phenjoy Privacy Policy

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1. Overview

phenjoy ("phenjoy," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the phenjoy platform at phenjoy.one. This Privacy Policy ("Policy") describes how phenjoy collects, uses, stores, shares, and protects personal information in connection with the phenjoy website and all related services.

This Policy applies to all users of the phenjoy platform, including registered players, visitors browsing the phenjoy website, and any other individuals whose personal data phenjoy processes in connection with the provision of its services. By registering an account or using the phenjoy platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

phenjoy operates in the Philippines and processes personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC). Where applicable, phenjoy also observes relevant international data protection standards.

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2. Personal Data We Collect

2.1 Information You Provide Directly

When you register for a phenjoy account or interact with the phenjoy platform, we collect personal data that you provide to us directly, including:

• Identity data: Full legal name, date of birth, gender, nationality;
• Contact data: Email address, Philippine mobile number, residential address (including city, province, and postal code);
• Account credentials: Username and encrypted password;
• Identity verification documents: Government-issued photo ID (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS card), proof of address, and selfie photographs submitted for KYC purposes;
• Financial data: GCash account details, PayMaya/Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and debit card details used for deposits and withdrawals;
• Communications: Messages sent to phenjoy support via live chat, email, or any other channel.

2.2 Information Collected Automatically

When you access the phenjoy platform, we automatically collect certain technical and usage data, including:

• Device data: Device type, operating system, browser type and version, screen resolution, and device identifiers;
• Network data: IP address, internet service provider, and approximate geographic location derived from your IP address;
• Usage data: Pages visited, games played, session duration, click patterns, deposit and withdrawal history, and betting activity;
• Cookie data: Information collected via cookies and similar tracking technologies as described in Section 6 of this Policy.

2.3 Information from Third Parties

phenjoy may receive personal data about you from third parties in certain circumstances, including:

• Identity verification and anti-fraud service providers used to verify your identity during the KYC process;
• Payment processors and e-wallet providers (GCash, PayMaya/Maya) in connection with deposit and withdrawal transactions;
• Responsible gaming databases and self-exclusion registries, to verify that you are not subject to a self-exclusion order;
• Regulatory authorities, including PAGCOR, where required by law.

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3. How We Use Your Personal Data

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

Purpose	Data Used
Account registration and management	Identity data, contact data, account credentials
Identity verification (KYC/AML compliance)	Identity data, verification documents, financial data
Processing deposits and withdrawals	Financial data, identity data
Providing and improving platform services	Usage data, device data, cookie data
Customer support and dispute resolution	Identity data, contact data, communications, usage data
Fraud prevention and security monitoring	All categories of data
Responsible gaming monitoring and intervention	Usage data, financial data, identity data
Marketing and promotional communications (with consent)	Contact data, usage data
Regulatory reporting and legal compliance	Identity data, financial data, usage data

phenjoy will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

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4. Legal Basis for Processing

phenjoy processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform the contract between you and phenjoy — including account management, game provision, and payment processing;
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, KYC obligations, and PAGCOR reporting requirements;
• Legitimate interests: Processing necessary for phenjoy's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw your consent at any time by contacting phenjoy support or updating your account preferences.

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5. Sharing Your Personal Data

5.1 Service Providers

phenjoy shares personal data with carefully selected third-party service providers who assist us in operating the phenjoy platform. These include identity verification providers, payment processors, cloud hosting providers, customer support software providers, and analytics platforms. All service providers are contractually required to process personal data only on phenjoy's instructions and to maintain appropriate security measures.

5.2 Regulatory and Law Enforcement Authorities

phenjoy may disclose personal data to PAGCOR , the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other competent Philippine government authorities where required by law, court order, or regulatory directive. phenjoy will notify you of such disclosures where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of phenjoy's business, your personal data may be transferred to the acquiring entity as part of that transaction. phenjoy will notify you via email or a prominent notice on the platform before your personal data is transferred and becomes subject to a different privacy policy.

5.4 No Sale of Personal Data

phenjoy does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Any sharing of personal data is limited to what is strictly necessary for the purposes described in this Policy.

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6. Cookies and Tracking Technologies

6.1 What Are Cookies

Cookies are small text files placed on your device when you visit the phenjoy website. They allow phenjoy to recognise your device, remember your preferences, and collect information about how you use the platform. phenjoy also uses similar technologies such as web beacons, pixel tags, and local storage objects for comparable purposes.

6.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the phenjoy platform to function. These include session cookies that keep you logged in and security cookies that help detect fraudulent activity. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and game history to personalise your phenjoy experience.
• Analytics cookies: Help phenjoy understand how players use the platform — which pages are visited most, where players drop off, and how performance can be improved. Data collected is aggregated and anonymised where possible.
• Marketing cookies: Used to deliver relevant promotional content about phenjoy to you. These are only placed with your consent.

6.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Please note that disabling certain cookies may affect the functionality of the phenjoy platform and your ability to access some features.

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7. Data Retention

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

• Account and transaction data is retained for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations and gaming regulatory requirements;
• KYC and identity verification documents are retained for a minimum of five (5) years following the end of the business relationship;
• Customer support communications are retained for three (3) years from the date of the communication;
• Marketing consent records are retained for as long as necessary to demonstrate compliance with consent requirements;
• Technical and usage logs are retained for up to twelve (12) months, after which they are anonymised or deleted.

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

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8. Data Security

phenjoy implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the phenjoy platform;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments, vulnerability scanning, and penetration testing;
• Multi-factor authentication requirements for administrative access to phenjoy systems;
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phenjoy will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay where required.

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9. Your Data Privacy Rights

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

• Right to be informed: You have the right to be informed about how your personal data is collected and processed — which is the purpose of this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data phenjoy holds about you, along with information about how it is being used;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data phenjoy holds about you;
• Right to erasure: You have 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 phenjoy's legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe phenjoy has violated your data privacy rights.

To exercise any of these rights, please contact the phenjoy Data Privacy Officer using the contact details provided in Section 13 of this Policy. phenjoy will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

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10. Minors and Age Restriction

The phenjoy platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. phenjoy does not knowingly collect personal data from persons under the age of 21.

If phenjoy 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 believe that a minor has registered on the phenjoy platform, please contact our support team immediately.

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11. Third-Party Links and Services

The phenjoy platform may contain links to third-party websites or services for informational purposes. phenjoy is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to the phenjoy platform and the personal data phenjoy collects and processes.

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12. Changes to This Privacy Policy

phenjoy reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

Where changes are material, phenjoy will notify registered users via email or a prominent notice on the phenjoy platform at least fourteen (14) days before the changes take effect. Your continued use of the phenjoy platform following the effective date of any revised Policy constitutes your acceptance of the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how phenjoy is protecting your personal data.

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13. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way phenjoy handles your personal data, please contact our designated Data Privacy Officer (DPO):

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.