phtaya11 Privacy Policy

Introduction & Scope

This Privacy Policy ("Policy") describes how phtaya11 ("we," "us," "our") collects, processes, stores, and protects the personal information of individuals ("you," "your," "Player," "User") who access or use the phtaya11 platform at phtaya11.club, including all associated services, features, games, and communications channels.

This Policy applies to all personal data processed by phtaya11 in connection with the provision of its online gaming services, whether you are a registered player, a visitor browsing the website, or a person who has previously held an account with us.

By accessing the phtaya11 platform or registering an account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, phtaya11 is the Personal Information Controller (PIC) in respect of all personal data collected and processed through the platform.

As the data controller, phtaya11 determines the purposes for which personal data is collected and the means by which it is processed. Where we engage third-party service providers to process personal data on our behalf, those parties act as Personal Information Processors (PIPs) and are contractually bound to process data only in accordance with our instructions and applicable law.

If you have any questions about how phtaya11 handles your personal data, or if you wish to exercise any of your rights under this Policy, please refer to Section 15 (Contact & DPO) for our Data Protection Officer's contact details.

Data We Collect

phtaya11 collects the following categories of personal data in the course of providing its services:

This information is collected at the point of registration and during KYC (Know Your Customer) verification. A valid Philippine government-issued ID — such as a driver's licence, passport, SSS card, UMID, or PhilSys National ID — is required to complete KYC.

Financial data is collected to process transactions, comply with Anti-Money Laundering (AML) obligations, and verify the source of funds where required. Full payment card numbers are never stored on phtaya11 systems.

Records of your communications with phtaya11, including live chat transcripts, support ticket histories, and any voluntary feedback or survey responses you provide.

How We Collect Your Data

phtaya11 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions;
• Automated collection: Technical data such as IP addresses, device identifiers, browser information, and session logs collected automatically when you access the platform via cookies and server-side logging;
• Third-party sources: Identity verification and fraud prevention services, payment processors (such as GCash and Maya), and regulatory databases, where permitted by law;
• Public records: Publicly available information used for identity verification or anti-fraud purposes, including regulatory exclusion lists and AML screening databases.

Legal Basis for Processing

phtaya11 processes your personal data on the following legal grounds under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and phtaya11, including account management, transaction processing, and service delivery;
• Legal obligation: Processing required to comply with applicable law, including PAGCOR regulations, Anti-Money Laundering Act obligations (RA 9160 as amended), and tax requirements;
• Legitimate interests: Processing necessary for phtaya11's legitimate business interests, including fraud prevention, platform security, and responsible gaming compliance, where these interests are not overridden by your fundamental rights;
• Consent: Where processing is based on your consent — for example, in connection with certain marketing communications — you have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

How We Use Your Personal Data

phtaya11 uses the personal data we collect for the following purposes:

• To create, manage, and maintain your phtaya11 account and provide access to our gaming services;
• To process financial transactions including deposits, withdrawals, and bonus payments;
• To verify your identity and age in compliance with PAGCOR requirements and KYC obligations;
• To comply with Anti-Money Laundering (AML) screening and transaction monitoring obligations;
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited activities;
• To enforce our Terms & Conditions and manage account suspensions or closures;
• To provide customer support and respond to your inquiries through live chat and email;
• To administer bonuses, promotions, and loyalty program benefits;
• To operate responsible gaming tools including deposit limits, loss limits, and self-exclusion, and to monitor for indicators of problem gambling;
• To send service-critical communications including transaction confirmations, security alerts, and changes to our terms or policies;
• To analyse platform usage for the purpose of improving our services, fixing technical issues, and enhancing game performance;
• To comply with applicable Philippine law, regulatory directives from PAGCOR, and court orders.

Data Sharing & Disclosure

phtaya11 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We may, however, share your data with the following categories of recipient where necessary and lawful:

• Payment processors and e-wallet providers: GCash, Maya, BPI, BDO, Metrobank, and other payment partners receive the minimum data required to process your transactions;
• Identity verification and KYC providers: Third-party services that verify the authenticity of your government ID and confirm your identity;
• Anti-fraud and AML service providers: Platforms that screen transactions and player data against financial crime databases in compliance with our legal obligations;
• Game software providers: Providers whose games are hosted on the phtaya11 platform may process technical session data in order to operate their games correctly;
• IT and hosting infrastructure providers: Cloud and server providers that host the phtaya11 platform and process data on our behalf under data processing agreements;
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), and other competent Philippine authorities where we are legally required to disclose information;
• Law enforcement: Philippine law enforcement agencies where we receive a lawful request or are required to report suspected criminal activity under applicable law.

All third-party processors engaged by phtaya11 are contractually required to process personal data only on our documented instructions, to maintain appropriate security standards, and to comply with applicable data protection law.

Cookies & Tracking Technologies

The phtaya11 platform uses cookies and similar tracking technologies to provide a functioning, secure, and personalised user experience. A "cookie" is a small text file stored on your device by your browser when you visit our website.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the platform to function correctly, including maintaining your login session, remembering security settings, and processing transactions. These cannot be disabled;
• Functional cookies: Remember your preferences such as language settings and game lobby filters. Disabling these may affect your experience;
• Analytics cookies: Collect anonymised data about how visitors use the platform — such as pages visited and session duration — to help us improve performance and usability;
• Security cookies: Used to detect and prevent fraudulent login attempts and suspicious account activity.

You may control cookie settings through your browser's privacy settings. Blocking strictly necessary cookies will prevent you from accessing the platform. phtaya11 does not use cookies to serve third-party advertising.

Data Retention

phtaya11 retains personal data for the period necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

Data Security

phtaya11 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security measures include:

• TLS/SSL encryption on all data transmitted between your device and our servers — every page of the platform, including the login form, is served over HTTPS;
• Encryption at rest for sensitive data fields including passwords (stored as salted cryptographic hashes) and KYC document files;
• Two-factor authentication (2FA) available to all registered players and mandatory for staff with access to player data systems;
• Access controls limiting internal access to personal data on a strict need-to-know basis with role-based permissions;
• Intrusion detection and monitoring systems that log and alert on suspicious access patterns in real time;
• Regular security audits of platform infrastructure, third-party integrations, and data processing practices;
• Data breach response procedures including notification to the National Privacy Commission (NPC) and affected individuals where required by RA 10173.

International Data Transfers

The phtaya11 platform is primarily operated to serve players in the Philippines. Some of our third-party service providers — including certain game software providers and cloud infrastructure partners — may be located outside the Philippines and may process personal data in their respective countries.

Where personal data is transferred outside the Philippines, phtaya11 ensures that such transfers occur only where:

• The destination country has been assessed as providing an adequate level of data protection;
• Appropriate contractual safeguards are in place, such as data processing agreements that bind the recipient to equivalent data protection standards;
• The transfer is necessary to perform your contract with us, such as processing a payment through an international payment network.

You may request further information about the safeguards applicable to international transfers of your personal data by contacting our Data Protection Officer at the address in Section 15.

Your Privacy Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by phtaya11:

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 15. We will respond to verified requests within the timeframes required by RA 10173. We may need to verify your identity before processing your request.

Children's Privacy & Minors

The phtaya11 platform is strictly intended for individuals who are 21 years of age or older in accordance with PAGCOR regulations governing online gambling in the Philippines. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a person below the minimum age — whether identified through our KYC process, a report from a third party, or our own investigation — we will immediately suspend the relevant account, delete the associated data to the extent permissible by law, and take any further action required by PAGCOR or other applicable regulatory authority.

Parents or guardians who believe a minor has registered with phtaya11 should contact our support team immediately. Verified reports will be acted upon without delay.

Changes to This Privacy Policy

phtaya11 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page;
• Notify registered players via the email address or mobile number on file at least seven (7) days before the updated policy takes effect, unless a shorter notice period is required by law;
• Display a prominent notice on the platform during the transition period.

Your continued use of the phtaya11 platform after the effective date of any updated Privacy Policy constitutes acceptance of the revised terms. We recommend that you review this Policy periodically.

Contact & Data Protection Officer

phtaya11 has appointed a Data Protection Officer (DPO) in compliance with the requirements of the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our DPO through the following channels:

• Email: [email protected] (with subject line: "Data Privacy Request")
• Live Chat: Available 24/7 from within your phtaya11 account dashboard — please advise the agent that your inquiry relates to a data privacy matter
• Response Time: We aim to acknowledge all data privacy requests within 72 hours and provide a substantive response within 30 calendar days of receiving a verified request

If you are not satisfied with our response or believe that your data rights have been violated, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to file a complaint is available on the NPC's official website.

For responsible gaming concerns — including self-exclusion requests, deposit limits, or problem gambling support — please visit our Responsible Gaming page, which contains additional resources and contact options specific to those matters.