Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how phdream11 ("phdream11," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the phdream11 online casino and sports betting platform available at phdream11.one (the "Platform").

phdream11 is committed to protecting the privacy of all players, particularly those based in the Philippines. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an account on phdream11 or by continuing to use 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. If you do not agree with any part of this Policy, you should discontinue use of the Platform and may request account closure in accordance with our Terms & Conditions.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and applicable data protection legislation, phdream11 acts as the data controller in respect of the personal data collected from players using the Platform. As data controller, phdream11 determines the purposes and means of processing your personal data.

phdream11 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection laws. Players may contact the DPO with any privacy-related inquiries using the contact details provided in Section 16 of this Policy.

Personal Data We Collect

phdream11 collects the following categories of personal data from players. The specific data collected may vary depending on the nature of your interaction with the Platform:

3.1 Identity and Contact Data

• Full legal name as it appears on a valid Philippine government-issued identification document
• Date of birth
• Gender (where provided)
• Residential address in the Philippines (e.g., Metro Manila, Cebu, Davao, Quezon City, Makati, or other regions)
• Valid Philippine mobile number
• Email address

3.2 Identification and Verification Data

• Copies of government-issued identification documents submitted for KYC verification (e.g., Philippine passport, driver's license, SSS card, PhilSys national ID, UMID)
• Proof of address documents where required
• Source of funds documentation where required for AML compliance

3.3 Financial and Transaction Data

• Payment method details (e.g., GCash account reference, PayMaya account reference, BPI, BDO, or Metrobank account details)
• Deposit and withdrawal transaction history
• Account balance history
• Bonus and promotional credit records

3.4 Gaming Activity Data

• Game session records including games played, wagers placed, and outcomes
• Sports betting selections and results
• Responsible gaming tool settings and usage (deposit limits, self-exclusion requests, cooling-off periods)
• Bonus claims and wagering requirement progress

3.5 Technical and Usage Data

• IP address and approximate geolocation data
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the Platform
• Login timestamps and session duration
• Cookies and similar tracking technology data (see Section 8)

3.6 Communications Data

• Records of communications between you and phdream11 customer support, including live chat transcripts and email correspondence
• Feedback, complaints, and dispute records
• Marketing communication preferences

How We Collect Your Data

phdream11 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or updating your account profile.
• Automated collection: Technical and usage data collected automatically when you access and interact with the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Data received from payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention services, and regulatory authorities where permitted by applicable law.
• Publicly available sources: In limited circumstances, phdream11 may verify information against publicly available records for fraud prevention and AML compliance purposes.

How We Use Your Personal Data

phdream11 uses the personal data we collect for the following purposes:

phdream11 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.

Legal Basis for Processing

phdream11 processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations, gaming regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing carried out for phdream11's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly in relation to marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing and Disclosure

phdream11 does not sell, rent, or trade your personal data to third parties for their own commercial or marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

7.1 Service Providers

phdream11 engages trusted third-party service providers to assist in operating the Platform. These include payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, game software providers, cloud hosting providers, and customer support technology providers. All service providers are contractually bound to process your data only on phdream11's instructions and in accordance with applicable data protection law.

7.2 Regulatory and Law Enforcement Authorities

phdream11 may disclose personal data to Philippine gaming regulatory authorities, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and other government bodies where required or permitted by applicable Philippine law. Such disclosures are made only to the extent necessary to fulfill our legal obligations.

7.3 Fraud Prevention and Security

phdream11 may share data with fraud prevention agencies and security service providers to protect the Platform and its players from fraudulent activity, money laundering, and other illegal conduct. Information shared for these purposes may be retained by such agencies and used to prevent fraud and money laundering in connection with other organizations.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of phdream11's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and the privacy practices of the successor entity prior to your data being transferred and becoming subject to a different privacy policy.

Cookies and Tracking Technologies

phdream11 uses cookies and similar tracking technologies (including web beacons and local storage) to operate and improve the Platform. The following categories of cookies are used:

• Essential cookies: Strictly necessary for the Platform to function. These include session cookies that maintain your login state and security cookies that protect against cross-site request forgery. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the Platform, including pages visited and features used. This data helps phdream11 identify areas for improvement.
• Marketing cookies: Used to deliver relevant promotional content to players who have consented to receive marketing communications from phdream11. These cookies track your interaction with phdream11 promotional materials.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the phdream11 Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

Data Retention

phdream11 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations and applicable tax laws.
• Gaming activity data: Retained for the duration of your account and for a minimum of three (3) years following account closure.
• Customer support communications: Retained for a minimum of two (2) years from the date of the communication, or longer if the communication relates to an ongoing dispute or legal matter.
• Technical and usage data: Generally retained for up to twelve (12) months, after which it is aggregated or anonymized.

Where personal data is no longer required for any lawful purpose, phdream11 will securely delete or anonymize it in accordance with our internal data disposal procedures.

Data Security

phdream11 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phdream11 Platform
• Encryption of sensitive data at rest, including identification documents and payment details
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security assessments and penetration testing of the Platform infrastructure
• Two-factor authentication (2FA) available for all player accounts
• Continuous monitoring for suspicious activity and potential security incidents
• Staff training on data protection obligations and security best practices

While phdream11 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, phdream11 will notify you and the National Privacy Commission (NPC) in accordance with the requirements of the Philippine Data Privacy Act.

Your Data Protection Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phdream11:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of access: You have the right to request a copy of the personal data phdream11 holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain account information directly through your phdream11 account settings.
• 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 phdream11's legal and regulatory 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. You may also object to processing based on legitimate interests, subject to phdream11's overriding legitimate grounds.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that phdream11 has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact phdream11 using the details provided in Section 16. phdream11 will respond to all verified data subject requests within thirty (30) days of receipt, or within such other timeframe as required by applicable law. We may need to verify your identity before processing your request.

Children's Privacy

The phdream11 Platform is strictly intended for individuals who are 21 years of age or older. phdream11 does not knowingly collect personal data from individuals under the age of 21. The minimum legal age for casino-style gambling in the Philippines is 21 years, and phdream11 enforces this requirement rigorously through its registration and KYC verification processes.

If phdream11 becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage individual will be returned in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered an account on phdream11, please contact us immediately using the details in Section 16 so that we can take appropriate action.

International Data Transfers

phdream11 primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including cloud hosting providers, game software providers, and fraud prevention services — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, phdream11 ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of the Philippine Data Privacy Act. Such safeguards may include contractual data protection clauses, adequacy decisions, or other legally recognized transfer mechanisms.

By using the phdream11 Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

Third-Party Links and Services

The phdream11 Platform may contain references to third-party game providers and payment services that operate under their own privacy policies. phdream11 is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the phdream11 Platform.

phdream11 does not endorse or make any representations about third-party privacy practices. Your interactions with third-party services are governed solely by the terms and privacy policies of those third parties.

Updates to This Privacy Policy

phdream11 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, phdream11 will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending a notification to the email address associated with your account.

The updated Policy will be effective from the date indicated in the "Last Updated" notice at the top of this page. Your continued use of the phdream11 Platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not agree with the updated Policy, you should discontinue use of the Platform and may request account closure in accordance with our Terms & Conditions.

We recommend reviewing this Privacy Policy periodically to stay informed of how phdream11 handles your personal data. The most current version will always be accessible at phdream11.one/privacy-policy.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way phdream11 handles your personal data, please contact our Data Protection Officer or Player Support team through the following channels:

phdream11 will acknowledge all privacy-related inquiries within 72 hours and will endeavor to resolve data subject requests within thirty (30) days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.

For general player support inquiries unrelated to data privacy, please contact: [email protected]