Privacy Policy

1. Introduction

phokd ("phokd," "we," "us," or "our") operates the online gaming platform available at phokd.app. We are committed to protecting the privacy and personal data of all individuals who interact with our platform, including registered players, visitors, and prospective users (collectively, "you" or "your").

This Privacy Policy ("Policy") describes how phokd collects, uses, discloses, stores, and protects your personal information in connection with your use of the phokd platform and all associated services. It also explains the rights available to you under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and how to exercise those rights.

By registering a phokd account, accessing the platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, please do not use the phokd platform.

This Policy should be read together with our Terms & Conditions and Responsible Gaming policy, both of which are incorporated herein by reference.

2. Personal Data We Collect

phokd collects personal data that is necessary to provide our services, comply with legal and regulatory obligations, and maintain the security and integrity of the platform. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — phokd is strictly for players aged 21 and above);
• Nationality and country of residence;
• Email address and Philippine mobile number;
• Username and encrypted password.

2.2 KYC & Verification Data

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, SSS ID, UMID card, or PhilSys national ID);
• Proof of address documents (e.g., utility bills, bank statements issued within the last three months);
• Selfie or liveness verification images where required for identity confirmation;
• Source of funds documentation where required under anti-money laundering regulations.

2.3 Financial & Transaction Data

• GCash account details, PayMaya account details, or bank account information (BPI, BDO, Metrobank, UnionBank) used for deposits and withdrawals;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references;
• Wagering history and game activity records.

2.4 Technical & Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, browser type and version;
• Session duration, pages visited, features used, and clickstream data;
• Cookies and similar tracking technology data (see Section 6).

2.5 Communications Data

• Records of your communications with phokd customer support, including live chat transcripts and email correspondence;
• Feedback, survey responses, and promotional opt-in preferences.

3. How We Use Your Personal Data

phokd uses the personal data we collect for the following purposes:

• Account Management: To register and maintain your phokd account, verify your identity, and provide you with access to the platform's features following phokd Login;
• Service Delivery: To process deposits and withdrawals, record gaming activity, calculate and pay out winnings, and provide customer support;
• Legal & Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the DPA, and other applicable Philippine laws and regulations, including mandatory reporting obligations;
• Age Verification: To verify that all players are at least 21 years of age, as required by PAGCOR regulations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, money laundering, and other prohibited activities;
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and content of the phokd platform;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.

4. Legal Basis for Processing

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

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or the use of non-essential cookies;
• Contractual Necessity: Where processing is necessary to perform our obligations under the Terms & Conditions you have agreed to, including account management, payment processing, and service delivery;
• Legal Obligation: Where processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA reporting requirements, and NPC data protection obligations;
• Legitimate Interests: Where processing is necessary for phokd's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.

5. Sharing Your Personal Data

phokd does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing deposits and withdrawals;
• KYC & Identity Verification Providers: Third-party identity verification services engaged to assist with KYC compliance;
• Game Technology Providers: Licensed game software providers whose games are available on the phokd platform, to the extent necessary to deliver game services and resolve disputes;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation;
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other legal process;
• Professional Advisers: Legal counsel, auditors, and other professional advisers engaged by phokd, subject to confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of phokd's assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom phokd shares personal data are required to handle such data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than those specified by phokd.

6. Cookies & Tracking Technologies

phokd uses cookies and similar tracking technologies (such as web beacons and pixel tags) to operate and improve the platform. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: These cookies are essential for the platform to function and cannot be disabled. They include session authentication cookies that keep you logged in to your phokd account and security cookies that protect against cross-site request forgery;
• Performance & Analytics Cookies: These cookies collect anonymised information about how players use the phokd platform, such as which pages are visited most frequently and how long sessions last. This data helps us improve platform performance and user experience;
• Functional Cookies: These cookies remember your preferences, such as your preferred language and display settings, to provide a more personalised experience;
• Marketing Cookies: With your consent, these cookies track your activity on the phokd platform to enable us to deliver relevant promotional content. You may withdraw consent for marketing cookies at any time.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phokd platform.

7. Data Retention

phokd retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account Data: Retained for the duration of your phokd account and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AMLA record-keeping obligations;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and its implementing rules;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by applicable law or ongoing regulatory proceedings;
• Customer Support Records: Retained for a period of three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings;
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, phokd will securely delete or anonymise the data.

8. Data Security

phokd implements appropriate technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phokd platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting access to personal data to authorised personnel on a need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning of platform infrastructure;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Staff training on data protection obligations and information security best practices.

While phokd 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 is likely to result in a risk to your rights and freedoms, phokd will notify the National Privacy Commission and affected individuals in accordance with the requirements of the DPA and its implementing rules.

9. Your Rights Under the DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phokd:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy;
• Right of Access: The right to request a copy of the personal data phokd holds about you and information about how it is being processed;
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you;
• 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 overriding 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 lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact phokd's Data Protection Officer using the contact details provided in Section 13. phokd will respond to all verified requests within the timeframes prescribed by the DPA and its implementing rules.

10. Children's Privacy

The phokd platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. phokd does not knowingly collect personal data from individuals under the age of 21.

If phokd becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered a phokd account or provided us with personal data, please contact us immediately using the details in Section 13.

11. International Data Transfers

phokd primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers or technology partners located outside the Philippines — for example, cloud infrastructure providers or game technology partners operating in other jurisdictions.

Where such transfers occur, phokd ensures that appropriate safeguards are in place to protect your personal data in accordance with the DPA and NPC regulations, including contractual data protection clauses that impose obligations on recipient parties equivalent to those applicable under Philippine law.

12. Changes to This Privacy Policy

phokd reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. The date of the most recent revision is indicated at the top of this page.

When material changes are made to this Policy, phokd will notify registered players via the email address associated with their account and/or by posting a prominent notice on the platform. Your continued use of the phokd platform following the posting of a revised Policy constitutes your acceptance of the changes.

We encourage you to review this Policy periodically to stay informed about how phokd protects your personal information.

13. Contact & Complaints

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

Email: [email protected]

The email address above is provided as plain text for reference only. phokd will acknowledge your request within three (3) business days and will endeavour to resolve your concern within the timeframes prescribed by the DPA.

If you are not satisfied with phokd's response to your data protection concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the DPA.