phruby Privacy Policy

01 Introduction

phruby ("phruby," "we," "us," or "our") operates the online gaming platform available at phruby.org. We understand that your personal data is important to you, and we take our responsibility as a data controller seriously. This Privacy Policy describes how phruby collects, uses, stores, shares, and protects the personal information of players and visitors ("you" or "the User") in connection with the phruby platform and all related services.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. It should be read together with the phruby Terms & Conditions and Responsible Gaming Policy.

By registering for a phruby account or using any phruby service, 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.

02 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, phruby is the personal information controller in respect of the personal data collected through the phruby platform. This means phruby determines the purposes and means of processing your personal data.

phruby has designated a Data Protection Officer ( "DPO") responsible for overseeing data protection compliance at phruby. You may contact the DPO regarding any data privacy concerns using the contact details provided in Section 16 of this Policy.

03 Data We Collect

phruby collects the following categories of personal data:

phruby does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly required for identity verification and regulatory compliance. We do not collect biometric data, health information, or political affiliations.

04 How We Collect Your Data

phruby collects personal data through the following means:

4.1 Directly From You

• When you register a phruby account and complete the registration form.
• When you submit KYC documents for identity verification.
• When you make deposits or request withdrawals through the phruby cashier.
• When you contact phruby customer support via live chat or email.
• When you respond to surveys, promotions, or competitions run by phruby.

4.2 Automatically

• Through cookies and similar tracking technologies when you browse phruby.org (see Section 9).
• Through server logs that record your IP address, device information, and access times.
• Through our gaming platform, which records all game activity associated with your account.

4.3 From Third Parties

• From identity verification service providers used to assist with KYC compliance.
• From payment processors (e.g., GCash, PayMaya, banks) to confirm transaction details.
• From fraud prevention and anti-money laundering screening services.

05 How We Use Your Data

phruby uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your phruby account.
• Identity Verification: To verify your identity and age (21+) as required by Philippine gaming regulations.
• Payment Processing: To process deposits and withdrawals via your registered payment methods.
• Regulatory Compliance: To meet our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and unauthorized account access.
• Responsible Gaming: To monitor gaming patterns and apply responsible gaming tools where necessary, including self-exclusion enforcement.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Service Improvement: To analyze usage patterns and improve the phruby platform, games, and user experience.
• Marketing Communications: To send you promotional offers and updates about phruby, where you have consented to receive such communications. You may opt out at any time.

06 Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform the contract between you and phruby (i.e., to operate your account and deliver gaming services).
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA, and the Data Privacy Act.
• Legitimate Interests: Processing necessary for phruby's legitimate interests in fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

07 Data Sharing & Disclosure

phruby may share your personal data with the following categories of recipients:

7.1 Service Providers

phruby engages trusted third-party service providers to assist in operating the platform, including KYC verification providers, payment processors (GCash, PayMaya, Philippine banks), IT infrastructure providers, and customer support tools. These providers are contractually bound to process your data only on phruby's instructions and in accordance with applicable data protection law.

7.2 Regulatory Authorities

phruby may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government authorities where required by law or in response to a lawful request.

7.3 Game Providers

Certain technical data (such as player session identifiers) may be shared with phruby's game content providers solely for the purpose of delivering game services. These providers do not receive your full identity or financial data.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of phruby's business assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

08 Data Retention

phruby retains your personal data for as long as your account is active and for a period thereafter as required by applicable Philippine law. Specifically:

• Account and KYC data is retained for a minimum of five (5) years after account closure, as required under PAGCOR regulations and the Anti-Money Laundering Act.
• Transaction records are retained for a minimum of five (5) years in accordance with AMLA requirements.
• Gaming history is retained for a minimum of three (3) years for regulatory reporting and dispute resolution purposes.
• Support communications are retained for two (2) years after the resolution of the relevant inquiry.
• Marketing consent records are retained for as long as you remain subscribed and for one (1) year after unsubscription.

After the applicable retention period, personal data is securely deleted or anonymized in accordance with phruby's data disposal procedures.

09 Cookies & Tracking Technologies

phruby uses cookies and similar technologies (such as web beacons and local storage) on phruby.org to enhance your experience, maintain your session, and analyze platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function. These cannot be disabled. They include session cookies that keep you logged in to your phruby account.
• Analytics Cookies: Used to understand how players interact with phruby.org, which pages are most visited, and where errors occur. This data is aggregated and anonymized.
• Functional Cookies: Used to remember your preferences, such as language settings and display options.
• Marketing Cookies: Used to deliver relevant promotional content to you on the phruby platform, where you have consented to marketing communications.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the phruby platform. Strictly necessary cookies cannot be disabled without impacting your ability to use the service.

10 Data Security

phruby implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS encryption for all data transmitted between your device and phruby servers.
• Encryption of sensitive data stored in phruby databases.
• Access controls ensuring that only authorized phruby personnel can access personal data, on a need-to-know basis.
• Regular security assessments and vulnerability testing of the phruby platform.
• Staff training on data protection and information security obligations.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While phruby takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phruby login credentials and for notifying us immediately if you suspect unauthorized access to your account.

11 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phruby:

• Right to be Informed: The right to know what personal data phruby collects about you and how it is used — as described in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phruby holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to phruby's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phruby has violated your data privacy rights.

To exercise any of these rights, please contact the phruby Data Protection Officer using the details in Section 16. phruby will respond to all data subject requests within 15 business days. Some requests may be subject to identity verification before processing.

12 Children's Privacy

If you are a parent or guardian and believe that a minor has registered on phruby, please contact our support team immediately. phruby takes underage gambling prevention seriously and cooperates fully with parents, guardians, and regulatory authorities in such cases.

13 Cross-Border Data Transfers

Some of phruby's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to the Philippines, phruby ensures that appropriate safeguards are in place, such as contractual data protection clauses consistent with NPC guidelines.

phruby will not transfer your personal data internationally without ensuring that adequate protections are in place and, where required, without obtaining your consent.

14 Third-Party Links

The phruby platform may contain links to third-party websites or services (for example, payment provider portals). phruby is not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to data collected by phruby through phruby.org and associated services.

15 Updates to This Privacy Policy

phruby may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. Where changes are material, phruby will notify you by email or by posting a prominent notice on the phruby platform prior to the changes taking effect.

The date of the most recent revision is shown at the top of this page. Your continued use of phruby after the effective date of any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically.

16 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or want to raise a data privacy concern, please contact the phruby Data Protection Officer:

If you are not satisfied with phruby's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.