resources.

For responsible gaming support, please visit our Responsible Gaming page. For the full terms governing your use of phmarry, please review our Terms & Conditions.