Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") describes how phinjoy Casino ("phinjoy," "we," "us," "our") collects, processes, stores, and protects the personal data of individuals ("you," "your," "the Player") who access or use the phinjoy platform, including our website and any associated applications (collectively, the "Platform").

1.2 phinjoy is committed to protecting the privacy and personal data of all players in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations. We take our obligations under this law seriously and have implemented appropriate technical and organizational measures to ensure compliance.

1.3 By registering an account on phinjoy 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.

1.4 This Policy should be read alongside phinjoy's Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your use of the phinjoy platform.

2. Data Controller

2.1 phinjoy Casino acts as the data controller in respect of the personal data collected through the Platform. As data controller, phinjoy determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

2.2 For all data privacy inquiries, requests, and complaints, you may contact phinjoy's designated Data Protection Officer (DPO) at: [email protected]

3. Personal Data We Collect

3.1 phinjoy collects the following categories of personal data in connection with the operation of the Platform:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government-issued ID number, nationality	Account registration, KYC verification, age verification
Contact Data	Email address, mobile number, residential address	Account communication, support, notifications
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history	Deposit and withdrawal processing, fraud prevention
Gaming Data	Game history, wager amounts, win/loss records, session duration, bonus usage	Platform operation, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, browser type, operating system, login timestamps	Security monitoring, fraud detection, platform optimization
Usage Data	Pages visited, features used, click patterns, session duration	Platform improvement, personalization, analytics
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer support, quality assurance, dispute resolution

3.2 phinjoy does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless strictly required for identity verification or legal compliance purposes, and only with your explicit consent where required by law.

4. How We Collect Your Data

4.1 Directly from You. The majority of personal data phinjoy holds about you is provided directly by you during the account registration process, KYC verification, deposit and withdrawal transactions, customer support interactions, and when you participate in promotions or surveys.

4.2 Automatically. When you access and use the phinjoy Platform, certain technical and usage data is collected automatically through cookies, web beacons, log files, and similar tracking technologies. This data helps us maintain platform security, analyze usage patterns, and improve the overall player experience.

4.3 From Third Parties. phinjoy may receive personal data about you from third-party identity verification providers, payment processors (such as GCash and PayMaya), fraud prevention services, and analytics providers. All third-party data sharing is governed by appropriate data processing agreements.

5. Purpose and Legal Basis for Processing

5.1 phinjoy processes your personal data only where a lawful basis exists under the Data Privacy Act of 2012. The primary legal bases we rely on are:

• Contractual Necessity: Processing required to fulfill our obligations under the phinjoy Terms & Conditions, including account management, game operation, and payment processing;
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and gaming regulatory requirements;
• Legitimate Interests: Processing necessary for phinjoy's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly in relation to marketing communications and non-essential cookies.

5.2 phinjoy will not use your personal data for purposes incompatible with those stated in this Policy without first obtaining your consent or establishing another lawful basis for processing.

6. Sharing Your Personal Data

6.1 phinjoy does not sell, rent, or trade your personal data to third parties for their own 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:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance;
• Fraud Prevention Services: Providers of fraud detection and anti-money laundering screening tools;
• IT and Platform Service Providers: Cloud hosting , database management, and cybersecurity providers who support the operation of the phinjoy Platform;
• Regulatory and Law Enforcement Authorities: Government agencies, regulators, and law enforcement bodies where disclosure is required by law or necessary to protect the rights, property, or safety of phinjoy, its players, or the public;
• Professional Advisors: Legal counsel, auditors, and other professional advisors where necessary for the conduct of phinjoy's business.

6.2 All third parties with whom phinjoy shares personal data are required to process such data in accordance with applicable data protection laws and are bound by appropriate contractual data processing agreements.

7. Data Retention

7.1 phinjoy 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.

7.2 As a general rule, phinjoy retains account and transaction records for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering regulations. Gaming history and responsible gaming records may be retained for longer periods where required by applicable gaming regulations.

7.3 Technical and usage data collected through cookies and analytics tools is typically retained for shorter periods, as specified in our cookie settings. Where data is no longer required, phinjoy will securely delete or anonymize it in accordance with our data retention schedule.

7.4 In certain circumstances, phinjoy may retain your data for longer periods where required by law, court order, or regulatory direction, or where retention is necessary for the establishment, exercise, or defense of legal claims.

8. Data Security

8.1 phinjoy implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phinjoy Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Continuous security monitoring, intrusion detection systems, and regular penetration testing;
• Secure data centers with physical access controls and environmental safeguards;
• Regular staff training on data protection and information security best practices.

8.2 While phinjoy 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, phinjoy will notify you and the National Privacy Commission (NPC) of the Philippines in accordance with applicable breach notification requirements.

8.3 You are responsible for maintaining the confidentiality of your phinjoy account credentials. Please notify our support team immediately if you suspect any unauthorized access to your account.

9. Cookies and Tracking Technologies

9.1 phinjoy uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, analyze usage patterns, and deliver relevant content. Cookies are small text files stored on your device when you visit the phinjoy website.

9.2 phinjoy uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, security, and fraud prevention. These cannot be disabled.
• Performance & Analytics Cookies: Help us understand how players interact with the Platform, which pages are most visited, and where improvements can be made. Data collected is aggregated and anonymized.
• Functional Cookies: Remember your preferences such as language settings, game preferences, and display options to provide a more personalized experience.
• Marketing Cookies: Used to deliver relevant promotions and offers. These are only set with your consent.

9.3 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phinjoy Platform. For more information on managing cookies, refer to your browser's help documentation.

10. Your Data Privacy Rights

10.1 Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by phinjoy:

11. Minors and Age Restriction

11.1 The phinjoy Platform is strictly intended for individuals who are 21 years of age or older. phinjoy does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the account registration and KYC process.

11.2 If phinjoy becomes aware that personal data has been collected from an individual under the age of 21, the relevant account will be immediately closed, all funds will be returned to the payment method used (net of any winnings), and the personal data will be securely deleted from our systems.

11.3 If you believe that a minor has registered an account on phinjoy, please contact our support team immediately at [email protected] so that we can take prompt action.

12. International Data Transfers

12.1 phinjoy primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines, phinjoy will ensure that appropriate safeguards are in place to protect your data, including contractual clauses that impose data protection obligations equivalent to those applicable in the Philippines.

12.2 By using the phinjoy Platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where phinjoy's service providers operate, subject to the safeguards described in this section.

13. Changes to This Privacy Policy

13.1 phinjoy reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or the features of the Platform. The date of the most recent revision is displayed at the top of this page.

13.2 Where material changes are made to this Policy, phinjoy will notify registered players via the email address associated with their account and/or by posting a prominent notice on the Platform. Your continued use of the phinjoy Platform following notification of changes constitutes your acceptance of the revised Policy.

13.3 We encourage you to review this Privacy Policy periodically to stay informed about how phinjoy protects your personal data.

14. Contact and Complaints

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

Email: [email protected]

14.2 phinjoy will respond to all data privacy requests within a reasonable timeframe and in accordance with the requirements of the Data Privacy Act of 2012. We are committed to resolving all privacy concerns fairly and transparently.

14.3 If you are not satisfied with phinjoy's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.