phlari Privacy Policy

1. Introduction

phlari ("phlari," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our online casino and sports betting platform (the "Platform"). This Privacy Policy ("Policy") describes how phlari collects, uses, stores, shares, and protects your personal information when you access or use the Platform, whether through our website or any associated mobile interface.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. It should be read together with our Terms & Conditions and Responsible Gaming Policy.

By registering a phlari account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, please discontinue use of the Platform and contact us to close your account.

2. Data Controller

phlari is the data controller responsible for your personal information collected through the Platform. As data controller, phlari determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data privacy laws.

For all data privacy inquiries, requests, and complaints, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

phlari collects the following categories of personal data from players:

phlari does not collect sensitive personal information (as defined under RA 10173) unless strictly required for regulatory compliance, in which case explicit consent will be obtained.

4. How We Collect Your Data

phlari collects your personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment data from GCash, PayMaya, and banking partners where necessary to process transactions.
• Publicly available sources: Information from public records or databases where required for regulatory compliance or fraud prevention purposes.

5. How We Use Your Personal Data

phlari uses your personal data for the following purposes:

• To create, manage, and maintain your phlari account.
• To verify your identity and age in compliance with Philippine gaming regulations (21+ requirement).
• To process deposits and withdrawals through your chosen payment method (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank).
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities in compliance with the Anti-Money Laundering Act (AMLA) of the Philippines.
• To provide customer support and resolve disputes.
• To monitor gaming activity for responsible gaming purposes, including identifying players who may be at risk of problem gambling.
• To send you transactional communications (account confirmations, deposit receipts, withdrawal notifications).
• To send you promotional communications and offers, where you have provided consent to receive them.
• To improve the Platform's performance, security, and user experience.
• To comply with our legal and regulatory obligations under Philippine law and PAGCOR requirements.

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you (i.e., operating your phlari account, processing transactions).
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for phlari's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such 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 consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

phlari does not sell your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors and banking partners (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank) — to process your deposits and withdrawals.
• Identity verification and KYC providers — to verify your identity and age as required by Philippine gaming regulations.
• Anti-money laundering and fraud prevention services — to screen transactions and comply with AMLA obligations.
• Game software providers — who supply the games available on the Platform and may receive limited technical data necessary to deliver gameplay.
• IT and cloud infrastructure providers — who host and maintain the Platform's servers and systems under strict data processing agreements.
• Regulatory and law enforcement authorities — including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where required by law or court order.
• Professional advisers — including lawyers, auditors, and accountants, where necessary for legal, compliance, or financial purposes, subject to professional confidentiality obligations.

All third parties with whom phlari shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and are prohibited from using your data for any purpose beyond what is strictly necessary.

phlari does not transfer your personal data outside the Philippines unless adequate data protection safeguards are in place and such transfer is permitted under the Data Privacy Act of 2012 and its Implementing Rules.

8. Cookies and Tracking Technologies

phlari uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit our website. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming limits you have set.
• Analytics cookies: Collect anonymized data about how players use the Platform — which pages are visited most, how long sessions last, and where errors occur — to help us improve performance.
• Marketing cookies: Used only where you have provided consent, to deliver relevant promotional content within the Platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. phlari does not use third-party advertising networks or place cookies for the benefit of external advertisers.

9. Data Retention

phlari retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required under Philippine AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA requirements.
• Customer support communications: Retained for three (3) years from the date of the interaction, or longer if related to an ongoing dispute or legal proceeding.
• Marketing preference records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent.
• Technical and usage logs: Retained for up to twelve (12) months for security and performance purposes, unless required longer for an active investigation.

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

10. Security Measures

phlari implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls ensuring that only authorized phlari personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits, vulnerability assessments, and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While phlari takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, phlari will notify you and the National Privacy Commission as required by law.

11. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phlari:

• Right to be informed: The right to know that your personal data is being collected and processed, and the purposes for which it is used — as set out in this Policy.
• Right of access: The right to request a copy of the personal data phlari holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure or blocking: The right to request deletion or blocking 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 where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. phlari will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

12. Minors and Age Restriction

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

If phlari discovers or has reason to believe that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and report the matter to the appropriate regulatory authority where required.

If you are a parent or guardian and believe that your child has provided personal data to phlari, please contact us immediately at the details provided in Section 14 so we can take prompt action.

13. Changes to This Privacy Policy

phlari reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect, where practicable.

The most current version of this Policy will always be available on this page, with the effective date indicated at the top. Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this page periodically to stay informed about how phlari protects your data.

14. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way phlari handles your personal data, please contact our Data Protection Officer (DPO):

phlari Data Protection Officer
Email: [email protected] (plain text — not a clickable link)
Available: Monday to Sunday, 24 hours a day

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to file a complaint with the NPC is available through official Philippine government channels.

For responsible gaming concerns, please visit our Responsible Gaming page for dedicated support resources.