phspin6 Privacy Policy

1.1 phspin6 is committed to protecting the privacy and personal data of every player on the Platform. We understand that Filipino players entrust us with sensitive information when they register, deposit funds, and engage in gaming activities, and we take that responsibility seriously.

1.2 This Policy applies to all personal data collected through the phspin6 Platform, including data collected via the website at phspin6.app, any mobile-optimized version of the Platform, and any communications between you and phspin6 (including live chat, email, and support interactions).

1.3 This Policy should be read alongside the phspin6 Terms & Conditions, which govern the overall relationship between phspin6 and its players. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2.1 phspin6 collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.2 phspin6 does not collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. We do not collect data relating to your racial or ethnic origin, political opinions, religious beliefs, or health information unless specifically required by law.

3.1 phspin6 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your phspin6 player account, including processing your registration, verifying your identity, and managing your account settings;
• Service Delivery: To provide you with access to all games, features, and services available on the phspin6 Platform, including live casino, slots, sports betting, and promotional offers;
• Payment Processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card, and to maintain accurate financial records in Philippine Peso (PHP);
• Regulatory Compliance: To fulfill our obligations under Philippine law, including anti-money laundering (AML) requirements, PAGCOR licensing conditions, and the Data Privacy Act of 2012;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other illegal conduct on the phspin6 Platform;
• Responsible Gaming: To monitor gameplay patterns and identify players who may be exhibiting signs of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our live chat and email support channels;
• Platform Improvement: To analyze usage data and improve the performance, design, and features of the phspin6 Platform;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided your consent to receive such communications.

3.2 phspin6 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

4.1 phspin6 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our obligations under the phspin6 Terms & Conditions, including account creation, payment processing, and service delivery;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR licensing requirements, and tax reporting duties;
• Legitimate Interests: Processing is necessary for phspin6's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your data protection rights;
• Consent: For marketing communications and non-essential cookies, phspin6 relies on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5.1 phspin6 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 third parties only to the extent necessary for the purposes described in this Policy:

• Payment Service Providers: GCash (Mynt), Maya (Voyager Innovations), and Philippine banking institutions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the processing of deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and AML compliance service providers who assist phspin6 in verifying player identities and screening against sanctions lists;
• Game Software Providers: Licensed game developers and content providers whose games are hosted on the phspin6 Platform — these providers may receive limited technical data necessary to deliver their games;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulatory mandate;
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on phspin6's behalf under strict data processing agreements;
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

5.2 All third-party service providers engaged by phspin6 are required to implement appropriate technical and organizational security measures and are contractually prohibited from using your personal data for any purpose other than providing services to phspin6.

5.3 In the event of a merger, acquisition, or sale of all or substantially all of phspin6's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

6.1 phspin6 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and collect usage analytics. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled without affecting Platform functionality;
• Performance & Analytics Cookies: Used to collect anonymized data about how players interact with the phspin6 Platform, helping us identify areas for improvement;
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming limits you have set;
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of phspin6 marketing campaigns — only activated with your consent.

6.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phspin6 Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the Platform.

7.1 phspin6 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account Data: Retained for the duration of your active phspin6 account, plus a minimum of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory investigation;
• Support Communications: Retained for three (3) years from the date of the last interaction, unless the communication relates to an ongoing dispute or legal matter;
• Marketing Consent Records: Retained for the duration of your consent, plus three (3) years to demonstrate compliance with consent requirements.

7.2 When personal data is no longer required for any lawful purpose, phspin6 will securely delete or anonymize it in accordance with our data destruction procedures. Anonymized data that can no longer be linked to an individual may be retained indefinitely for statistical and analytical purposes.

8.1 phspin6 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:

• Encryption: All data transmitted between your device and the phspin6 Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption;
• Access Controls: Access to personal data is restricted to phspin6 personnel and authorized third parties on a strict need-to-know basis. All access is logged and regularly audited;
• Two-Factor Authentication: phspin6 supports and encourages the use of two-factor authentication (2FA) for all player accounts to prevent unauthorized access;
• Penetration Testing: phspin6 conducts regular security assessments and penetration tests to identify and remediate vulnerabilities in the Platform;
• Incident Response: phspin6 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, phspin6 will notify the National Privacy Commission and affected players within the timeframes prescribed by the Data Privacy Act.

8.2 While phspin6 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your phspin6 login credentials and for notifying us immediately if you suspect unauthorized access to your account.

9.1 Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by phspin6:

10.1 The phspin6 Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. phspin6 does not knowingly collect personal data from persons under the age of 21.

10.2 If phspin6 becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the relevant account, delete the personal data in question, and handle any associated funds in accordance with applicable regulations.

10.3 If you are a parent or guardian and believe that your child has registered on the phspin6 Platform, please contact our support team immediately so that we can take appropriate action.

11.1 phspin6 primarily processes and stores personal data within the Republic of the Philippines. However, some of our third-party service providers — including cloud infrastructure providers and game software developers — may process data in other jurisdictions.

11.2 Where personal data is transferred outside the Philippines, phspin6 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission;
• Transfers to countries or organizations that the NPC has determined provide an adequate level of data protection;
• Binding corporate rules where the transfer is within a group of companies.

11.3 You may request information about the specific safeguards in place for any international transfer of your personal data by contacting phspin6's Data Protection Officer.

12.1 phspin6 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. When material changes are made, phspin6 will notify registered players via the email address associated with their account and/or by posting a prominent notice on the phspin6 Platform.

12.2 The updated Policy will become effective on the date specified in the notice. Your continued use of the phspin6 Platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not agree with the updated Policy, you may request account closure in accordance with the phspin6 Terms & Conditions.

12.3 The "Last Updated" date at the top of this page always reflects the most recent revision. We encourage you to review this Policy periodically to stay informed about how phspin6 protects your personal data.

13.1 phspin6 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact us through the following channels:

13.2 If you are not satisfied with phspin6's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent authority responsible for administering and implementing the Data Privacy Act of 2012.