phspin 7 Privacy Policy

1 Introduction

phspin 7 is committed to protecting the privacy and personal data of all players who use our platform. This Privacy Policy applies to all personal data collected through the phspin 7 website, mobile application, and any related services (collectively, the "Platform").

This Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. phspin 7 takes its obligations as a personal information controller seriously and is committed to handling your data with care, transparency, and respect.

Please read this Policy carefully. If you have any questions about how phspin 7 handles your personal data, you may contact our Data Protection Officer using the details provided in Section 15 of this Policy.

2 Data Controller

phspin 7 acts as the personal information controller in respect of the personal data collected through the Platform. As the data controller, phspin 7 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

phspin 7 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at the email address provided in Section 15 of this Policy.

3 Personal Data We Collect

phspin 7 collects the following categories of personal data from players and platform users:

phspin 7 does not collect sensitive personal information beyond what is strictly necessary for identity verification, regulatory compliance, and responsible gaming obligations.

4 How We Collect Your Data

phspin 7 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 8 for more details on cookies.
• Third-party sources: Identity verification data from government databases or third-party KYC service providers; payment data from GCash, PayMaya, and banking partners; fraud prevention data from third-party screening services.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with our licensing and compliance obligations.

5 How We Use Your Personal Data

phspin 7 uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phspin 7 player account, including verifying your identity and age (21+ requirement).
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of phspin 7 platform services.
• Regulatory compliance: To comply with our obligations under PAGCOR regulations, anti-money laundering (AML) laws, and the Philippine Data Privacy Act of 2012.
• Responsible gaming: To monitor gaming activity, identify signs of problem gambling, enforce self-exclusion requests, and administer responsible gaming tools.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your consent to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the phspin 7 platform experience for all players.

6 Legal Basis for Processing

phspin 7 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — including account creation, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable laws and regulations, including PAGCOR licensing requirements, AML obligations, and tax reporting duties.
• Legitimate interests: Processing necessary for phspin 7's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing and Disclosure

phspin 7 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment processors, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where required by law or regulatory obligation.
• Technology service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, where necessary for the conduct of phspin 7's business.
• Business transfers: In the event of a merger, acquisition, or sale of phspin 7's business assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom phspin 7 shares personal data are required to handle such data in accordance with applicable data protection laws and phspin 7's data protection standards.

8 Cookies and Tracking Technologies

phspin 7 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The following types of cookies are used:

• Essential cookies: Strictly necessary for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Analytics cookies: Used to collect anonymized data about how players use the Platform, helping us identify areas for improvement. These are only set with your consent.
• Preference cookies: Used to remember your settings and preferences, such as language and display options, to personalize your experience.
• Marketing cookies: Used to deliver relevant promotional content. These are only set where you have consented to receive marketing communications from phspin 7.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phspin 7 Platform.

9 Data Retention

phspin 7 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AML regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Marketing data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymized within thirty (30) days.
• Technical and log data: Retained for up to twelve (12) months for security and fraud prevention purposes.

When personal data is no longer required, phspin 7 will securely delete or anonymize it in accordance with our data disposal procedures.

10 Data Security

phspin 7 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the phspin 7 Platform
• Encryption of sensitive data at rest, including financial information and identity documents
• Role-based access controls limiting data access to authorized personnel only
• Regular security audits, vulnerability assessments, and penetration testing
• Two-factor authentication (2FA) options for player accounts
• Continuous monitoring for suspicious activity and potential data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phspin 7 will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act of 2012 and NPC Circular No. 16-03.

11 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phspin 7:

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data phspin 7 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, subject to our legal and regulatory retention obligations.
• Right to object: The right to object to the processing of your personal data, including for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used 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 rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the email address provided in Section 15. phspin 7 will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12 Children's Privacy and Age Restriction

The phspin 7 Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with Philippine gaming regulations. phspin 7 does not knowingly collect personal data from individuals under the age of 21.

If phspin 7 becomes aware that personal data has been collected from a person under 21 years of age, we will immediately close the relevant account, delete the associated personal data, and refund any deposits made. If you believe that a minor has registered on the phspin 7 Platform, please contact our support team immediately.

13 International Data Transfers

phspin 7 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international payment processors.

Where such transfers occur, phspin 7 ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses that meet the standards required by the Philippine Data Privacy Act of 2012 and NPC regulations. phspin 7 will not transfer your personal data to countries that do not provide an adequate level of data protection without your explicit consent or appropriate contractual safeguards.

14 Updates to This Privacy Policy

phspin 7 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material, phspin 7 will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the phspin 7 Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how phspin 7 protects your personal data.

15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phspin 7, please contact our Data Protection Officer:

Data Protection Officer — phspin 7
Email: privacy@phspin-7.com

For general customer support inquiries, you may also reach our support team at: support@phspin-7.com

phspin 7 aims to respond to all privacy-related inquiries within fifteen (15) business days. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.