phlagi Privacy Policy – Your Data, Your Rights

phlagi ("phlagi," "we," "us," or "our") is an online gaming platform operating in the Philippines, offering casino games, slots, bingo, fishing games, and related entertainment services through the website phlagi.com and any associated mobile applications or platforms (collectively, the "Platform").

phlagi acts as the Personal Information Controller (as defined under Republic Act No. 10173, the Data Privacy Act of 2012) with respect to the personal data of players and visitors who use the phlagi Platform. This means phlagi determines the purposes and means by which your personal data is processed.

This Privacy Policy applies to all personal data collected by phlagi through the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and general browsing of the phlagi website.

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

phlagi does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, unless specifically required for responsible gaming purposes (e.g., self-exclusion requests) or as mandated by applicable law.

phlagi collects personal data through the following means:

• Direct Interactions: When you register a phlagi account, complete identity verification, make a deposit or withdrawal, contact our support team, or respond to a survey or promotion, you directly provide us with personal data.
• Automated Technologies: When you access the phlagi Platform, we automatically collect certain technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This data helps us maintain platform security and improve your experience.
• Third-Party Sources: We may receive personal data about you from third-party identity verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), fraud prevention services, and analytics providers. All third-party data sharing is governed by appropriate data processing agreements.
• Publicly Available Sources: In limited circumstances related to fraud prevention or regulatory compliance, phlagi may collect data from publicly available sources such as government databases or public records.

phlagi uses your personal data only for the purposes for which it was collected, or for compatible purposes that you would reasonably expect. The primary purposes for which we process your personal data include:

• Account Management: Creating and maintaining your phlagi account, verifying your identity, and managing your phlagi login credentials.
• Service Delivery: Providing access to phlagi's games, processing your bets, crediting winnings, and delivering the full range of phlagi Casino services.
• Financial Processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank; detecting and preventing fraudulent transactions.
• Regulatory Compliance: Fulfilling our obligations under Philippine law, including anti-money laundering (AML) requirements, PAGCOR regulatory requirements, and the Data Privacy Act of 2012.
• Responsible Gaming: Monitoring gameplay patterns to identify potential problem gambling behavior, administering self-exclusion requests, and enforcing deposit limits set by players.
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform Improvement: Analyzing usage data to improve the phlagi Platform's performance, user experience, and game offerings.
• Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other security threats.

phlagi will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

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

• Contractual Necessity: Processing is necessary to perform the contract between you and phlagi — specifically, to provide you with access to the phlagi Platform and its services, including account management, gameplay, and financial transactions.
• Legal Obligation: Processing is necessary to comply with phlagi's legal obligations under Philippine law, including AML regulations, PAGCOR requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for phlagi's legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your data protection rights.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — phlagi relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

phlagi 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 your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification service providers who assist phlagi in verifying player identities and preventing fraud.
• Game Providers: Third-party game software providers whose games are available on the phlagi Platform. These providers may receive limited technical data necessary to deliver their games.
• Analytics Providers: Service providers who help phlagi analyze Platform usage and improve user experience. All analytics data is processed under strict data processing agreements.
• Regulatory Authorities: Philippine government agencies and regulatory bodies, including PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC), where disclosure is required by law or regulation.
• Law Enforcement: Philippine law enforcement authorities, where disclosure is required by a valid legal order, court order, or where phlagi reasonably believes disclosure is necessary to prevent or investigate illegal activity.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by phlagi, subject to professional confidentiality obligations.

All third parties with whom phlagi shares personal data are required to process that data in accordance with applicable Philippine data protection laws and phlagi's data protection standards.

phlagi uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and analyze how the Platform is used. The types of cookies we use include:

• Strictly Necessary Cookies: These cookies are essential for the phlagi Platform to function correctly. They enable core features such as secure phlagi login sessions, account authentication, and fraud prevention. These cookies cannot be disabled without significantly impairing Platform functionality.
• Performance Cookies: These cookies collect anonymized information about how visitors use the phlagi Platform, such as which pages are visited most frequently and whether users encounter error messages. This data helps us improve Platform performance.
• Functionality Cookies: These cookies remember your preferences and settings — such as your preferred language or display settings — to provide a more personalized experience on phlagi.
• Analytics Cookies: These cookies help phlagi understand player behavior and engagement patterns on the Platform, enabling us to make data-driven improvements to our game offerings and user interface.

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

phlagi 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 Philippine law. Our general data retention periods are as follows:

Upon expiry of the applicable retention period, phlagi will securely delete or anonymize your personal data in accordance with our internal data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for statistical and analytical purposes, as it can no longer be used to identify you.

phlagi implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• SSL/TLS Encryption: All data transmitted between your device and phlagi's servers is encrypted using industry-standard SSL/TLS protocols.
• Access Controls: Access to personal data is restricted to authorized phlagi personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Firewalls and Intrusion Detection: phlagi's servers are protected by enterprise-grade firewalls and intrusion detection systems that monitor for and respond to suspicious activity in real time.
• Regular Security Audits: phlagi conducts regular internal and third-party security audits to identify and remediate potential vulnerabilities in our systems.
• Two-Factor Authentication: phlagi supports two-factor authentication (2FA) for player accounts to provide an additional layer of security for your phlagi login.
• Data Breach Response: In the event of a personal data breach that poses a risk to your rights and freedoms, phlagi will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

The phlagi Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. phlagi does not knowingly collect, process, or retain personal data from individuals under the age of 21.

All new phlagi accounts are subject to mandatory age verification as part of the KYC process. Players who cannot provide valid proof of age will not be permitted to access the phlagi Platform. If phlagi discovers that personal data has been collected from a person under the age of 21, we will immediately suspend the relevant account and delete the associated personal data without undue delay.

phlagi primarily stores and processes your personal data within the Philippines. However, in certain circumstances — such as when using third-party service providers whose servers are located outside the Philippines — your personal data may be transferred to, stored in, or processed in countries other than the Philippines.

Where such international transfers occur, phlagi ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012 and the regulations of the National Privacy Commission. These safeguards may include:

• Entering into data processing agreements with third-party recipients that incorporate data protection standards equivalent to those required under Philippine law.
• Transferring data only to countries or organizations that the NPC has determined provide an adequate level of data protection.
• Obtaining your explicit consent for specific international transfers where required by applicable law.

By using the phlagi Platform and accepting this Privacy Policy, you acknowledge that your personal data may be transferred internationally in the circumstances described above, subject to the safeguards outlined herein.

The phlagi Platform may contain links to third-party websites, applications, or services. These third-party platforms operate independently of phlagi and are governed by their own privacy policies. phlagi is not responsible for the privacy practices, content, or security of any third-party platforms.

We encourage you to review the privacy policies of any third-party platforms you visit before providing them with your personal data. The inclusion of a link to a third-party platform on the phlagi website does not constitute an endorsement of that platform's privacy practices or content.

phlagi 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 regulatory requirements. When we make material changes to this Privacy Policy, we will:

• Post the updated Privacy Policy on the phlagi website with a revised effective date prominently displayed at the top of the page.
• Notify registered phlagi players via email or in-platform notification where the changes are material and affect your rights or our obligations.
• Where required by law, obtain your renewed consent before implementing changes that affect processing activities based on consent.

Your continued use of the phlagi Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Privacy Policy periodically to stay informed about how phlagi protects your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or phlagi's data processing practices, please contact our Data Protection Officer using the details below. We are committed to addressing all privacy-related inquiries promptly and transparently.

• Data Protection Officer: phlagi DPO
• Email: [email protected]
• Website: phlagi.com
• Response Time: Within 72 hours for acknowledgment; 15 business days for substantive response

If you are not satisfied with phlagi's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012 and ensuring compliance by personal information controllers operating in the Philippines.