Privacy Policy

1 Who We Are

PHPSpin is an online gaming platform accessible at https://phpspin.net and through the PHPSpin mobile application. For the purposes of this Privacy Policy, PHPSpin acts as the data controller in respect of all personal data collected from players and visitors to the platform.

As data controller, PHPSpin determines the purposes and means by which your personal data is processed. We are responsible for ensuring that your data is handled lawfully, fairly, and transparently in accordance with applicable Philippine data protection legislation and PAGCOR regulatory requirements.

If you have any questions about how PHPSpin handles your personal data, or if you wish to exercise any of your data rights, please contact us using the details provided in Section 14 of this policy.

2 Data We Collect

PHPSpin collects the following categories of personal data from players and platform visitors:

PHPSpin does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information, except where required by law or where you voluntarily provide such information in the context of a responsible gaming self-assessment.

3 How We Collect Data

PHPSpin collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical data collected automatically when you visit the PHPSpin website or use the mobile application, including through cookies, web beacons, and server logs. See Section 7 for more detail on cookies.
• Third-party sources: Identity and fraud-check data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), identity verification service providers, and fraud prevention agencies, where you have consented to such sharing or where we are legally permitted to receive it.
• Regulatory sources: Information received from PAGCOR or other regulatory bodies in connection with licensing, compliance, or investigation requirements.

Where PHPSpin collects data from third-party sources, we take reasonable steps to verify that the third party had the right to share that data with us and that the data is accurate and up to date.

4 Why We Use Your Data

PHPSpin uses your personal data for the following purposes:

• Account creation and management: To register your account, verify your identity, and maintain your player profile on the PHPSpin platform.
• Service delivery: To provide access to games, process deposits and withdrawals in Philippine Peso (₱), and deliver the features and functionality of the PHPSpin platform.
• Identity verification and KYC: To verify that you meet the eligibility requirements to use PHPSpin, including the 21+ age requirement, and to comply with anti-money laundering (AML) obligations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other prohibited conduct as described in our Terms & Conditions.
• Regulatory compliance: To meet our obligations under applicable Philippine law and PAGCOR regulations, including record-keeping, reporting, and audit requirements.
• Customer support: To respond to your inquiries, resolve disputes, and provide assistance with account or technical issues.
• Responsible gaming: To monitor gaming behavior, apply responsible gaming tools such as deposit limits and self-exclusion, and identify players who may be at risk of problem gambling.
• Platform improvement: To analyze usage patterns, conduct internal research, and improve the features, performance, and security of the PHPSpin platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have opted in to receive such communications. You may opt out at any time.

PHPSpin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for doing so.

5 Legal Basis for Processing

PHPSpin processes your personal data on the following legal bases:

• Contractual necessity: Processing that is necessary to perform our contract with you — that is, to provide the PHPSpin gaming service as described in our Terms & Conditions. This includes account management, payment processing, and game delivery.
• Legal obligation: Processing that is required to comply with applicable laws and regulations, including KYC/AML obligations, PAGCOR reporting requirements, and tax record-keeping.
• Legitimate interests: Processing that is necessary for PHPSpin's legitimate business interests, including fraud prevention, platform security, and internal analytics, provided that such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent — primarily in the context of marketing communications and optional data collection. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Where PHPSpin relies on legitimate interests as a legal basis, we conduct a balancing assessment to ensure that our interests do not override your fundamental rights and freedoms. You may request information about any such assessment by contacting us at the details in Section 14.

6 Data Sharing & Disclosure

PHPSpin 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: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals. These providers process your financial data under their own privacy policies and applicable financial regulations.
• Identity verification providers: Third-party KYC and AML service providers who assist PHPSpin in verifying player identities and screening against sanctions and watchlists.
• Game software providers: Licensed game developers and content providers whose games are available on the PHPSpin platform. These providers may receive anonymized or pseudonymized gaming data for the purpose of game performance monitoring and fairness auditing.
• Regulatory authorities: PAGCOR and other Philippine government agencies, where disclosure is required by law, court order, or regulatory direction.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required in connection with a criminal investigation or legal proceeding.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers who process data on PHPSpin's behalf under strict data processing agreements.
• Professional advisors: Legal counsel, auditors, and compliance consultants, where necessary for PHPSpin to obtain professional advice or conduct internal investigations.

All third parties with whom PHPSpin shares personal data are required to maintain appropriate technical and organizational security measures and to process data only for the purposes for which it was shared. PHPSpin does not authorize any third party to use your personal data for their own independent marketing or commercial purposes.

7 Cookies & Tracking Technologies

PHPSpin uses cookies and similar tracking technologies on its website and mobile application to enhance your experience, maintain session security, and gather analytics data. The following types of cookies may be used:

• Essential cookies: Strictly necessary for the operation of the PHPSpin platform, including session management, login authentication, and security functions. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gaming configurations, so that you do not need to re-enter them on each visit.
• Analytics cookies: Used to collect anonymized data about how players interact with the PHPSpin platform, including pages visited, time spent, and navigation paths. This data helps PHPSpin improve the platform experience.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the PHPSpin platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the PHPSpin platform. PHPSpin does not use third-party advertising cookies or behavioral tracking cookies for the purpose of serving targeted advertisements on external websites.

8 Data Retention

PHPSpin retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AML obligations.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, in compliance with Philippine financial regulations.
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session, for the purposes of dispute resolution and regulatory audit.
• Communications data: Support correspondence and chat logs are retained for a minimum of two (2) years from the date of the last communication.
• Technical and log data: Server logs and technical data are retained for up to twelve (12) months, unless required for longer periods in connection with a security investigation or legal proceeding.
• Marketing consent records: Records of your marketing preferences and consent are retained for the duration of your account and for one (1) year following account closure.

Upon expiry of the applicable retention period, PHPSpin will securely delete or anonymize your personal data in accordance with its internal data disposal procedures. Where data is anonymized rather than deleted, the resulting anonymized data may be retained indefinitely for statistical and analytical purposes, as it can no longer be used to identify you.

9 Data Security

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

• SSL/TLS encryption for all data transmitted between your device and PHPSpin's servers.
• Encryption at rest for sensitive personal and financial data stored on PHPSpin's systems.
• Access controls limiting access to personal data to authorized PHPSpin personnel on a strict need-to-know basis.
• Two-factor authentication options for player accounts to reduce the risk of unauthorized access.
• Regular security audits and penetration testing conducted by qualified cybersecurity professionals.
• Incident response procedures to detect, contain, and respond to data security incidents in a timely manner.
• Staff training on data protection and information security best practices.

While PHPSpin takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, PHPSpin will notify you and the relevant regulatory authorities in accordance with applicable legal requirements.

You also play an important role in keeping your account secure. Please ensure that you use a strong, unique password for your PHPSpin account, enable two-factor authentication where available, and never share your login credentials with anyone.

10 Your Data Rights

Subject to applicable law, you have the following rights in respect of your personal data held by PHPSpin:

• Right of access: You have the right to request a copy of the personal data that PHPSpin holds about you, along with information about how it is being used.
• Right to rectification: You have the right to request that PHPSpin correct any inaccurate or incomplete personal data held about you.
• Right to erasure: You have the right to request that PHPSpin delete your personal data in certain circumstances, such as where the data is no longer necessary for the purposes for which it was collected. Note that this right is subject to PHPSpin's legal obligations to retain certain data.
• Right to restriction: You have the right to request that PHPSpin restrict the processing of your personal data in certain circumstances, such as while a dispute about the accuracy of the data is being resolved.
• Right to data portability: You have the right to receive a copy of the personal data you have provided to PHPSpin in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to object: You have the right to object to the processing of your personal data where PHPSpin relies on legitimate interests as its legal basis, or where your data is being used for direct marketing purposes.
• Right to withdraw consent: Where PHPSpin processes your data on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact PHPSpin's support team using the details in Section 14. We will respond to all data rights requests within thirty (30) days. In complex cases, this period may be extended by a further two months, in which case we will notify you of the extension and the reasons for it.

PHPSpin will not charge a fee for handling data rights requests unless the request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

11 Children & Minors

PHPSpin implements age verification procedures during the registration process to prevent underage individuals from accessing the platform. If PHPSpin becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered an account on PHPSpin or provided personal data to us, please contact our support team immediately using the details in Section 14. We will investigate and take appropriate action as quickly as possible.

12 Third-Party Links

The PHPSpin platform may contain references to third-party services, such as payment providers and game software developers. This Privacy Policy applies only to data collected and processed by PHPSpin directly. PHPSpin is not responsible for the privacy practices of third-party services, and we encourage you to review the privacy policies of any third-party services you interact with in connection with your use of PHPSpin.

PHPSpin does not control the content or data practices of third-party payment providers such as GCash, PayMaya, BPI, BDO, or Metrobank. When you initiate a payment transaction, you will be subject to the privacy policy and terms of service of the relevant payment provider in addition to this policy.

13 Changes to This Policy

PHPSpin 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.

When material changes are made to this policy, PHPSpin will notify registered players via email or through an in-platform notification prior to the changes taking effect, where reasonably practicable. We encourage you to review this policy periodically to stay informed about how PHPSpin protects your personal data.

Your continued use of the PHPSpin platform following the publication of any amendment to this Privacy Policy constitutes your acknowledgment of the updated policy. If you do not agree with any changes, you should cease using the platform and may close your account in accordance with the Terms & Conditions.

14 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or about how PHPSpin handles your personal data, please contact our Data Protection team using the following details:

PHPSpin aims to resolve all privacy-related inquiries and complaints within thirty (30) days of receipt. For complex matters, we will keep you informed of progress and provide a final response within sixty (60) days.

If you are not satisfied with PHPSpin's response to your privacy complaint, you have the right to escalate your complaint to the relevant Philippine data protection authority or to PAGCOR, as appropriate. PHPSpin will cooperate fully with any regulatory investigation into our data protection practices.

For responsible gaming concerns that involve personal data — such as requests to apply self-exclusion or to delete gaming history — please indicate "RESPONSIBLE GAMING – DATA REQUEST" in your message subject line so that your inquiry is directed to the appropriate team without delay.