Privacy Policy

1 Introduction

phmoba is committed to protecting the privacy and personal data of all users of our platform. We understand that trust is the foundation of any relationship between a player and a gaming platform, and we take our data protection obligations seriously.

This Privacy Policy has been prepared in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). It applies to all personal data collected by phmoba in connection with the operation of the phmoba platform, whether collected online, through our mobile application, or through any other channel.

This Privacy Policy should be read together with our Terms & Conditions, which are available at phmoba.xyz/terms-conditions. Capitalised terms used but not defined in this Privacy Policy have the meanings given to them in the Terms & Conditions.

If you have any questions about this Privacy Policy or how phmoba handles your personal data, please contact our Data Protection Officer using the details provided in Section 14 of this Policy.

2 Personal Data We Collect

phmoba collects the following categories of personal data from users of the platform:

phmoba does not intentionally collect sensitive personal information beyond what is necessary for identity verification and regulatory compliance. Where sensitive personal information is collected — such as government ID numbers — it is handled with the highest level of security and access controls.

3 How We Collect Your Data

phmoba collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the phmoba platform, including through cookies, web beacons, and similar tracking technologies.
• Third-party sources: Identity verification data from third-party KYC service providers; fraud prevention data from anti-fraud service providers; payment data from payment processors including GCash and PayMaya.
• Publicly available sources: Information from public registers or databases where necessary for regulatory compliance or fraud prevention purposes.

phmoba will always inform you at the point of collection what personal data is being collected and for what purpose, to the extent required by applicable law.

4 How We Use Your Personal Data

phmoba uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phmoba account, including processing your registration, verifying your identity, and managing your account settings.
• Service delivery: To provide you with access to the phmoba platform, process your bets, manage your deposits and withdrawals, and deliver the gaming services you have requested.
• Identity verification and KYC: To verify your identity and age (21+) in compliance with applicable Philippine gaming regulations and anti-money laundering requirements.
• Payment processing: To process your deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Customer support: To respond to your enquiries, complaints, and support requests, and to maintain records of our communications with you.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform.
• Legal and regulatory compliance: To comply with our obligations under Philippine law, including reporting requirements under the Anti-Money Laundering Act and applicable gaming regulations.
• Responsible gaming: To monitor your gaming activity and identify potential signs of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the phmoba platform.
• Marketing communications: To send you promotional offers, bonuses, and news about phmoba, where you have consented to receive such communications or where we have a legitimate interest in doing so. You may opt out at any time.

phmoba will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5 Legal Basis for Processing

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

• Contractual necessity: Processing that is necessary to perform our contract with you — i.e., to provide you with access to the phmoba platform and deliver the services described in our Terms & Conditions.
• Legal obligation: Processing that is required to comply with our legal and regulatory obligations under Philippine law, including anti-money laundering regulations, gaming regulations, and tax reporting requirements.
• Legitimate interests: Processing that is necessary for phmoba's legitimate business interests, including fraud prevention, platform security, and improving our services, provided that such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including the sending of marketing communications. Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing and Disclosure

phmoba 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:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and identity verification service providers engaged by phmoba to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention services: Third-party fraud detection and prevention service providers who assist phmoba in identifying and preventing fraudulent activity on the platform.
• IT and infrastructure providers: Cloud hosting, data storage, and technology service providers who process data on phmoba's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies in the Philippines where disclosure is required by law, court order, or regulatory directive, including the Anti-Money Laundering Council (AMLC) and the National Privacy Commission (NPC).
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by phmoba in connection with the operation of the platform, subject to professional confidentiality obligations.

All third parties with whom phmoba shares personal data are required to handle that data in accordance with applicable data protection laws and phmoba's data protection standards. Where third parties process data on phmoba's behalf, they do so only on phmoba's documented instructions.

7 Data Retention

phmoba retains your personal data for as long as is necessary to fulfil 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 data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with applicable anti-money laundering regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine anti-money laundering laws.
• Identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support communications: Retained for three (3) years from the date of the communication, or longer where the communication relates to an ongoing dispute or legal matter.
• Marketing consent records: Retained for the duration of your account and for three (3) years following account closure, to demonstrate compliance with consent requirements.

Where personal data is no longer required for any lawful purpose, phmoba will securely delete or anonymise it in accordance with our data destruction procedures.

8 Data Security

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

• Encryption: All data transmitted between your device and the phmoba platform is encrypted using SSL/TLS protocols. Sensitive data stored on our servers is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorised phmoba personnel and service providers who have a legitimate need to access it. All access is logged and monitored.
• Two-factor authentication: phmoba supports and encourages the use of two-factor authentication (2FA) for all player accounts to provide an additional layer of security.
• Regular security audits: phmoba conducts regular security assessments and penetration testing to identify and address potential vulnerabilities in our systems.
• Staff training: All phmoba staff who handle personal data receive regular training on data protection obligations and security best practices.
• Incident response: phmoba maintains a data breach response plan. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

While phmoba takes all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. You are responsible for keeping your account credentials confidential and for notifying phmoba immediately if you suspect any unauthorised access to your account.

9 Cookies and Tracking Technologies

phmoba uses cookies and similar tracking technologies on the phmoba platform to enhance your user experience, analyse platform usage, and support our security and fraud prevention measures. The following types of cookies are used:

• Strictly necessary cookies: These cookies are essential for the operation of the phmoba platform and cannot be disabled. They include cookies that enable you to log in, maintain your session, and use core platform features.
• Functional cookies: These cookies remember your preferences and settings — such as your preferred language and display options — to provide a more personalised experience.
• Analytics cookies: These cookies collect anonymised information about how users interact with the phmoba platform, helping us understand which features are most used and where improvements can be made. This data is aggregated and does not identify individual users.
• Security cookies: These cookies support our fraud detection and prevention systems by helping us identify unusual or suspicious activity on the platform.

phmoba does not use third-party advertising or tracking cookies. You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may affect the functionality of the phmoba platform.

10 Your Data Protection Rights

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

• Right to be informed: The right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data that phmoba holds about you, together with information about how it is being used.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data that phmoba holds 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 phmoba's 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 phmoba's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that phmoba has not handled your personal data in accordance with applicable law.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. phmoba will respond to all valid requests within thirty (30) days. In some cases, we may need to verify your identity before processing your request.

11 Children's Privacy and Age Restriction

The phmoba platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. phmoba does not knowingly collect personal data from individuals under the age of 21.

During the registration process, phmoba collects your date of birth and verifies your age as part of our Know Your Customer (KYC) procedures. Where phmoba has reason to believe that an account has been registered by or on behalf of a person under the age of 21, the account will be suspended immediately, all pending transactions will be cancelled, and any deposited funds will be returned to the payment source after deducting any applicable processing fees.

If you are a parent or guardian and believe that your child has registered an account on phmoba, please contact our support team immediately using the details in Section 14. We will investigate and take appropriate action as quickly as possible.

12 International Data Transfers

phmoba primarily stores and processes personal data within the Philippines. In some cases, personal data may be transferred to and processed in countries outside the Philippines — for example, where phmoba uses cloud infrastructure or service providers with operations in other jurisdictions.

Where personal data is transferred outside the Philippines, phmoba ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012. These safeguards may include:

• Transferring data only to countries that have been assessed as providing an adequate level of data protection.
• Entering into data transfer agreements with recipient organisations that incorporate standard contractual clauses approved by the National Privacy Commission.
• Ensuring that recipient organisations are bound by binding corporate rules or other approved transfer mechanisms.

You may request further information about the safeguards in place for international data transfers by contacting our Data Protection Officer.

13 Changes to This Privacy Policy

phmoba reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes to this Privacy Policy are material, phmoba will notify registered users via the email address associated with their account or through a prominent notice on the platform, no less than seven (7) days before the changes take effect. For changes required by law or regulatory directive, we may implement changes with immediate effect and notify you as soon as practicable thereafter.

Your continued use of the phmoba platform after the effective date of any amendment to this Privacy Policy constitutes your acknowledgement of the updated Policy. We encourage you to review this Privacy Policy periodically to stay informed of how phmoba protects your personal data.

14 Contact Us and Data Protection Officer

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

• Support Page: phmoba.xyz/support
• Live Chat: Available 24/7 via the phmoba platform
• Email: [email protected]

phmoba aims to acknowledge all privacy-related requests within five (5) business days and to provide a substantive response within thirty (30) days. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

If you are not satisfied with phmoba's response to your privacy request or complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.