phcity1 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how phcity1 ("phcity1," "we," "us," or "our") collects, uses, stores, and protects the personal data of individuals ("you," "Player," or "User") who access or use the phcity1 online gaming platform at phcity1.net, including all associated games, features, and services.

phcity1 is committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy should be read together with the phcity1 Terms & Conditions. In the event of any conflict between this Policy and the Terms & Conditions on matters relating to data privacy, this Policy shall prevail.

2. Data Controller

phcity1 acts as the data controller in respect of the personal data collected through the phcity1 platform. As data controller, phcity1 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy laws.

phcity1 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and with the Data Privacy Act of 2012. Contact details for the DPO are provided in Section 15 of this Policy.

3. Data We Collect

3.1 Registration Data

When you create a phcity1 account, we collect the following personal data:

• Full legal name;
• Date of birth (to verify that you are 21 years of age or older);
• Residential address in the Philippines (city, province, barangay);
• Email address and/or mobile number;
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with Philippine gaming regulations and anti-money laundering requirements, we collect:

• Government-issued photo ID (e.g., PhilSys National ID, passport, driver's license, SSS/GSIS ID, PRC ID, or Voter's ID);
• Proof of address documents (e.g., utility bill, bank statement, or barangay certificate);
• Proof of payment method ownership where required.

3.3 Financial Data

When you make deposits or request withdrawals, we collect transaction records including payment method details (e.g., GCash account reference, Maya account reference, or bank account details), transaction amounts in Philippine Peso (PHP), and transaction timestamps. phcity1 does not store full payment card numbers or full bank account numbers on its servers.

3.4 Gaming Activity Data

We collect records of your gaming activity on the phcity1 platform, including games played, bets placed, wins and losses, session durations, and bonus usage. This data is used for account management, responsible gaming monitoring, and regulatory compliance.

3.5 Technical and Device Data

When you access phcity1, we automatically collect certain technical data, including:

• IP address and approximate geographic location;
• Device type, operating system, and browser type;
• Pages visited, features used, and time spent on the platform;
• Cookie identifiers and session tokens (see Section 8).

3.6 Communications Data

If you contact phcity1 customer support, we retain records of your communications, including the content of messages, support tickets, and chat transcripts, for quality assurance and dispute resolution purposes.

4. How We Collect Your Data

phcity1 collects your personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion;
• Automatically — through cookies, web beacons, and similar tracking technologies when you access and use the phcity1 platform (see Section 8);
• From third parties — from identity verification service providers, payment processors, and fraud prevention services that assist us in operating the platform and complying with our legal obligations.

5. How We Use Your Data

phcity1 uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phcity1 player account;
• Identity verification: To verify your identity and age (21+) in compliance with Philippine gaming regulations;
• Payment processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• Regulatory compliance: To comply with our obligations under Philippine gaming regulations, anti-money laundering laws, and the Data Privacy Act of 2012;
• Responsible gaming: To monitor gaming activity and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct;
• Platform improvement: To analyze usage patterns and improve the phcity1 platform, games, and services;
• Marketing communications: To send you promotional offers and updates about phcity1, where you have opted in to receive such communications.

6. Legal Basis for Processing

phcity1 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform our contract with you (i.e., to provide the phcity1 gaming service) — this covers account management, payment processing, and customer support;
• Legal obligation: Processing is necessary to comply with our legal obligations under Philippine gaming regulations, anti-money laundering laws, and tax laws — this covers KYC verification and transaction record-keeping;
• Legitimate interests: Processing is necessary for our legitimate interests in operating a secure and fair gaming platform — this covers fraud prevention, security monitoring, and platform improvement, provided these interests are not overridden by your rights;
• Consent: Where we rely on your consent as the legal basis for processing — specifically for marketing communications — you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7. Sharing Your Data

7.1 Service Providers

phcity1 shares your personal data with carefully selected third-party service providers who assist us in operating the platform. These include identity verification providers, payment processors (GCash, Maya, and banking partners), game software providers, cloud hosting providers, and customer support platforms. All service providers are required to process your data only on our instructions and in accordance with data processing agreements that impose obligations equivalent to those in this Policy.

7.2 Regulatory and Law Enforcement Authorities

phcity1 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government authorities where required by law, court order, or regulatory requirement. phcity1 will notify you of such disclosures where permitted by law.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of phcity1's business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it.

7.4 No Sale of Personal Data

phcity1 does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. Your data is yours — we are merely its custodian.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit the phcity1 platform. They allow us to recognize your device, remember your preferences, and analyze how you use the platform. phcity1 uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function — these cannot be disabled. They include session authentication tokens and security cookies;
• Functional cookies: Remember your preferences such as language settings and game display options;
• Analytics cookies: Help us understand how players use the platform so we can improve it. Data collected is aggregated and anonymized where possible;
• Marketing cookies: Used to deliver relevant promotional content to you, where you have consented to receive marketing communications.

8.2 Managing Cookies

You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phcity1 platform. Strictly necessary cookies cannot be disabled as they are essential for the platform to operate securely.

9. Data Security

phcity1 implements a comprehensive set of technical and organizational security measures to protect your personal data, including:

• TLS/SSL encryption for all data transmissions between your device and phcity1 servers;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of the phcity1 platform;
• Multi-factor authentication for administrative access to phcity1 systems;
• Incident response procedures for detecting, reporting, and responding to personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phcity1 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

While phcity1 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials.

10. Data Retention

phcity1 retains your personal data for the following periods:

• Account data: For the duration of your account and for five (5) years following account closure, as required by Philippine gaming regulations and anti-money laundering laws;
• KYC and identity verification data: For five (5) years following account closure or the completion of the relevant transaction, whichever is later;
• Financial transaction records: For five (5) years following the date of the transaction, in compliance with Philippine tax and anti-money laundering laws;
• Gaming activity records: For three (3) years following the date of the activity, or longer if required by regulatory authorities;
• Customer support communications: For two (2) years following the resolution of the relevant inquiry or dispute;
• Marketing consent records: For as long as you remain opted in, and for one (1) year following withdrawal of consent.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, phcity1 will securely delete or anonymize the data.

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 in respect of your personal data held by phcity1:

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which is the purpose of this Privacy Policy;
• Right of access: The right to request a copy of the personal data phcity1 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• 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 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 legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the phcity1 Data Protection Officer using the contact details in Section 15. phcity1 will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with the Data Privacy Act of 2012.

12. Children's Privacy

The phcity1 platform is strictly restricted to individuals who are 21 years of age or older. phcity1 does not knowingly collect personal data from persons under 21 years of age. If phcity1 becomes aware that personal data has been collected from an underage individual, the relevant account will be immediately closed, all data will be deleted, and the matter may be reported to the relevant Philippine authorities.

13. Third-Party Links

The phcity1 platform may contain links to third-party websites or services. This Privacy Policy applies only to the phcity1 platform and does not cover the privacy practices of any third-party websites. phcity1 is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party websites you visit.

14. Updates to This Privacy Policy

phcity1 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, phcity1 will notify registered players via email or through a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the phcity1 platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the amended Policy, you must cease using the platform and may request account closure in accordance with the phcity1 Terms & Conditions.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by phcity1, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that phcity1 has violated your data privacy rights. Information about the NPC's complaint procedures is available on the NPC's official website.