Privacy Policy

1. Scope & Application

This Privacy Policy applies to all personal information collected, processed, stored, and disclosed by phlaro (referred to herein as "phlaro," "we," "us," or "our") in connection with the operation of the phlaro online gaming platform accessible at phlaro.cam (the "Platform") and all related services, applications, and communications.

This Policy applies to all persons who interact with phlaro, including registered players, visitors to the Platform, applicants, and any individual whose personal data we handle. By accessing 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.

This Policy should be read alongside phlaro's Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference. In the event of any conflict between this Privacy Policy and a separate agreement you have entered into with phlaro, the terms of that separate agreement shall prevail.

2. Personal Data We Collect

phlaro collects personal data that is necessary to provide our gaming services, comply with our legal and regulatory obligations, and improve your experience on the Platform. The categories of personal data we collect include:

2.1 Identity & Account Data

• Full legal name as it appears on a government-issued identification document.
• Date of birth and age verification information.
• Gender (optional, collected to personalize your experience).
• Username and encrypted account password.
• Profile photograph (if voluntarily uploaded).
• Government-issued identification number (e.g., PhilSys National ID, SSS, UMID, passport, or driver's license number).

2.2 Contact Data

• Email address (primary and secondary, if provided).
• Philippine mobile number (used for OTP verification and support).
• Residential address including barangay, city or municipality, province, and postal code.

2.3 Financial & Payment Data

• GCash account number or registered mobile number.
• PayMaya account details.
• Bank account details (BPI, BDO, Metrobank, or other Philippine bank accounts) where provided for withdrawals.
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references.
• KYC documentation, including proof of payment method ownership.

2.4 Gaming Activity Data

• Game session logs, including games played, bet amounts, game results, and session durations.
• Bonus and promotion uptake history.
• Responsible gaming tool settings, including deposit limits, loss limits, and self-exclusion records.
• Player account balance history and transaction logs.

2.5 Technical & Usage Data

• IP address and geolocation data at the time of login and key account actions.
• Device type, operating system, browser type and version.
• Pages visited, time spent on page, navigation paths, and click data.
• Session timestamps and access logs.
• Cookie identifiers and similar tracking technology data (see Section 9).

2.6 Communications Data

• Customer support chat transcripts and email correspondence.
• Feedback, survey responses, and promotional opt-in preferences.
• Records of any complaints or disputes submitted to phlaro.

3. How We Collect Your Data

phlaro collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, contact support, or respond to promotions.
• Automatically: Through cookies, server logs, and tracking technologies when you access or use the Platform (see Section 9).
• From third-party payment processors: GCash, PayMaya, and partner banks may share transaction confirmation data with phlaro to verify deposits and withdrawals.
• From identity verification services: phlaro may use third-party KYC and identity verification providers to validate the authenticity of documents submitted during registration or account review.
• From fraud prevention and AML screening services: phlaro uses third-party screening tools to comply with anti-money laundering obligations under Philippine law.
• From game providers: Our partner game studios (e.g., Evolution Gaming, Pragmatic Play) may provide session and outcome data to phlaro for dispute resolution and integrity monitoring purposes.

4. Purposes of Processing

phlaro processes your personal data for the following specific purposes:

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our agreement with you, including account management, payment processing, and game access.
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Tax Code.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests do not override your privacy rights.
• Consent: For optional processing such as marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

phlaro does not sell your personal data to any third party. We may share your data only in the following circumstances and only to the extent necessary for the stated purpose:

6.1 Service Providers

We engage trusted third-party service providers to assist in delivering the Platform, including payment processors (GCash, PayMaya, partner banks), identity verification providers, cloud hosting and infrastructure providers, customer support software vendors, and analytics platforms. All service providers are contractually bound to process your data only on our instructions and to maintain appropriate security standards.

6.2 Game Providers

Where necessary to resolve a game dispute or investigate a technical issue, phlaro may share relevant session data with the game studio that supplied the game in question (e.g., Evolution Gaming, Pragmatic Play, Microgaming). Sharing is limited to the data strictly required for the investigation.

6.3 Regulatory & Legal Authorities

phlaro is required by Philippine law to share certain player data with regulatory bodies including PAGCOR and the Anti-Money Laundering Council (AMLC) upon lawful request. We may also disclose data to courts, law enforcement agencies, or other government authorities where required by a valid legal order or to protect the rights, property, or safety of phlaro, its players, or the public.

6.4 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving phlaro, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such change in data controller via the email address registered to your account.

7. Data Retention

phlaro retains your personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law. Our standard retention periods are as follows:

• Active account data: Retained for the duration of your account and for a minimum of 5 years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements.
• Financial transaction records: Retained for a minimum of 10 years from the date of the transaction, as required under Philippine tax and AML regulations.
• KYC and identity verification documents: Retained for the duration of your account and for 5 years after account closure.
• Customer support records: Retained for 3 years from the date of the last interaction.
• Marketing preferences and consent records: Retained for the duration of your account or until consent is withdrawn, whichever comes first.
• Technical and usage logs: Retained for 12 months from the date of collection, unless longer retention is required for security investigation purposes.

Upon expiration of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification.

8. Security Measures

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phlaro Platform.
• Encryption of sensitive data fields (including passwords and financial credentials) at rest using industry-standard algorithms.
• Two-factor authentication (2FA) available for all player accounts.
• Real-time fraud monitoring and anomaly detection systems that flag suspicious account activity for review.
• Strict access controls limiting staff access to personal data on a need-to-know basis, with full access audit logging.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform infrastructure.
• Staff training on data privacy obligations and information security protocols.
• Incident response procedures designed to detect, contain, and notify affected parties of any data breach in accordance with the requirements of the National Privacy Commission (NPC).

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed as completely secure. If you become aware of any unauthorized access to your phlaro account, please contact our support team immediately.

9. Cookies & Tracking Technologies

phlaro uses cookies and similar tracking technologies (such as web beacons, pixel tags, and local storage objects) to improve Platform functionality, analyze usage patterns, and support our security and fraud prevention systems.

9.1 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens, and language preference settings. These cannot be disabled without impairing Platform functionality.
• Performance and analytics cookies: Used to collect aggregated, anonymized data about how players interact with the Platform, which pages are visited most frequently, and where errors occur. This data helps us improve the Platform.
• Functional cookies: Used to remember your preferences (such as game lobby layout, currency display, and responsible gaming settings) to provide a more personalized experience.
• Marketing cookies: Used with your consent to track activity across sessions for the purpose of serving relevant phlaro promotions within the Platform. We do not place third-party advertising cookies.

9.2 Cookie Management

You can manage your cookie preferences through your browser settings or through the cookie preference center available on the Platform. Disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled via browser settings without breaking core Platform features.

10. Your Data Privacy Rights

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 phlaro:

• Right to be informed: To be notified about the collection and processing of your personal data, as set out in this Privacy Policy.
• Right of access: To request a copy of the personal data phlaro holds about you, along with information about how it is being processed.
• Right to rectification: To request that inaccurate or incomplete personal data be corrected or updated. You may update most account information directly from your account dashboard.
• Right to erasure: To request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations. Note that data required for PAGCOR or AMLC compliance cannot be deleted until mandatory retention periods have expired.
• Right to data portability: To receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller where technically feasible.
• Right to object: To object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time via the unsubscribe link in any promotional email or by contacting our support team.
• Right to withdraw consent: Where processing is based on your consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: To lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact phlaro's Data Protection Officer (see Section 14). We will respond to verified requests within 30 days. We may need to verify your identity before processing certain requests.

11. Minors & Age Policy

phlaro's services are strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. We do not knowingly collect or process personal data from individuals under the age of 21.

During account registration, all users are required to provide their date of birth and confirm that they meet the minimum age requirement. phlaro reserves the right to request additional age verification documentation at any time. Accounts found to belong to individuals under 21 will be immediately closed, all funds will be refunded to the payment source, and the matter may be reported to relevant authorities.

If you believe that a minor has registered an account on phlaro, please contact our support team immediately at the details provided in Section 14.

12. International Data Transfers

Some of phlaro's service providers and game studio partners are based outside the Philippines. When personal data is transferred to recipients in other countries, phlaro takes steps to ensure that an equivalent level of data protection applies, including:

• Using data processing agreements that incorporate standard contractual clauses approved by the National Privacy Commission or recognized international equivalents.
• Limiting cross-border data transfers to service providers in jurisdictions with adequate data protection laws or subject to binding corporate rules.
• Ensuring that any international transfer of financial or KYC data is subject to encryption both in transit and at rest.

By using the phlaro Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

13. Updates to This Privacy Policy

phlaro reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. When material changes are made, we will notify registered players via their registered email address and by posting a prominent notice on the Platform at least 7 days before the changes take effect.

The "Last Updated" date at the top of this Policy will reflect the most recent revision. Your continued use of the Platform after the effective date of any changes constitutes your acknowledgment of the updated Policy. If you do not agree with a material change, you should close your account before the changes take effect.

14. Contact & Data Protection Officer

phlaro has designated a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, you may contact us through the following channels:

• Live Chat: Available 24/7 inside your phlaro account dashboard — the fastest way to reach us for urgent data privacy matters.
• Email: [email protected] — please include "Privacy Request" or "Data Privacy" in the subject line so your message reaches the DPO team directly.
• Response Time: We aim to acknowledge all data privacy requests within 5 business days and resolve them within 30 days of acknowledgment.

If you are not satisfied with phlaro's response to your data privacy request, you have the right to escalate your concern to the National Privacy Commission of the Philippines.