PH Charm Privacy Policy

1 Introduction

PH Charm is committed to protecting the privacy and personal data of every player who uses our platform. We understand that Filipino players trust us with sensitive information — from identity documents to financial transaction records — and we take that responsibility seriously.

This Policy is designed to be transparent and easy to understand. It tells you exactly what personal data PH Charm collects, the purposes for which it is processed, who it may be shared with, how long it is retained, and the rights available to you under Philippine law. If you have any questions after reading this Policy, please contact our Data Protection Officer using the details provided in Section 15.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, PH Charm is the Personal Information Controller in respect of the personal data collected through the platform.

PH Charm has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and with applicable Philippine data privacy law. You may contact the DPO at any time using the contact details set out in Section 15 of this Policy.

3 Personal Data We Collect

PH Charm collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include the following:

4 How We Collect Your Data

PH Charm collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the platform, including through cookies, web beacons, log files, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment transaction data from GCash, PayMaya, BPI, BDO, and Metrobank.
• Publicly available sources: In limited circumstances, PH Charm may verify information against publicly available Philippine government databases for compliance purposes.

5 How We Use Your Personal Data

PH Charm uses the personal data it collects for the following purposes:

• Account management: Creating and maintaining your PH Charm player account, verifying your identity, and managing your account settings and preferences.
• Service delivery: Providing access to games, processing deposits and withdrawals, crediting bonuses, and delivering customer support.
• Age and eligibility verification: Confirming that you meet the 21+ age requirement and are eligible to use the platform under Philippine law.
• Legal and regulatory compliance: Meeting our obligations under the Anti-Money Laundering Act (RA 9160), PAGCOR-regulated gaming guidelines, the Data Privacy Act (RA 10173), and other applicable Philippine laws.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: Monitoring wagering patterns to identify potential problem gambling behavior and to administer self-exclusion and limit-setting tools.
• Communications: Sending transactional notifications (deposit confirmations, withdrawal updates), security alerts, and — where you have opted in — promotional communications about PH Charm offers.
• Platform improvement: Analyzing usage data to improve the performance, features, and user experience of the PH Charm platform.
• Dispute resolution: Maintaining records necessary to investigate and resolve disputes between players and PH Charm.

6 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML reporting obligations, PAGCOR regulatory requirements, and tax reporting.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

PH Charm does not sell, rent, or trade your personal data to third parties. 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:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements.
• AML compliance partners: Screening services used to fulfill our obligations under the Anti-Money Laundering Act and PAGCOR guidelines.
• IT and platform service providers: Cloud hosting, data storage, and cybersecurity providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or court order.
• Professional advisers: Legal counsel, auditors, and accountants, where necessary for the conduct of PH Charm's business operations.

8 Cookies & Tracking Technologies

PH Charm uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the platform. The types of cookies we use are as follows:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Performance and analytics cookies: Used to collect anonymized data about how players use the platform — such as which games are most popular and where errors occur — to help us improve the service.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Marketing cookies: Used only where you have given explicit consent, to deliver relevant promotional content about PH Charm within the platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the PH Charm platform. For strictly necessary cookies, no opt-out is available as they are required for the platform to operate.

9 Data Retention

PH Charm retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC-approved data disposal procedures.

10 Data Security

PH Charm implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS 1.3 encryption for all data in transit between your device and PH Charm servers.
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records.
• Multi-factor authentication (MFA) for all administrative access to systems containing personal data.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity firms.
• Role-based access controls ensuring that only authorized personnel can access personal data, on a strict need-to-know basis.
• Comprehensive data breach response procedures, including NPC notification within 72 hours of discovering a breach that poses a real risk of serious harm.
• Regular staff training on data privacy obligations and security best practices.

11 Your Data Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by PH Charm:

• Right to be informed: The right to be notified of how your personal data is being collected and processed — which this Policy fulfills.
• Right of access: The right to request a copy of the personal data PH Charm holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held about you.
• Right to erasure: 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 our 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, commonly used, machine-readable format and to transmit it to another controller.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

12 Children's Privacy

The PH Charm platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law governing casino-style online gaming. PH Charm does not knowingly collect personal data from individuals under the age of 21.

If PH Charm becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and — where required — report the matter to the relevant Philippine authorities. If you believe that a minor has registered on PH Charm, please notify us immediately via the contact details in Section 15.

13 Cross-Border Data Transfers

In certain circumstances, PH Charm may transfer personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or international KYC verification services. Any such cross-border transfer of personal data is conducted in accordance with Section 21 of the Data Privacy Act of 2012 and applicable NPC regulations.

Before transferring personal data outside the Philippines, PH Charm ensures that the recipient country or organization provides an adequate level of data protection, or that appropriate safeguards are in place — such as contractual clauses approved by the NPC or binding corporate rules. PH Charm will not transfer your personal data to jurisdictions that do not provide adequate protection without your explicit consent, except where required by Philippine law.

14 Changes to This Privacy Policy

PH Charm 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 NPC guidance. The date of the most recent revision is always displayed at the top of this page.

When material changes are made to this Policy, PH Charm will notify registered players via email or through a prominent notice on the platform at least seven (7) days before the changes take effect. Your continued use of the PH Charm platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how PH Charm protects your personal data. If you disagree with any changes to this Policy, you may close your account in accordance with the Terms & Conditions.

15 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by PH Charm, please contact our Data Protection Officer:

Data Protection Officer — PH Charm
Email (plain text — not a link): [email protected]

If you are not satisfied with PH Charm's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to file a complaint with the NPC is available through official Philippine government channels.