phearn Privacy Policy

1. Introduction and Scope

phearn ("phearn," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the phearn online casino platform, including the website at phearn.app and any associated mobile applications (collectively, the "Platform").

This Privacy Policy ("Policy") describes how phearn collects, uses, stores, shares, and protects personal data relating to registered players, prospective players, and visitors to the Platform ("you" or "Data Subject"). It also explains the rights available to you under applicable Philippine data protection law and how to exercise those rights.

This Policy applies to all personal data processed by phearn in connection with the Platform, regardless of the device or channel through which you access it. It should be read together with phearn's Terms & Conditions and any game-specific or promotion-specific terms published on the Platform.

By registering a phearn account or continuing to use the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with how phearn processes your personal data as described herein, you should discontinue use of the Platform and, if applicable, request closure of your account.

2. Data Controller Information

phearn is the data controller responsible for the personal data collected through the Platform. As data controller, phearn determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

phearn has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the phearn DPO using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

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

3.1 Identity and Registration Data

• Full legal name as it appears on a government-issued identification document;
• Date of birth and age verification information;
• Gender (where voluntarily provided);
• Government-issued ID type and number (e.g., Philippine passport, SSS, UMID, driver's licence, PhilSys national ID);
• Nationality and country of residence.

3.2 Contact Data

• Email address;
• Philippine mobile number;
• Residential address (city, province, postal code).

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records;
• Payment method details (e.g., GCash account reference, Maya account reference, bank account details for BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, or debit card details);
• Account balance history and wagering activity;
• Bonus and promotion redemption records.

3.4 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session logs, login timestamps, and session duration;
• Pages visited, games played, and features accessed on the Platform;
• Clickstream data and interaction logs.

3.5 Communications Data

• Records of correspondence with phearn support via live chat, email, or any other channel;
• Feedback, complaints, and dispute records;
• Marketing communication preferences and opt-in/opt-out records.

3.6 Responsible Gaming Data

• Self-exclusion requests and status;
• Deposit, loss, and session limit settings;
• Responsible gaming assessment responses where voluntarily provided.

4. How We Collect Your Data

phearn collects personal data through the following means:

• Directly from you — when you register a phearn account, complete identity verification, make a deposit or withdrawal, contact support, participate in promotions, or update your account settings;
• Automatically — through cookies, web beacons, server logs, and similar tracking technologies when you access and interact with the Platform (see Section 7 for details);
• From third parties — including identity verification service providers, payment processors, fraud prevention agencies, and, where applicable, publicly available sources used for KYC and anti-money laundering (AML) compliance purposes.

5. Purposes and Legal Bases for Processing

phearn processes your personal data for the following purposes, each supported by a lawful basis under the Philippine Data Privacy Act of 2012:

Where phearn relies on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing and Disclosure of Personal Data

phearn does not sell, rent, or trade your personal data to third parties for their own commercial purposes. phearn 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:

• Identity verification and KYC providers — to verify your identity and age in compliance with regulatory requirements;
• Payment processors and financial institutions — to process deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• Fraud prevention and AML screening services — to detect and prevent fraudulent activity and money laundering;
• IT infrastructure and cloud service providers — who host and maintain the Platform's technical infrastructure under strict data processing agreements;
• Regulatory and law enforcement authorities — including PAGCOR and the National Privacy Commission (NPC), where disclosure is required by law, court order, or regulatory direction;
• Professional advisers — including lawyers, auditors, and accountants, where necessary for phearn's legal and compliance obligations.

All third-party service providers engaged by phearn are required to process personal data only in accordance with phearn's instructions and applicable data protection law. phearn does not permit third-party service providers to use your personal data for their own independent purposes.

7. Cookies and Tracking Technologies

phearn uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit the Platform. phearn uses the following categories of cookies:

• Strictly necessary cookies — essential for the Platform to function, including session management, login authentication, and security features. These cannot be disabled;
• Functional cookies — remember your preferences such as language settings and game display options to personalise your experience;
• Analytics cookies — collect aggregated, anonymised data about how players use the Platform, helping phearn identify areas for improvement;
• Marketing cookies — used to deliver relevant promotional content to you on the Platform, based on your activity and preferences, where you have provided consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

8. Data Retention

phearn retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. 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 compliance with 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 financial regulations;
• Support and communications data — retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings;
• Marketing preference data — retained until you withdraw consent or request deletion, whichever is earlier;
• Technical and usage data — retained for up to twelve (12) months in identifiable form, after which it may be anonymised and retained for analytical purposes.

When personal data is no longer required, phearn will securely delete or anonymise it in accordance with its data disposal procedures.

9. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and phearn's servers;
• Encryption of sensitive data at rest, including financial and identity information;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Two-factor authentication (2FA) options for player accounts;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phearn will notify the National Privacy Commission (NPC) and, where required, affected individuals, within the timeframes prescribed by the Philippine Data Privacy Act of 2012.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phearn. To exercise any of these rights, please contact phearn's Data Protection Officer using the details in Section 14.