Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") describes how phmoba ("the Company," "we," "us," or "our") collects, uses, stores, and protects the personal data of individuals ("you," "the Player," "the User") who access or use the phmoba online gaming platform at phmoba.one and any associated mobile-optimized interfaces (collectively, the "Platform").

1.2 phmoba is committed to protecting the privacy and personal data of all its users in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission ("NPC").

1.3 By registering an account on the Platform or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

1.4 This Policy should be read alongside phmoba's Terms & Conditions, which govern your use of the Platform more broadly.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, phmoba acts as the Personal Information Controller ("PIC") in respect of the personal data collected through the Platform.

2.2 As Personal Information Controller, phmoba 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.

2.3 phmoba has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

3.1 phmoba collects the following categories of personal data from its users:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (for age verification purposes);
• Mobile phone number registered in the Philippines;
• Email address;
• Residential address (province, city/municipality).

3.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS ID, Voter's ID);
• Selfie or live photo for facial verification purposes;
• Proof of address documents where required.

3.3 Financial Data

• GCash or PayMaya / Maya account number (last digits only, for verification);
• Bank account details (bank name, account number) for withdrawal processing;
• Transaction history including deposit amounts, withdrawal amounts, and dates;
• Debit card details (card number masked, expiry date) where applicable.

3.4 Account & Gaming Data

• Username and encrypted password;
• Game history, bet amounts, win/loss records, and session durations;
• Bonus and promotion usage history;
• Responsible gaming settings and self-imposed limits;
• Customer support interaction records.

3.5 Technical & Usage Data

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

4. How We Collect Your Data

4.1 Directly from you — when you register an account, complete identity verification, make a deposit or withdrawal, contact customer support, or update your account settings.

4.2 Automatically — through cookies, web beacons, and similar tracking technologies when you access and navigate the Platform (see Section 8 for full details on cookies).

4.3 From third parties — from identity verification service providers, payment processors (GCash, Maya, banks), fraud detection services, and, where applicable, from regulatory authorities such as PAGCOR in connection with licensing compliance obligations.

5. How We Use Your Personal Data

5.1 phmoba uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your phmoba account;
• Identity verification: Confirming your age (21+) and identity in compliance with PAGCOR regulations and AML requirements;
• Payment processing: Processing deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• Platform operation: Delivering game content, calculating results, and maintaining accurate transaction records;
• Customer support: Responding to your queries, complaints, and account-related requests;
• Fraud prevention & security: Detecting and preventing fraudulent activity, money laundering, and unauthorized account access;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling and administering self-exclusion and limit-setting tools;
• Legal compliance: Meeting obligations under Philippine law, PAGCOR regulations, and AML/KYC requirements;
• Platform improvement: Analyzing usage data to improve the performance, features, and user experience of the Platform;
• Marketing communications: Sending promotional offers and updates to players who have opted in to receive such communications (you may opt out at any time).

6. Legal Basis for Processing

6.1 Under the Data Privacy Act of 2012, phmoba processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and phmoba (i.e., operating your account and delivering gaming services);
• Legal obligation: Processing required to comply with applicable Philippine laws, PAGCOR regulations, and AML/KYC obligations;
• 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 provided explicit consent. You may withdraw consent at any time.

7. Data Sharing & Disclosure

7.1 phmoba does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data only in the following circumstances:

• Payment processors: GCash, PayMaya / Maya, and partner banks receive the minimum data necessary to process your deposits and withdrawals;
• Identity verification providers: KYC service providers receive identity documents and biometric data solely for the purpose of verifying your identity;
• Game providers: Third-party game studios receive anonymized session data necessary to deliver game content and calculate results;
• Fraud & security services: Fraud detection providers receive technical data (IP address, device fingerprint) to identify suspicious activity;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies may receive data as required by law or regulatory directive;
• Legal proceedings: Courts, law enforcement agencies, or legal advisors where disclosure is required by a valid court order or legal obligation.

7.2 All third-party service providers engaged by phmoba are contractually required to process your personal data only for the specified purpose, to maintain appropriate security standards, and to comply with applicable Philippine data protection law.

8. Cookies & Tracking Technologies

8.1 phmoba uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyze usage patterns. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled.
• Functional cookies: Remember your language preference, display settings, and responsible gaming limits between sessions.
• Analytics cookies: Collect anonymized data about how players navigate the Platform, which pages are most visited, and where errors occur. This data is used solely to improve the Platform.
• Marketing cookies: Used only where you have given explicit consent, to deliver relevant promotional content within the Platform.

8.2 You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent the Platform from functioning correctly. Disabling analytics or marketing cookies will not affect your ability to play.

9. Data Retention

9.1 phmoba 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 are as follows:

• Account and identity data: Retained for the duration of your account plus five (5) years after account closure, in compliance with AML record-keeping requirements;
• Transaction records: Retained for five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter as evidence of consent;
• Technical and usage data: Retained for thirteen (13) months in anonymized or aggregated form for analytics purposes.

9.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with phmoba's data disposal procedures.

10. Data Security

10.1 phmoba implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phmoba servers;
• Encryption of sensitive data at rest, including identity documents and financial information;
• Role-based access controls ensuring that only authorized personnel can access personal data, and only to the extent necessary for their role;
• Regular penetration testing and security audits conducted by independent third-party security firms;
• Two-factor authentication (2FA) available for all player accounts;
• Automated fraud detection and anomaly monitoring systems operating 24/7.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phmoba will notify the National Privacy Commission within seventy-two (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.

11. Your Data Rights

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

11.2 To exercise any of the above rights, please contact phmoba's Data Protection Officer using the contact details in Section 15. We will respond to all verified requests within thirty (30) calendar days.

12. Children's Privacy

12.1 The phmoba Platform is strictly intended for individuals aged twenty-one (21) years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. phmoba does not knowingly collect personal data from individuals under the age of 21.

12.2 If phmoba becomes aware that personal data has been collected from a person under the age of 21, the account will be immediately closed, all data will be deleted, and any funds held in the account will be returned to the payment source after verification.

12.3 If you are a parent or guardian and believe that your child has registered on the Platform, please contact our support team immediately using the details in Section 15.

13. International Data Transfers

13.1 phmoba's primary servers and data storage infrastructure are located within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, game content providers or cloud infrastructure partners.

13.2 Where personal data is transferred outside the Philippines, phmoba ensures that appropriate safeguards are in place, including contractual data processing agreements that require the recipient to maintain data protection standards equivalent to those required under Philippine law.

13.3 phmoba will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or without implementing appropriate contractual safeguards.

14. Changes to This Privacy Policy

14.1 phmoba reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days before the changes take effect.

14.2 The "Last updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

14.3 We encourage you to review this Policy periodically to stay informed about how phmoba protects your personal data.

15. Contact & Complaints

15.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact phmoba's Data Protection Officer:

15.2 If you are not satisfied with phmoba's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC can be reached through its official government channels.

This Privacy Policy was last reviewed and updated in May 2026 and is effective immediately for all phmoba.one users.