This Privacy Policy explains how phfairy collects, uses, stores, and protects the personal data of its Members and website visitors, in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. By using the phfairy Platform, you acknowledge that you have read and understood this Policy.
🔒 phfairy is committed to the responsible and transparent handling of personal data. Your data is never sold to third parties for marketing purposes. We collect only what we need, for clearly defined purposes, with your informed consent.
1.1 The data controller responsible for the personal data of phfairy Members and site visitors is the operator of the phfairy platform accessible at phfairy.club ("phfairy," "we," "us," "our").
1.2 phfairy has designated a Data Protection Officer (DPO) responsible for ensuring compliance with RA 10173 and overseeing the implementation of this Privacy Policy. Contact details for the DPO are provided in Section 15 of this Policy.
1.3 phfairy is registered with the National Privacy Commission (NPC) of the Philippines as required under RA 10173 for personal information controllers processing the personal data of Filipino data subjects.
2.1 phfairy collects the following categories of personal data, depending on your interaction with the Platform:
Identity Data:
Contact Data:
Account & Transaction Data:
Technical & Usage Data:
Communications Data:
3.1 Directly from you: When you register an Account, complete identity verification (KYC), make a deposit or withdrawal, place a bet, contact support, participate in promotions, or interact with phfairy Circle.
3.2 Automatically: Through cookies, web beacons, session tracking, and server logs when you access the phfairy website or mobile platform. Technical data is collected automatically whenever you interact with our Platform.
3.3 From third parties: From identity verification service providers (for KYC/AML compliance), payment processors (transaction confirmation data), fraud detection services, and PAGCOR or other regulatory bodies where required by law.
4.1 phfairy processes your personal data for the following specific, legitimate purposes:
5.1 Under RA 10173, phfairy processes personal data on the following legal bases:
6.1 phfairy does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following circumstances:
Service providers and processors: phfairy engages trusted third-party service providers who process personal data on our behalf and under our instruction, under binding data processing agreements. These include:
Regulatory and legal disclosure: phfairy will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, courts, law enforcement agencies, and other government bodies when required to do so by applicable Philippine law, court order, or regulatory demand.
Business transfers: In the event of a merger, acquisition, or sale of substantially all of phfairy's assets, personal data may be transferred to the acquiring entity, subject to the same privacy protections as this Policy.
6.2 All third-party processors who handle phfairy Member data are bound by contractual data processing agreements that require them to process data only as instructed, maintain appropriate security measures, and comply with RA 10173.
7.1 Some of phfairy's third-party service providers (including cloud hosting, game content providers, and fraud detection services) may be located outside the Philippines and may process your personal data in other jurisdictions.
7.2 Where personal data is transferred outside the Philippines, phfairy ensures that appropriate safeguards are in place, including contractual clauses that impose equivalent data protection standards consistent with RA 10173, and that such transfers are conducted only where necessary and proportionate to the purposes described in Section 4.
7.3 By using the phfairy Platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where our service providers operate, subject to the protections described in this Section.
8.1 phfairy retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law, whichever is longer.
8.2 Specific retention periods include:
8.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be attributed to an identified or identifiable individual.
9.1 phfairy uses cookies and similar tracking technologies (web beacons, pixel tags, local storage) on the Platform for the following purposes:
9.2 You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using phfairy, but may affect certain personalisation features.
10.1 phfairy implements appropriate technical and organisational measures to protect your personal data against accidental loss, destruction, alteration, unauthorised disclosure, or access. These measures include:
10.2 In the event of a personal data breach that is likely to harm your rights and interests, phfairy will notify you and the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required by RA 10173.
11.1 Under RA 10173, you have the following rights with respect to your personal data processed by phfairy. You may exercise these rights by contacting our DPO as described in Section 15.
| Right | Description | How to Exercise |
|---|---|---|
| Right to be Informed | The right to know how phfairy collects, uses, and shares your personal data — fulfilled by this Privacy Policy. | Satisfied by reading this Policy |
| Right of Access | The right to request a copy of the personal data phfairy holds about you. | Contact DPO via live chat or email |
| Right to Rectification | The right to correct inaccurate or incomplete personal data. | Update via Account settings or contact support |
| Right to Erasure | The right to request deletion of personal data where no longer necessary, subject to legal retention obligations. | Contact DPO — note regulatory retention periods apply |
| Right to Object | The right to object to processing for direct marketing, or processing based on legitimate interests. | Contact DPO or use marketing opt-out in Account settings |
| Right to Data Portability | The right to receive your personal data in a structured, machine-readable format. | Contact DPO — processed within 30 days |
| Right to Lodge a Complaint | The right to file a complaint with the National Privacy Commission if you believe your data rights have been violated. | privacy.gov.ph (NPC official website) |
11.2 phfairy will respond to all data subject rights requests within thirty (30) calendar days of receipt. Where a request is complex or involves a large volume of data, phfairy may extend this period by a further thirty (30) days, notifying you of the extension and reason.
12.1 The phfairy Platform is strictly for persons aged 21 years and older. phfairy does not knowingly collect or process personal data from persons under 21 years of age.
12.2 If phfairy becomes aware that it has inadvertently collected personal data from a person under 21 — whether through a false declaration of age or any other means — phfairy will immediately suspend the relevant Account, delete the associated personal data to the extent permitted by legal retention obligations, and report the matter as required by PAGCOR.
12.3 Parents or guardians who believe that a minor may have registered a phfairy Account are requested to contact phfairy immediately via live chat or email so that the Account can be reviewed and closed.
13.1 The phfairy Platform may contain links to third-party websites or services (such as payment provider portals). This Privacy Policy applies exclusively to the phfairy Platform. When you follow a link to a third-party site, phfairy assumes no responsibility for the privacy practices or content of that third-party site.
13.2 We encourage you to read the privacy policies of any third-party sites you visit, particularly payment providers, before submitting personal data to those services.
14.1 phfairy reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, data processing practices, or Platform features. The "Last Updated" date at the top of this page reflects the most recent revision.
14.2 Material changes to this Policy — particularly changes that affect how we use your personal data or affect your data subject rights — will be notified to Members via in-Platform notification, email (where registered), or prominent notice on the phfairy homepage at least seven (7) days before taking effect.
14.3 Your continued use of the phfairy Platform following notification of a revised Privacy Policy constitutes acceptance of the changes. If you do not agree to the revised Policy, you may exercise your right to data erasure (subject to legal retention obligations) and close your Account.
15.1 For any questions, concerns, or requests relating to this Privacy Policy or the personal data phfairy holds about you, please contact our Data Protection Officer through the following channels:
15.2 If you are not satisfied with phfairy's response to your data subject rights request, or believe phfairy has violated your rights under RA 10173, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.
phfairy is fully compliant with the Philippine Data Privacy Act of 2012 (RA 10173). We are registered with the National Privacy Commission and have appointed a Data Protection Officer to oversee compliance.
All data transmitted between your device and phfairy is encrypted with 256-bit SSL — the same standard used by Philippine banks like BPI and BDO. Your passwords are stored as cryptographic hashes, never in plaintext.
phfairy never sells, rents, or trades your personal data to third parties for their marketing purposes. We share data only with service providers bound by processing agreements, and with regulators as required by Philippine law.
Access, correct, delete, or port your data. Object to marketing. Lodge complaints with the NPC. phfairy responds to all data rights requests within 30 days and treats every request with seriousness.
In the event of a personal data breach that may harm your rights, phfairy will notify you and the National Privacy Commission within 72 hours, as required by RA 10173. Transparency is non-negotiable.
phfairy does not knowingly collect data from persons under 21. All phfairy accounts require age verification. If we discover underage access, the Account is immediately suspended and data deleted to the extent legally permitted.
Our Data Protection Officer and support team are available 24/7 to address any privacy concerns, data access requests, or questions about how phfairy handles your personal information.