Privacy Policy

1. Introduction

plushph takes your privacy seriously. As a Philippine-based online gaming platform serving Filipino players across Metro Manila, Cebu, Davao, and nationwide, we are bound by the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, administered by the National Privacy Commission (NPC). This Policy sets out our data practices in plain, understandable language, and explains the rights you hold as a data subject under Philippine law.

This Policy should be read alongside our Terms and Conditions and our Responsible Gaming Policy, all of which form part of your agreement with plushph.

2. Data Controller

For purposes of the Data Privacy Act, plushph is the personal information controller responsible for the personal data collected through the Platform. All data governance, access controls, and compliance obligations rest with plushph.

Our designated Data Protection Officer (DPO) can be contacted via the support channels listed at the end of this Policy. The DPO is responsible for overseeing plushph's data protection compliance and for handling data subject requests.

3. Personal Data We Collect

plushph collects the following categories of personal data, depending on the nature of your interaction with the Platform:

3.1 Registration Data

• Full legal name
• Date of birth (to verify minimum age of 21 years)
• Philippine mobile number
• Username and encrypted password
• Residential address (collected at KYC stage)

3.2 Identity Verification (KYC) Data

• Government-issued ID (Philippine passport, driver's licence, SSS/UMID/GSIS ID, or Voter's ID)
• Selfie or live photo for liveness verification
• Proof of address (where required)

3.3 Financial Data

• GCash or Maya mobile number linked to your account
• Bank account details (BPI, BDO, UnionBank, Metrobank) for bank transfer withdrawals
• Transaction history: deposits, withdrawals, and game wagers

3.4 Usage & Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser
• Session logs, login timestamps, and page interaction data
• Game play history and betting patterns

3.5 Communication Data

• Records of live chat, email, and SMS support interactions
• Responses to surveys or promotional campaigns (if you participate)

4. How We Use Your Personal Data

plushph uses the personal data it collects for the following purposes:

• Account creation and management: To register your account, verify your identity, and maintain your Member profile on the plushph Platform.
• Age and identity verification: To comply with the PAGCOR requirement that all casino players be at least 21 years of age and to fulfil KYC obligations under Philippine anti-money laundering law.
• Transaction processing: To process deposits and withdrawals through GCash, Maya, and Philippine bank channels in Philippine Pesos.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, money laundering, and other prohibited activity.
• Legal and regulatory compliance: To meet obligations under the Data Privacy Act, PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Customer support: To respond to your queries, resolve disputes, and provide assistance via plushph's 24/7 support channels.
• Responsible gaming: To monitor gaming behaviour and apply responsible gaming tools such as deposit limits, session alerts, and self-exclusion where appropriate.
• Marketing communications: To send you promotional offers, bonuses, and updates about plushph — but only where you have given consent, and always with an easy opt-out option.
• Platform improvement: To analyse usage patterns and improve the plushph user experience, game lobby, mobile performance, and payment flows.

5. Legal Basis for Processing

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

• Contractual necessity: Processing necessary to perform our obligations under the Terms and Conditions you agreed to upon registration (e.g., account management, payment processing).
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, AMLA requirements, and NPC data protection obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your privacy rights.
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

6. Sharing Your Personal Data

plushph does not sell your personal data. We may share your data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment processors: GCash (G-Xchange Inc.), Maya (Voyager Innovations), and Philippine banks for transaction processing and fraud monitoring.
• KYC and identity verification providers: Third-party KYC platforms engaged to verify the identity and age of Members, subject to data processing agreements.
• Game providers: Licensed game studios (e.g., Pragmatic Play, Jili, PG Soft) receive session data necessary to deliver their games. Game providers do not receive your financial or identification data beyond what is technically required for game delivery.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies, where required by law or valid legal process.
• IT and security service providers: Cloud hosting, cybersecurity, and data analytics providers operating under strict data processing agreements with plushph.

All third parties with whom plushph shares personal data are contractually required to handle that data in accordance with the Philippine Data Privacy Act and to use it only for the specific, authorised purposes for which it was shared.

7. Cookies & Tracking Technologies

The plushph Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and collect analytics data. The types of cookies we use include:

• Essential cookies: Required for basic Platform functionality, including login session management and security. These cannot be disabled without disrupting your use of plushph.
• Analytics cookies: Used to understand how Members interact with the plushph Platform, which pages are most visited, and where improvements are needed. Data collected is aggregated and anonymised.
• Preference cookies: Store your language, display, and notification preferences so you don't need to reset them on every visit.
• Marketing cookies: Used only with your consent to deliver personalised promotional content. You may opt out at any time via your account settings or browser controls.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use core plushph features.

8. Data Security

plushph implements technical and organisational security measures proportionate to the sensitivity of the personal data we hold. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and plushph servers;
• AES-256 encryption at rest for sensitive stored data, including financial records and KYC documents;
• Role-based access controls ensuring that only authorised plushph personnel access personal data, and only to the extent necessary for their role;
• Regular penetration testing and vulnerability assessments of the Platform;
• Multi-factor authentication required for all plushph staff accessing systems that hold Member data;
• 24/7 security monitoring and automated anomaly detection.

Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, plushph will notify affected Members and the NPC within the timeframes required by the Data Privacy Act.

9. Data Retention Periods

plushph retains personal data for as long as your account is active and for a period thereafter as required by law or as necessary for legitimate business purposes. Specific retention periods include:

• Account and KYC data: Retained for the life of your account and for a minimum of five (5) years after account closure, as required by AMLA and PAGCOR record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years in compliance with AMLA requirements.
• Support interaction records: Retained for three (3) years from the date of the interaction.
• Marketing consent records: Retained until you withdraw consent or for three (3) years from the last interaction, whichever is earlier.
• Analytics data: Aggregated and anonymised data may be retained indefinitely as it cannot be traced back to individual Members.

When personal data is no longer required, it is securely deleted or anonymised in accordance with plushph's data retention and disposal procedures.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by plushph:

• Right to be informed: The right to know how your personal data is being collected, processed, and used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data plushph holds about you.
• Right to rectification: The right to correct inaccurate, outdated, or incomplete personal data.
• Right to erasure or blocking: The right to request that your personal data be erased or its processing blocked, subject to legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, machine-readable format and to transmit it to another platform.
• Right to damages: The right to seek compensation for damages suffered as a result of inaccurate, incomplete, outdated, or unlawfully obtained personal data.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe plushph has violated your data privacy rights.

To exercise any of these rights, contact plushph's Data Protection Officer via the support channels listed in Section 14. We will respond to all verifiable data subject requests within fifteen (15) business days of receipt, consistent with NPC guidelines.

11. Children and Minors

The plushph Platform is strictly for adults aged 21 years and above in accordance with Philippine gaming regulations. plushph does not knowingly collect personal data from individuals under 21 years of age. If plushph discovers that it has inadvertently collected data from a minor, that account will be immediately closed and all associated data deleted without delay. Parents or guardians who believe a minor has registered on the Platform should contact plushph immediately via live chat or email.

12. International Data Transfers

plushph's primary servers are located in the Philippines. However, some of our service providers — including game studios, cloud infrastructure providers, and analytics platforms — may process data in other jurisdictions. In all cases where personal data is transferred outside the Philippines, plushph ensures that appropriate safeguards are in place, including contractual clauses that require the recipient to protect your data to a standard equivalent to that required by Philippine law.

13. Updates to This Privacy Policy

plushph may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. Material changes will be communicated to Members via SMS notification to your registered mobile number or via a prominent notice on the plushph Platform. We recommend reviewing this Policy periodically. The current version is always available at plushph.one/privacy-policy, and the effective date at the top of this document indicates when it was last revised. Your continued use of the Platform following any update constitutes acceptance of the revised Policy.

14. Contact & NPC Complaints

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how plushph handles your personal data, please contact us:

• Data Protection Officer: Reachable via plushph's 24/7 live chat or by email
• Email: [email protected]
• Support Hours (live agents): 8AM – 10PM PHT

If your concern is not resolved to your satisfaction, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC can be reached through official government channels at privacy.gov.ph.