Privacy Policy

This Privacy Policy ("Policy") describes how phspinn Operations Inc. ("phspinn," "we," "us," "our") collects, processes, stores, and discloses personal data in connection with your use of the phspinn online gaming platform, accessible at phspinn.net and all associated mobile applications and sub-domains (collectively, the "Platform").

phspinn Operations Inc. is the data controller for personal data processed in connection with the Platform. As data controller, phspinn determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

Where phspinn engages third-party service providers to process personal data on its behalf (e.g., KYC verification partners, payment processors, game providers), those parties act as data processors and are bound by data processing agreements that require them to handle your data only in accordance with phspinn's documented instructions and this Policy.

phspinn collects personal data through several channels: directly from you during registration and platform use, automatically through technical systems as you use the Platform, and from third parties such as identity verification providers and payment processors. The categories of personal data we collect include the following:

phspinn does not collect special categories of personal data (i.e., data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data for identification purposes) except where strictly required by applicable law or where you voluntarily provide such data in a support context.

Under the Data Privacy Act of 2012 and its Implementing Rules, phspinn must have a lawful basis for processing your personal data. The bases we rely on are as follows:

• Contractual necessity: Processing required to perform our contract with you — i.e., providing you with access to the Platform, processing your deposits and withdrawals, crediting your winnings, and managing your account. Without this processing, we cannot provide the service.
• Legal obligation: Processing required to comply with our obligations under Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Terrorism Financing Prevention and Suppression Act, the Data Privacy Act of 2012, and tax reporting obligations.
• Legitimate interests: Processing necessary for phspinn's legitimate business interests, provided those interests are not overridden by your rights and freedoms. This includes fraud prevention, platform security, responsible gaming monitoring, and internal analytics to improve the Platform.
• Consent: Where we rely on your consent — for example, to send you promotional emails or push notifications about bonuses and new games — you have the right to withdraw that consent at any time through your account notification settings without affecting the lawfulness of processing carried out prior to withdrawal.

phspinn uses personal data for the following specific purposes, each linked to one or more of the lawful bases described in Section 03:

• Account creation and management: To register your account, verify your identity and age (21+ requirement under PAGCOR rules), maintain your account preferences, and provide you with access to the Platform.
• Transaction processing: To process your deposits via GCash, PayMaya, BPI, BDO, Metrobank, Visa/Mastercard, and cryptocurrency; to credit your account; and to process withdrawal requests to your nominated payment method.
• KYC and AML compliance: To verify your identity and source of funds as required by PAGCOR, AMLA, and our internal compliance policies. This may involve automated screening against sanctions lists and politically exposed persons (PEP) databases.
• Responsible gaming: To monitor your gaming activity for indicators of problem gambling behaviour, to apply deposit limits or cool-off periods you have set, and to intervene proactively where required by our PAGCOR licence obligations.
• Customer support: To respond to your queries, resolve disputes, and manage feedback and complaints.
• Marketing and promotions: To send you information about phspinn promotions, new games, and special offers — but only where you have provided consent or where we have a legitimate interest and you have not opted out.
• Platform improvement and analytics: To understand how players use the Platform, to identify technical issues, and to develop new features and improvements using aggregated and pseudonymised data.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, collusion, and other prohibited conduct on the Platform.

phspinn does not sell your personal data. We share your personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Service providers (data processors): Third-party companies that process data on our behalf, including our KYC and identity verification partner, payment gateway and e-wallet processors (GCash, PayMaya, BPI, BDO, Metrobank), game content providers, cloud hosting providers, and customer support platform operators. All such parties are bound by data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), and law enforcement agencies — where disclosure is required or permitted by applicable Philippine law.
• AML and fraud screening providers: Automated screening services that check your identity against sanctions lists, PEP databases, and adverse media sources as required by the AMLA and our PAGCOR licence conditions.
• Corporate transactions: In the event of a merger, acquisition, restructuring, or sale of assets involving phspinn Operations Inc., your personal data may be transferred to the relevant acquiring or successor entity, subject to equivalent privacy protections.

phspinn uses cookies and similar tracking technologies (collectively, "cookies") on the Platform to deliver, maintain, and improve its services. Cookies are small text files placed on your device by your browser when you visit the Platform.

You can manage your cookie preferences through the cookie settings panel accessible from the footer of the Platform. You may also configure your browser to block or delete cookies, though this may affect the functionality of certain features. phspinn does not use third-party advertising cookies or share cookie data with external advertising networks.

phspinn retains personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law. The following retention schedule applies:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with phspinn's data disposal procedures. Anonymised data (which can no longer identify you) may be retained indefinitely for statistical and research purposes.

Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights with respect to your personal data held by phspinn. To exercise any of these rights, contact our Data Protection Officer (see Section 12).

If you are not satisfied with phspinn's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

phspinn implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS 1.3): All data transmitted between your browser or app and phspinn's servers is encrypted in transit using TLS 1.3 with AES-256 cipher suites.
• Encryption at rest: Sensitive data fields — including payment references, government ID numbers, and authentication tokens — are encrypted at rest using AES-256.
• Access controls: Strict role-based access controls (RBAC) limit phspinn staff access to personal data on a need-to-know basis. All access is logged and audited.
• Two-Factor Authentication (2FA): 2FA via SMS OTP is available to all players and is mandatory for all phspinn staff accessing internal systems containing personal data.
• Regular security audits: phspinn engages independent third-party security firms to conduct penetration testing and vulnerability assessments at least annually.
• Data breach response plan: A documented incident response plan is in place, with defined escalation procedures, NPC notification timelines, and player communication protocols.

phspinn is an online gambling platform strictly intended for persons aged 21 years and above, in compliance with PAGCOR regulations and the applicable provisions of Philippine law governing gambling activities. The Platform is not directed at, and is not intended for use by, any person under the age of 21.

phspinn does not knowingly collect personal data from any person under the age of 21. If you are a parent or guardian and believe that a minor has registered on the Platform or has otherwise provided personal data to phspinn, please contact our support team immediately. Upon verification, we will take prompt steps to delete the relevant account and any associated personal data.

phspinn reviews this Privacy Policy regularly and reserves the right to update it at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. The effective date at the top of this page always reflects the date the current version came into force.

When we make material changes to this Policy — for example, changes that affect the categories of data we collect, the purposes for which we use it, or the rights available to you — we will notify registered players by email to the address registered on their account and/or by a prominent notice on the Platform prior to the changes taking effect, where reasonably practicable.

Your continued use of the Platform after the effective date of any revised Policy constitutes your acknowledgement of the updated Policy. If you disagree with any changes, you may close your account and request deletion of your data subject to the retention obligations described in Section 07.

phspinn has appointed a Data Protection Officer (DPO) as required under the Data Privacy Act of 2012 and NPC regulations. The DPO is responsible for overseeing phspinn's compliance with data privacy laws and is your primary point of contact for any privacy-related concerns.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to report a concern about how phspinn handles your personal data, please contact us:

You also have the right to lodge a complaint directly with the National Privacy Commission if you believe phspinn has not handled your personal data in accordance with the Data Privacy Act of 2012. Details on how to file a complaint are available on the NPC website.