phluv Casino Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") describes how phluv Casino ("phluv," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "Player") who access or use the phluv Casino website, mobile platform, games, and related services (collectively, the "Platform").

This Policy applies to all personal data processed by phluv in connection with the operation of the Platform, including data collected during account registration, identity verification, gameplay, financial transactions, customer support interactions, and marketing communications.

By registering a phluv 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 with this Policy, please do not use the phluv Platform.

2 Data Controller Information

phluv Casino is the data controller responsible for the personal data collected through the Platform. As data controller, phluv determines the purposes and means of processing your personal information and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

For all privacy-related enquiries, requests, or complaints, you may contact phluv's designated Data Protection Officer (DPO) at the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

phluv collects the following categories of personal data:

Identity & Contact Data:

• Full legal name, date of birth, and gender
• Residential address (including city, province, and postal code)
• Email address and mobile phone number
• Government-issued identification number and document images (e.g., PhilSys ID, passport, driver's license)

Financial Data:

• GCash or PayMaya mobile wallet number
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where used for transactions
• Transaction history, deposit amounts, withdrawal amounts, and account balances

Technical & Usage Data:

• IP address, device type, operating system, and browser type
• Login timestamps, session duration, and pages visited on the Platform
• Game history, wagering activity, and bonus usage
• Geolocation data (city/region level, derived from IP address)

Communications Data:

• Records of customer support interactions via live chat or email
• Responses to surveys, promotions, or feedback requests
• Marketing communication preferences

4 How We Collect Your Data

phluv collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from accredited verification service providers; fraud prevention data from anti-money laundering (AML) screening services; payment confirmation data from GCash, PayMaya, and banking partners.

5 How We Use Your Data

phluv uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your phluv account, including processing deposits, withdrawals, and bonus credits.
• Identity verification: To verify your age (21+), identity, and eligibility to use the Platform in compliance with Philippine gaming regulations.
• Fraud prevention & AML compliance: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyse usage patterns, troubleshoot technical issues, and develop new features and games.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time.
• Responsible gaming: To monitor gaming behaviour and apply responsible gaming tools (deposit limits, self-exclusion) where appropriate.
• Legal compliance: To comply with applicable Philippine laws, regulatory requirements, and court orders.

6 Legal Basis for Processing

phluv 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 (i.e., to operate your phluv account and provide gaming services).
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations and gaming licensing requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

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

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other Philippine payment service providers, solely to process your deposits and withdrawals.
• Identity verification providers: Accredited third-party KYC (Know Your Customer) service providers engaged to verify your identity and age in compliance with Philippine gaming regulations.
• AML screening services: Third-party anti-money laundering and fraud detection platforms used to screen transactions and player activity against regulatory watchlists.
• IT and platform service providers: Cloud hosting, data storage, and cybersecurity vendors who process data on phluv's behalf under strict data processing agreements.
• Regulatory authorities: Philippine government agencies, including the National Privacy Commission (NPC) and relevant gaming regulatory bodies, where disclosure is required by law or court order.
• Professional advisers: Legal counsel, auditors, and compliance consultants, where necessary for the conduct of phluv's business operations.

All third parties with whom phluv shares personal data are required to handle such data in accordance with applicable Philippine data protection law and phluv's data protection standards. phluv does not transfer personal data outside the Philippines except where necessary and subject to appropriate safeguards.

8 Cookies & Tracking Technologies

phluv uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how you use the Platform.

phluv uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting core Platform functionality.
• Performance & analytics cookies: Used to collect anonymised data about how players navigate the Platform, which pages are visited most frequently, and where errors occur. This data helps phluv improve the user experience.
• Functional cookies: Used to remember your preferences, such as language settings, display options, and responsible gaming tool configurations.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of phluv's marketing campaigns. These are only set with your consent.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phluv Platform. For marketing cookies, you may withdraw consent by updating your communication preferences in your phluv account settings.

9 Data Retention

phluv retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting obligations.

Specific retention periods applicable to phluv player data include:

• Account data: Retained for the duration of your active phluv account and for a minimum of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Identity verification documents: Retained for the duration of your account and for five (5) years following account closure.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter as evidence of prior consent.

Upon expiry of the applicable retention period, phluv will securely delete or anonymise your personal data in accordance with its data disposal procedures.

10 Your Rights Under Philippine Law

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by phluv:

• Right to be informed: The right to know that your personal data is being collected and processed, and to receive clear information about how it is used.
• Right of access: The right to request a copy of the personal data phluv holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data in your phluv account.
• 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 phluv's 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 file a complaint with the National Privacy Commission (NPC) if you believe phluv has violated your data privacy rights.

To exercise any of these rights, please contact phluv's Data Protection Officer using the details in Section 14. phluv will respond to all verified requests within fifteen (15) business days, or within such extended period as permitted by applicable law.

11 Data Security

phluv implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and phluv's servers.
• AES-256 encryption for sensitive data stored in phluv's databases.
• Two-factor authentication (2FA) available for all phluv player accounts.
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• 24/7 intrusion detection and monitoring systems.
• Secure data disposal procedures for physical and electronic records.

While phluv takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, phluv will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by Philippine law.

12 Children's Privacy

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

If phluv becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all associated data will be deleted, and any deposited funds will be returned to the payment source after deducting amounts already wagered. Parents and guardians who believe their child may have registered on the phluv Platform are encouraged to contact our support team immediately.

13 Changes to This Policy

phluv reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. Where changes are material, phluv will provide advance notice via email to your registered address or via a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when this Policy was most recently revised. Your continued use of the phluv Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically.

14 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or phluv's data practices, please contact our Data Protection Officer: