Privacy Policy

phrus ("we," "us," "our") is committed to protecting the privacy and personal data of all individuals who use the phrus online gaming platform. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

This Privacy Policy describes in detail the types of personal data phrus collects from players and visitors, the purposes for which that data is processed, the parties with whom it may be shared, the security measures in place to protect it, and the rights available to you as a data subject under Philippine law.

phrus takes its obligations as a personal information controller seriously. We process personal data only when there is a lawful basis for doing so, and we are committed to handling your information with transparency, fairness, and respect for your privacy at all times.

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, phrus acts as the personal information controller in respect of all personal data collected through the phrus platform.

As personal information controller, phrus determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data protection law.

If you have any questions about how phrus processes your personal data, or if you wish to exercise any of your data subject rights as described in Section 11 of this Policy, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 15.

phrus collects the following categories of personal data in connection with your use of the platform. We collect only what is necessary for the specific purposes described in this Policy.

phrus collects personal data through the following means:

• Direct Collection: Information you provide directly to phrus when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions.
• Automated Collection: Technical and usage data collected automatically when you access and interact with the phrus platform, including through cookies, web beacons, and similar tracking technologies as described in Section 8.
• Third-Party Sources: Identity verification data received from KYC service providers, fraud prevention data from payment processors, and publicly available information used to verify the accuracy of data you have provided.
• Payment Processors: Transaction confirmation data received from GCash, PayMaya, BDO, BPI, Metrobank, and other payment service providers in connection with your deposits and withdrawals on phrus.

phrus does not collect personal data from social media platforms or third-party data brokers for marketing purposes.

phrus uses the personal data it collects for the following specific purposes:

• Account Management: To create, maintain, and manage your phrus account, including verifying your identity and eligibility to use the platform.
• Service Delivery: To provide you with access to phrus games, process your deposits and withdrawals, and deliver the full range of phrus platform features.
• KYC and Age Verification: To verify that you meet the minimum age requirement of 21 years and to comply with our Know Your Customer obligations under applicable Philippine regulations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the phrus platform.
• Responsible Gaming: To monitor gaming patterns and identify players who may be exhibiting signs of problem gambling, in order to provide appropriate support and intervention tools.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance in connection with your use of phrus.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering requirements, data protection obligations, and any lawful requests from regulatory authorities.
• Platform Improvement: To analyze usage patterns and technical performance data in order to improve the phrus platform, fix bugs, and develop new features.
• Communications: To send you important account-related notifications, security alerts, and, where you have consented, promotional communications about phrus offers and updates.

phrus does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

phrus processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 of the Philippines:

• Contractual Necessity: Processing that is necessary to perform the contract between you and phrus — specifically, to provide you with access to the phrus platform and to process your financial transactions.
• Legal Obligation: Processing that is required for phrus to comply with applicable Philippine laws and regulations, including anti-money laundering laws, gaming regulations, and tax reporting requirements.
• Legitimate Interests: Processing carried out for phrus's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as the sending of promotional communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Vital Interests: In exceptional circumstances, processing that is necessary to protect your vital interests or those of another person, such as in connection with responsible gaming interventions.

phrus does not sell, rent, or trade your personal data to any third party. phrus may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Service Providers: Third-party companies that provide services to phrus, including KYC verification providers, payment processors (GCash, PayMaya, BDO, BPI, Metrobank), IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only on phrus's instructions and in accordance with applicable data protection law.
• Regulatory Authorities: Philippine government agencies and regulatory bodies, including PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by law or in response to a lawful order.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other lawful legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of phrus's assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.
• With Your Consent: To any other third party where you have given your explicit prior consent to such disclosure.

phrus uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and collect usage analytics. The following types of cookies are used by phrus:

• Strictly Necessary Cookies: These cookies are essential for the phrus platform to function correctly. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without significantly impairing your ability to use phrus.
• Functional Cookies: These cookies remember your preferences and settings on phrus, such as your preferred language and display options, to provide a more personalized experience.
• Analytics Cookies: These cookies collect aggregated, anonymized information about how visitors use the phrus platform, helping us understand which features are most popular and where improvements can be made.
• Security Cookies: These cookies help phrus detect and prevent fraudulent activity, unauthorized access attempts, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phrus platform. phrus does not use third-party advertising cookies or cross-site tracking technologies for marketing purposes.

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

• Encryption: All data transmitted between your device and phrus servers is encrypted using Transport Layer Security (TLS). Sensitive data at rest, including financial information and identity documents, is encrypted using industry-standard encryption algorithms.
• Access Controls: Access to personal data within phrus is restricted on a strict need-to-know basis. All phrus staff with access to personal data are subject to confidentiality obligations and receive regular data protection training.
• Infrastructure Security: phrus servers are hosted in secure data centers with physical access controls, redundant systems, and continuous security monitoring.
• Vulnerability Management: phrus conducts regular security assessments and penetration testing to identify and remediate potential vulnerabilities in the platform.
• Incident Response: phrus maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, phrus will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

While phrus takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are also responsible for maintaining the security of your phrus account credentials.

phrus 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 and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active phrus account, plus a minimum of five (5) years following account closure, as required by anti-money laundering regulations.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, in compliance with applicable Philippine financial regulations.
• KYC Documents: Identity verification documents are retained for the duration of your account plus five (5) years following account closure.
• Gaming Records: Game history and session data are retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes.
• Support Communications: Customer support records are retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Records of your marketing consent or opt-out are retained for the duration of your account to demonstrate compliance with applicable law.

Upon expiry of the applicable retention period, phrus will securely delete or anonymize your personal data in accordance with its data disposal procedures.

As a data subject under the Data Privacy Act of 2012 of the Philippines, you have the following rights in respect of your personal data held by phrus. You may exercise any of these rights by contacting our Data Protection Officer using the details in Section 15.

phrus will respond to all data subject rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case phrus will notify you of the extension and the reasons for it. phrus will not charge a fee for processing data subject rights requests unless they are manifestly unfounded or excessive.

The phrus platform is strictly intended for adults aged 21 years and older. phrus does not knowingly collect personal data from individuals under the age of 21. This is consistent with the minimum legal age for casino-style gambling in the Republic of the Philippines.

If phrus becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and permanently close the associated account. All funds in such accounts will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account on phrus or provided personal data to phrus, please contact our Data Protection Officer immediately using the contact details in Section 15.

phrus primarily processes and stores personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, for example in connection with cloud infrastructure or KYC verification services.

Where such international transfers occur, phrus ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission of the Philippines.
• Implementing contractual data protection clauses with international service providers that impose obligations equivalent to those under Philippine data protection law.
• Conducting due diligence on all international service providers to verify that they maintain appropriate technical and organizational security measures.

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

phrus 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 to this Policy, phrus will notify you through one or more of the following methods:

• A prominent notice displayed on the phrus platform upon your next login following the update.
• An email notification sent to the registered email address on your phrus account.
• An update to the "Last Updated" date displayed at the top of this Privacy Policy.

Your continued use of the phrus platform after the effective date of any amendment to this Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree with any changes to this Policy, you should cease using the phrus platform and may request account closure in accordance with the phrus Terms & Conditions.

phrus recommends that you review this Privacy Policy periodically to stay informed of how we are protecting your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way phrus processes your personal data, please contact our Data Protection Officer through the following channel:

When submitting a data subject rights request, please include your full name, registered phrus account email address, and a clear description of your request to help us process it efficiently.

If you are not satisfied with phrus's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about how to file a complaint with the NPC is available on the NPC's official website.

This Privacy Policy was last updated on January 1, 2026. This version supersedes all previous versions of the phrus Privacy Policy.