phpspin Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how phpspin ("phpspin," "we," "us," or "our") collects, uses, stores, and protects the personal information of players and visitors ("you" or "your") who access the phpspin website at https://phpspin.app and all associated services (collectively, the "Platform").

phpspin is committed to protecting the privacy of all players, particularly those based in the Philippines. This Policy is drafted in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as well as applicable guidelines issued by the National Privacy Commission (NPC).

By registering an account or using the phpspin Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the phpspin Platform.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference.

2. Personal Data We Collect

phpspin collects the following categories of personal data from players and Platform visitors:

2.1 Identity and Contact Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (to verify the 21+ age requirement);
• Nationality and country of residence;
• Residential address (barangay, city/municipality, province);
• Email address;
• Mobile phone number.

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., PhilSys ID, passport, driver's license, SSS/GSIS ID, Voter's ID);
• Proof of address documents (e.g., utility bill, bank statement);
• Selfie or liveness verification image where required;
• Proof of payment method ownership.

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records;
• Payment method details (GCash mobile number, Maya account reference, bank account name and last digits);
• Transaction amounts in Philippine Peso (₱);
• Wagering history and game activity records.

2.4 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features used;
• Login timestamps and access logs.

2.5 Communications Data

• Records of communications with phpspin customer support;
• Feedback, survey responses, and promotional opt-in preferences.

Data Category	Examples	Required?
Identity & Contact	Name, email, mobile, address	Yes — for registration
KYC / Verification	Government ID, selfie	Yes — for withdrawals
Financial	GCash number, transaction history	Yes — for payments
Technical	IP address, device info	Automatic — for security
Communications	Support chat logs	When you contact us

3. How We Collect Your Data

phpspin collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, log files, and similar tracking technologies (see Section 7);
• Third-party sources: Identity verification data from KYC service providers; payment confirmation data from GCash, Maya, and banking partners; fraud prevention data from security service providers.

4. How We Use Your Personal Data

phpspin uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your phpspin player account;
• Identity verification: To verify your age (21+), identity, and eligibility to use the Platform in compliance with Philippine gaming regulations;
• Payment processing: To process deposits and withdrawals via GCash, Maya, and bank transfer;
• Game provision: To deliver and personalise your gaming experience on the phpspin Platform;
• Customer support: To respond to your inquiries, complaints, and support requests;
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct;
• Legal compliance: To comply with our obligations under Philippine law, including PAGCOR regulations, the Data Privacy Act of 2012, and Anti-Money Laundering Act (AMLA) requirements;
• Responsible gaming: To monitor gaming behaviour and provide responsible gaming interventions where appropriate;
• Marketing communications: To send you promotional offers and updates, where you have opted in to receive such communications. You may opt out at any time.

5. Legal Basis for Processing

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

• Contractual necessity: Processing is necessary to perform our contract with you — i.e., to provide the phpspin gaming services you have registered for;
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AMLA obligations, and NPC directives;
• Legitimate interests: Processing is necessary for phpspin's legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

phpspin does not sell or rent your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the phpspin Platform, including KYC and identity verification providers, payment processors (GCash, Maya, and banking partners), IT infrastructure and hosting providers, and customer support platform providers. All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

phpspin may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities where required by law, court order, or regulatory directive. We will notify you of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of phpspin's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

6.4 Cross-Border Transfers

Where personal data is transferred outside the Philippines, phpspin ensures that appropriate safeguards are in place in accordance with the Data Privacy Act of 2012 and NPC guidelines, including contractual clauses that provide equivalent data protection standards.

7. Cookies and Tracking Technologies

phpspin uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse Platform usage.

7.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login status to provide a more personalised experience.
• Analytics cookies: Help us understand how players use the phpspin Platform so we can improve performance and content. Data collected is aggregated and anonymised.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your explicit consent.

7.2 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phpspin Platform. For strictly necessary cookies, no opt-out is available as they are essential to service delivery.

8. Data Retention

phpspin retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law. Specifically:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• KYC documents: Retained for five (5) years following account closure or the completion of the relevant transaction;
• Support communications: Retained for two (2) years from the date of the last communication;
• Technical and usage data: Retained for up to twelve (12) months for security and analytics purposes.

Upon expiry of the applicable retention period, phpspin will securely delete or anonymise your personal data in accordance with our data disposal procedures.

9. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phpspin Platform;
• Encrypted storage of sensitive personal and financial data at rest;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to systems holding personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

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

10. Your Data Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by phpspin:

11. Children's Privacy and the 21+ Requirement

The phpspin Platform is strictly intended for adults aged twenty-one (21) years and above, in accordance with Philippine gaming regulations. phpspin does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the phpspin Platform, please contact us immediately at [email protected] so that we can take appropriate action.

12. Changes to This Privacy Policy

phpspin reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email and post a prominent notice on the phpspin Platform, along with the updated effective date at the top of this page.

Your continued use of the phpspin Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how phpspin protects your personal data.

13. Contact Our Data Protection Officer

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

• Email: [email protected]
• General Support: [email protected]
• Response Time: Within fifteen (15) business days for data rights requests; within two (2) business days for general privacy inquiries.

For complaints that cannot be resolved directly with phpspin, you may contact the National Privacy Commission of the Philippines at [email protected] or visit their official website for guidance on filing a formal complaint.