Table of Contents
- Introduction and Scope
- Data Controller Information
- What Personal Data We Collect
- How We Collect Your Data
- Legal Basis for Processing
- How We Use Your Personal Data
- Sharing Your Personal Data
- Cookies and Tracking Technologies
- Data Retention
- Data Security
- Your Data Subject Rights
- Children's Privacy
- Amendments to This Policy
- Contact and Complaints
1. Introduction and Scope
This Privacy Policy ("Policy") is issued by phspin ("phspin," "We," "Us," or "Our") and applies to all personal data collected in connection with your use of the phspin online casino and sports betting platform, accessible at phspin.cam, including any mobile-optimised versions of the Platform (collectively, the "Platform" or "Service").
phspin is committed to protecting the privacy and personal data of all players and users, including Filipino players across Metro Manila, Cebu, Davao, Iloilo, and every part of the archipelago. This Policy is designed to comply with the Republic of the Philippines' Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (NPC).
By registering for an account or continuing to use the phspin Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal data as described herein. If you do not agree with any provision of this Policy, you should cease using the Platform and contact our Data Protection Officer to request account closure.
Scope Note: This Policy applies to all personal data processed by phspin in connection with the Platform, including data collected during registration, KYC verification, financial transactions, gameplay, and customer support interactions. It does not apply to third-party websites or services that may be linked to or from the Platform.
2. Data Controller Information
For the purposes of the Data Privacy Act of 2012 and this Policy, phspin is the personal information controller responsible for the personal data collected through the Platform. phspin has appointed a Data Protection Officer (DPO) who is responsible for overseeing our data protection practices and ensuring compliance with applicable privacy laws.
You may contact our Data Protection Officer with any privacy-related inquiries, requests, or complaints at the following contact address:
- Data Protection Officer, phspin
- Email: [email protected] (please include "DPO / Privacy Request" in your subject line)
phspin is registered with the National Privacy Commission (NPC) of the Philippines in accordance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations.
3. What Personal Data We Collect
phspin collects personal data that is necessary for providing safe, compliant, and effective online gaming and sports betting services to Filipino players. The categories of personal data we collect include:
3.1 Identity and Registration Data
- Full legal name as it appears on your government-issued identification;
- Date of birth (to verify compliance with the 21+ age requirement);
- Gender;
- Nationality;
- Government-issued identification numbers (e.g., PhilSys ID number, passport number, driver's licence number, UMID number); and
- Photographs or scans of government-issued identification documents submitted for KYC verification.
3.2 Contact and Address Data
- Email address;
- Philippine mobile phone number;
- Residential address (including barangay, city/municipality, province, and postal code); and
- Proof of address documents (e.g., utility bills, bank statements).
3.3 Financial and Transaction Data
- Payment method details (e.g., registered GCash or Maya mobile number, bank account details for BDO, BPI, Metrobank, or UnionBank);
- Deposit and withdrawal history;
- Transaction amounts, dates, and reference numbers;
- Account balance information; and
- Bonus and promotional activity records.
3.4 Gaming and Betting Activity Data
- Game session records (games played, duration, bets placed, outcomes);
- Sports betting history (markets wagered, odds accepted, results);
- Responsible gaming settings (deposit limits, self-exclusion status, cooling-off periods); and
- Gameplay preferences and settings.
3.5 Technical and Device Data
- IP address and geolocation data (country and region level);
- Device type, operating system, and browser type;
- Session timestamps and login records;
- Cookie identifiers and similar tracking data; and
- Platform navigation and interaction logs.
3.6 Communications Data
- Records of correspondence with phspin customer support (including chat transcripts, email exchanges, and support ticket history);
- Responses to surveys and promotional communications; and
- Feedback submitted through any Platform feedback mechanism.
4. How We Collect Your Personal Data
phspin collects personal data through the following primary channels:
| Collection Method | Description |
|---|---|
| Direct Registration | Data you provide when creating your phspin account, including name, email, date of birth, mobile number, and residential address. |
| KYC Verification | Identity documents and proof of address submitted during the account verification process mandated by PAGCOR and the Anti-Money Laundering Act. |
| Payment Processing | Financial details provided or generated when you make deposits and withdrawal requests via GCash, Maya, bank transfer, or other accepted payment methods. |
| Platform Interaction | Gaming and betting activity automatically recorded as you use the Platform, including game sessions, wagers, and account settings changes. |
| Technical Collection | Device, browser, and connection data collected automatically via cookies, log files, and similar technologies when you access the Platform. |
| Customer Support | Communications data you provide when you contact phspin's support team via live chat or email. |
| Third-Party Sources | Identity verification and fraud detection data received from licensed third-party verification service providers used to meet PAGCOR and AML compliance requirements. |
5. Legal Basis for Processing
phspin processes your personal data only where we have a lawful basis to do so under the Data Privacy Act of 2012 and its Implementing Rules and Regulations. The applicable legal bases for our processing activities are:
- Contractual Necessity: Processing necessary to perform the contract between you and phspin — including account registration, identity verification, processing deposits and withdrawals, and providing gaming and betting services — is undertaken on the basis that it is necessary for the performance of that contract.
- Legal Obligation: Processing necessary to comply with our legal obligations under Philippine law, including PAGCOR licensing requirements, Republic Act No. 9160 (Anti-Money Laundering Act, as amended), and Republic Act No. 10927 (AMLA Amendment extending coverage to casinos). This includes mandatory KYC verification and transaction monitoring.
- Legitimate Interests: Processing undertaken for phspin's legitimate business interests, where those interests are not overridden by your privacy rights. This includes fraud detection, platform security, responsible gaming monitoring, and improving our services.
- Consent: Where required by law, and for certain optional processing activities such as direct marketing communications, phspin will seek your explicit consent before processing your personal data for such purposes. You may withdraw your consent at any time without affecting the lawfulness of prior processing.
6. How We Use Your Personal Data
phspin uses the personal data we collect for the following purposes:
6.1 Account Management and Service Delivery
To create and maintain your phspin account, verify your identity and age, process your deposits and withdrawal requests, provide access to casino games and sports betting markets, manage your account balance and transaction history, and deliver customer support services.
6.2 Regulatory Compliance and Legal Obligations
To comply with phspin's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act, and other applicable Philippine laws and regulations. This includes conducting KYC due diligence, filing Suspicious Transaction Reports (STRs) and Covered Transaction Reports (CTRs) with the Anti-Money Laundering Council (AMLC) where required, and cooperating with PAGCOR audits and investigations.
6.3 Fraud Prevention and Platform Security
To detect, prevent, and investigate fraud, money laundering, cheating, multi-accounting, and other forms of abuse of the Platform. phspin uses automated and manual review processes to identify suspicious activity and protect the integrity of the gaming environment for all Filipino players.
6.4 Responsible Gaming
To monitor gameplay patterns and implement responsible gaming protections, including enforcing deposit limits, session time controls, cooling-off periods, and self-exclusion. phspin may use your gaming data to identify signs of problem gambling and proactively reach out to affected players in accordance with PAGCOR's responsible gaming requirements.
6.5 Communications and Marketing
To send you transactional communications related to your account (e.g., deposit confirmations, withdrawal notifications, security alerts), and, where you have consented, to send you promotional communications about phspin bonuses, events, and new features. You may opt out of marketing communications at any time by contacting our support team.
6.6 Platform Improvement
To analyse how players use the Platform in order to improve the user experience, game selection, platform performance, and customer support quality. This analysis is typically performed on aggregated or pseudonymised data where possible.
7. Sharing Your Personal Data
phspin does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your personal data only in the following limited circumstances:
7.1 Regulatory and Law Enforcement Authorities
phspin may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the National Bureau of Investigation (NBI), or other Philippine government authorities where required by law, court order, regulatory directive, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of phspin, our players, or the public.
7.2 Third-Party Service Providers
phspin engages trusted third-party service providers to assist in delivering our services. These providers are permitted to process your personal data only as instructed by phspin and subject to contractual data processing agreements that require them to maintain the confidentiality and security of your data. Categories of service providers include:
- Identity verification and KYC service providers;
- Payment processors and e-wallet service providers (including GCash and Maya infrastructure providers);
- Game content providers and platform technology partners;
- Fraud detection and cybersecurity services; and
- Cloud hosting and data storage infrastructure providers.
7.3 Business Transfers
In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of phspin's assets, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in accordance with applicable Philippine law.
No Unauthorised Third-Party Sharing: phspin will never share your personal data with third parties for their own marketing or commercial purposes without your explicit, separate consent. Your data is used only for the purposes described in this Policy.
8. Cookies and Tracking Technologies
phspin uses cookies and similar tracking technologies to operate, secure, and improve the Platform. Cookies are small text files stored on your device that allow us to recognise returning users, maintain session integrity, and analyse how the Platform is used.
8.1 Types of Cookies We Use
- Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that maintain your login state and security tokens that protect against cross-site request forgery (CSRF). These cookies cannot be disabled without impairing Platform functionality.
- Functional Cookies: Used to remember your preferences and settings, such as your preferred language, display settings, and responsible gaming tool configurations.
- Analytics Cookies: Used to understand how players navigate the Platform, which games are most popular, and where users encounter difficulties. This information is used in aggregated or pseudonymised form to improve the Platform.
- Security Cookies: Used to support fraud detection and account security functions, including identifying unusual login patterns or device anomalies.
8.2 Managing Cookies
You may manage cookie preferences through your browser settings. Most modern browsers allow you to refuse some or all cookies, or to receive a notification before a cookie is stored. Please note that disabling strictly necessary cookies will impair your ability to use core Platform features, including logging into your phspin account.
9. Data Retention
phspin retains your personal data only for as long as necessary to fulfil the purposes described in this Policy, and to comply with our legal and regulatory obligations under Philippine law. The following retention periods apply:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account and identity data | 5 years from account closure | PAGCOR licensing and AMLA requirements |
| KYC documents | 5 years from account closure | Anti-Money Laundering Act obligations |
| Financial transaction records | 5 years from transaction date | AMLA and PAGCOR record-keeping requirements |
| Gaming and betting activity logs | 3 years from activity date | Regulatory compliance and dispute resolution |
| Customer support records | 3 years from last interaction | Dispute resolution and service improvement |
| Technical and device logs | 12 months from collection | Security and fraud detection |
| Marketing consent records | Duration of consent plus 2 years | DPA consent record requirements |
Upon expiry of the applicable retention period, phspin will securely delete or anonymise your personal data in accordance with industry-standard data destruction practices.
10. Data Security
phspin implements comprehensive technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security measures include:
- Encryption: All data transmitted between your device and the phspin Platform is protected using Transport Layer Security (TLS) with 256-bit encryption. Sensitive data at rest, including financial details and identity documents, is encrypted using AES-256 encryption standards.
- Access Controls: Access to personal data within phspin's systems is restricted on a strict need-to-know basis. Employees with access to personal data undergo background screening and receive mandatory data privacy training.
- Two-Factor Authentication: phspin offers and recommends two-factor authentication (2FA) for all player accounts to reduce the risk of unauthorised access.
- Penetration Testing: The Platform undergoes regular third-party penetration testing and security audits to identify and remediate vulnerabilities.
- Incident Response: phspin maintains a documented data breach incident response plan. In the event of a personal data breach that poses a risk to player rights and freedoms, phspin will notify the National Privacy Commission and affected individuals in accordance with the timeframes prescribed under the Data Privacy Act of 2012.
While phspin employs robust security measures, no internet-based system can guarantee absolute security. You are responsible for maintaining the confidentiality of your account login credentials and for notifying phspin immediately if you suspect any unauthorised access to your account.
11. Your Data Subject Rights
As a data subject under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data processed by phspin:
- Right to Be Informed: The right to be informed about how your personal data is being collected, processed, and used — which is the primary purpose of this Privacy Policy.
- Right to Access: The right to request a copy of the personal data phspin 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 phspin holds about you.
- Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw your consent and no other legal basis exists for processing. Please note that this right may be subject to our legal obligations to retain certain data under PAGCOR and AMLA requirements.
- Right to Object: The right to object to phspin's processing of your personal data on grounds relating to your particular situation, including the right to object to processing for direct marketing purposes.
- Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit it to another data controller where technically feasible.
- Right to Damages: The right to claim compensation for damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.
- Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phspin has handled your personal data in violation of the Data Privacy Act of 2012.
To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." We will respond to your request within fifteen (15) business days in accordance with NPC guidelines. We may request proof of your identity before processing your request to protect against unauthorised disclosure of personal data.
NPC Contact: If you are not satisfied with our response to your privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines. The NPC can be reached through their official government website and offices in Quezon City, Metro Manila.
12. Children's Privacy
The phspin Platform is strictly intended for individuals aged 21 years and above. phspin does not knowingly collect personal data from individuals under the age of 21. As part of our registration and KYC processes, phspin takes active measures to verify the age of all account applicants in compliance with PAGCOR regulations and Philippine gaming laws.
If phspin becomes aware that personal data has been collected from an individual under the age of 21, we will immediately deactivate the relevant account, delete or anonymise all associated personal data, and report the incident through applicable channels. If you are a parent or guardian and believe that a minor has registered on the phspin Platform, please contact our support team immediately at [email protected].
13. Amendments to This Policy
phspin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. When material changes are made to this Policy, we will notify registered players via the email address associated with their phspin account and by posting a prominent notice on the Platform.
The "Last Updated" date at the top of this document reflects the date of the most recent revision. Continued use of the phspin Platform following publication of an updated Policy constitutes your acknowledgment of the changes. We encourage you to review this Policy periodically to stay informed of how phspin is protecting your personal data.
14. Contact and Complaints
phspin welcomes questions, requests, and feedback regarding this Privacy Policy and our data processing practices. Please direct all privacy-related communications to:
- Data Protection Officer, phspin
- Email: [email protected] — please include "Privacy Policy" or "DPO Request" in your subject line
- Response Time: phspin aims to acknowledge all privacy correspondence within two (2) business days and to provide a substantive response within fifteen (15) business days.
For issues related to responsible gaming, self-exclusion, or deposit limits, please visit our Responsible Gaming page or contact our support team directly via live chat on the Platform. For general account or payment queries, our 24/7 customer support team is available via live chat after you log in to your phspin account.
Your Data, Your Rights: phspin is committed to transparency and accountability in the way we handle your personal data. Under the Philippine Data Privacy Act of 2012, you have meaningful rights over your information — and we are here to help you exercise them. Do not hesitate to reach out to our Data Protection Officer with any concern, no matter how small.
How phspin Protects Your Data
These are the core data protection principles phspin applies every day to keep Filipino players' personal information safe and handled with integrity.
DPA 2012 Compliant
phspin processes all player data in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and the National Privacy Commission's implementing regulations. Your rights as a Philippine data subject are fully recognised and respected.
256-Bit Encryption
Every connection between your device and phspin is protected by TLS 256-bit encryption — the same standard used by major Philippine banks. Sensitive data stored on our servers, including KYC documents and financial details, is encrypted at rest using AES-256.
Dedicated Data Protection Officer
phspin has appointed a qualified Data Protection Officer (DPO) who oversees all data privacy matters and acts as your point of contact for exercising your rights under the Data Privacy Act. Our DPO is registered with the National Privacy Commission.
No Data Selling
phspin does not sell, rent, or trade your personal data to third parties for their commercial use — ever. Your data is used only for the purposes described in this Privacy Policy, including delivering our services, meeting legal obligations, and keeping the Platform secure.
Your Rights, Respected
You have the right to access, correct, delete, and port your personal data. You can object to marketing communications at any time. phspin responds to all data subject rights requests within 15 business days and cooperates fully with NPC oversight.
Clear Retention Limits
phspin retains your personal data only for as long as legally required or operationally necessary. Retention periods are clearly defined and data is securely deleted once those periods expire, in accordance with PAGCOR and AMLA record-keeping requirements.
Your Privacy Is Safe at phspin
phspin combines Philippine-grade data privacy compliance with a world-class online casino experience. GCash and Maya payments, 1,000+ games, and 24/7 Filipino support — all backed by the DPA 2012. 21+ only.
21+ only. Online gambling involves risk. Please gamble responsibly. PAGCOR regulated.