funph Casino Privacy Policy

1 Introduction and Scope

funph ("funph," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the funph online gaming platform. This Privacy Policy ("Policy") describes how funph collects, uses, stores, discloses, and protects personal information in connection with your use of the funph website, mobile platform, games, and all related services (collectively, the "Platform").

This Policy applies to all registered players, visitors, and any individual whose personal data is processed by funph in connection with the Platform. It should be read together with our Terms & Conditions, which govern your use of funph as a whole.

By registering an account or using the funph 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 funph Platform.

2 Data Controller Information

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, funph acts as the Personal Information Controller in respect of the personal data collected through the Platform.

funph has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws and this Policy. If you have any questions or concerns about how funph processes your personal data, you may contact our DPO using the contact details provided in Section 15 of this Policy.

3 Personal Data We Collect

funph collects the following categories of personal data in connection with your use of the Platform:

funph does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, health information, or political opinions.

4 How We Collect Your Data

funph collects personal data through the following means:

• Direct interactions: Information you provide when registering a funph account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the funph Platform, including through cookies, web beacons, and server logs. See Section 10 for more details on cookies.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment data from GCash, PayMaya/Maya, and banking partners in connection with your transactions.
• Publicly available sources: Information from public databases used for fraud prevention and regulatory compliance purposes.

5 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the funph Terms & Conditions, including account management, game operation, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Legitimate interests: Processing necessary for funph's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Where funph relies on your consent as the legal basis for processing — for example, for optional marketing communications — you may withdraw that consent at any time by contacting our support team or updating your account preferences.

6 How We Use Your Personal Data

funph uses the personal data we collect for the following purposes:

• Account management: To register and maintain your funph account, verify your identity and age, and manage your account settings and preferences.
• Service delivery: To provide access to games, process deposits and withdrawals via GCash, PayMaya/Maya, and bank transfer, and deliver the full range of funph platform features.
• Regulatory compliance: To fulfill funph's obligations under PAGCOR regulations, the Anti-Money Laundering Act, and other applicable Philippine laws, including conducting KYC checks and filing required reports.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the funph Platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and administer responsible gaming tools such as deposit limits and session reminders.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance through funph's support channels.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the funph Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and news about funph — only where you have provided consent or where permitted by applicable law. You may opt out at any time.
• Legal proceedings: To establish, exercise, or defend legal claims involving funph, including in proceedings before Philippine courts or PAGCOR.

7 Disclosure of Your Personal Data

funph does not sell, rent, or trade your personal data. We 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 and processors: Third-party companies that provide services to funph, including KYC and identity verification providers, payment processors (GCash, PayMaya/Maya, and banking partners), IT infrastructure providers, customer support platforms, and analytics services. These parties are contractually bound to process your data only on funph's instructions and in accordance with applicable data privacy laws.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law, court order, or regulatory directive.
• Fraud prevention and compliance partners: Third-party fraud screening and AML compliance services used to protect the integrity of the funph Platform and comply with Philippine financial regulations.
• Professional advisers: Lawyers, auditors, accountants, and insurers engaged by funph in connection with the operation of its business, subject to confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of funph's business, your personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

funph will not disclose your personal data to any third party for their own independent marketing purposes without your explicit consent.

8 International Data Transfers

funph primarily stores and processes your personal data within the Republic of the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines — for example, in connection with cloud infrastructure or international KYC services — funph ensures that such transfers are conducted in accordance with the Data Privacy Act of 2012 and the implementing rules of the National Privacy Commission.

Specifically, funph implements appropriate safeguards for international transfers, which may include contractual clauses approved by the NPC, adequacy determinations, or other legally recognized transfer mechanisms. If you would like more information about the safeguards applicable to a specific transfer, please contact our Data Protection Officer using the details in Section 15.

9 Data Retention

funph retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your funph account and for a minimum of five (5) years following account closure, in accordance with PAGCOR requirements and the Anti-Money Laundering Act.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and its implementing regulations.
• KYC and verification documents: Retained for the period required by PAGCOR and AML regulations, typically five (5) years from the end of the business relationship.
• Communications and support data: Retained for up to three (3) years from the date of the communication, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and usage data: Retained for up to two (2) years from collection, unless required for longer periods for security or fraud investigation purposes.

When personal data is no longer required, funph will securely delete or anonymize it in accordance with its data disposal procedures.

10 Cookies and Tracking Technologies

The funph Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and analyze how the Platform is used. A cookie is a small text file placed on your device when you visit a website.

funph uses the following types of cookies:

• Strictly necessary cookies: Essential for the operation of the funph Platform, including maintaining your login session and enabling core platform functionality. These cookies cannot be disabled without affecting your ability to use funph.
• Functional cookies: Used to remember your preferences and settings on the funph Platform, such as your preferred language and display options.
• Analytics cookies: Used to collect aggregated, anonymized information about how players use the funph Platform, helping us identify areas for improvement. funph uses analytics data internally and does not share individual-level analytics data with third parties for their own purposes.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats on the funph Platform.

funph does not use advertising or cross-site tracking cookies. You can manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair your ability to use the funph Platform.

11 Security of Your Personal Data

funph takes the security of your personal data seriously and implements a range of technical and organizational measures to protect it against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the funph Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls ensuring that only authorized funph personnel with a legitimate need can access personal data.
• Regular security assessments, penetration testing, and vulnerability scanning of the funph Platform.
• Staff training on data privacy and security obligations.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While funph takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your funph login credentials and for notifying us immediately if you suspect unauthorized access to your account.

12 Your Rights Under the Data Privacy Act

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by funph:

• Right to be informed: The right to be informed of how your personal data is collected, used, and processed by funph — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data funph holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data funph 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 processing is unlawful — subject to funph's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on funph's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe funph has violated your data privacy rights.

To exercise any of these rights, please contact funph's Data Protection Officer using the details provided in Section 15. funph will respond to all verified requests within the timeframes prescribed by the Data Privacy Act and NPC regulations. We may need to verify your identity before processing your request.

13 Children's Privacy

The funph Platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. funph does not knowingly collect personal data from individuals under the age of 21.

If funph becomes aware that personal data has been collected from a person under 21 years of age, 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 provided personal data to funph, please contact our support team immediately so that we can take appropriate action.

14 Amendments to This Privacy Policy

funph 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, funph will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect, except where immediate changes are required by law.

Your continued use of the funph Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically. The most current version will always be available on this page, with the effective date clearly indicated at the top.

15 How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way funph processes your personal data, please contact our Data Protection Officer. Our support team and DPO are available to assist all Filipino players with data privacy matters.

You may reach funph by email at: [email protected]

Please include your registered funph username and a clear description of your request or concern so that we can assist you efficiently. funph aims to acknowledge all data privacy requests within three (3) business days and to resolve them within the timeframes prescribed by the Data Privacy Act of 2012.

If you are not satisfied with funph's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through its official channels.