1. Introduction and Scope
This Privacy Policy applies to all personal information collected by funph through our website, mobile applications, customer support channels, and any other services we provide to players in the Philippines. funph is committed to protecting your personal information and complying with the Data Privacy Act of 2012 (Republic Act No. 10173) and all applicable Philippine data protection regulations. We implement industry-standard security measures to safeguard your data against unauthorized access, disclosure, alteration, or destruction.
This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of funph services. By creating an account, depositing funds, or using any funph service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.
2. Information We Collect
2.1 Information You Provide Directly
When you register an account with funph, we collect personal information that you voluntarily provide, including:
- Identity Information: Full legal name, date of birth, gender, and nationality as shown on government-issued identification documents.
- Contact Information: Email address, mobile phone number, and residential address including street, barangay, city/municipality, province, and postal code.
- Account Credentials: Username, password (stored in encrypted form), and security questions you select for account recovery.
- Verification Documents: Copies of government-issued IDs (Philippine passport, driver's license, UMID, SSS ID, postal ID, etc.), proof of address documents (utility bills, bank statements, government correspondence), and photographs for identity verification purposes.
- Payment Information: GCash mobile number, PayMaya account details, bank account numbers, and transaction records for deposits and withdrawals. Note that we do not store full credit card numbers or CVV codes; these are processed directly by our payment service providers.
- Communication Records: Chat transcripts with customer support, emails you send us, feedback forms, survey responses, and any other communications you have with funph.
2.2 Information We Collect Automatically
When you access funph services, we automatically collect technical and behavioral information, including:
- Device Information: Device type (mobile phone, tablet, desktop computer), operating system (Android, iOS, Windows, macOS), browser type and version, screen resolution, and device identifiers.
- Usage Information: Pages viewed, games played, bet amounts, win/loss records, session duration, clickstream data, and navigation patterns within the funph platform.
- Location Information: IP address, which we use to verify that you are physically located in the Philippines when accessing our services, as required by gaming regulations. We do not collect precise GPS coordinates unless you explicitly grant location permissions on mobile devices.
- Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to recognize your device, remember your preferences, maintain session state, analyze site usage patterns, and deliver personalized content. See Section 8 for detailed information about our cookie practices.
2.3 Information from Third Parties
We may receive information about you from third-party sources, including:
- Payment Providers: GCash, PayMaya, banks, and other payment processors provide us with transaction confirmation data, payment method validation information, and fraud detection signals.
- Identity Verification Services: Third-party identity verification providers conduct background checks, validate government-issued IDs, and perform anti-money laundering screening on our behalf.
- Marketing Partners: Affiliates and advertising partners may provide information about how you discovered funph, including referral codes, campaign identifiers, and marketing attribution data.
- Public Sources: We may collect publicly available information from social media profiles, business registries, and other public databases to verify identity or investigate suspicious activity.
3. How We Use Your Information
funph uses the personal information we collect for the following purposes:
3.1 Account Management and Service Delivery
- Creating and managing your funph account, including username, password, and profile settings.
- Processing deposits, withdrawals, and other financial transactions.
- Maintaining your account balance, transaction history, and gaming records.
- Providing customer support, responding to inquiries, and resolving disputes.
- Sending service-related communications such as account verification emails, password reset instructions, and transaction confirmations.
3.2 Regulatory Compliance and Security
- Verifying your identity and age to comply with the minimum 21+ age requirement under Philippine law.
- Confirming that you are physically located in the Philippines when accessing gaming services.
- Conducting anti-money laundering (AML) screening and Know Your Customer (KYC) verification as required by PAGCOR regulations.
- Detecting, preventing, and investigating fraud, cheating, bonus abuse, and other prohibited conduct.
- Monitoring for suspicious betting patterns, collusion, or account takeover attempts.
- Complying with legal obligations, responding to government inquiries, and cooperating with law enforcement investigations.
- Maintaining records required by gaming regulations, tax authorities, and financial crime prevention laws.
3.3 Responsible Gaming
- Implementing responsible gaming tools such as deposit limits, loss limits, and self-exclusion features.
- Monitoring player behavior for signs of problem gambling and proactively intervening when necessary.
- Providing access to responsible gaming resources, support organizations, and self-assessment tools.
- Honoring self-exclusion requests and preventing excluded players from creating new accounts.
3.4 Marketing and Personalization
- Sending promotional offers, bonuses, and game recommendations via email, SMS, or push notifications (only with your consent, which you may withdraw at any time).
- Personalizing your gaming experience by suggesting games based on your preferences and play history.
- Conducting market research, surveys, and focus groups to improve our services.
- Analyzing usage patterns to optimize platform performance, identify popular games, and develop new features.
3.5 Business Operations
- Performing internal analytics, auditing, and reporting.
- Testing new features, conducting A/B tests, and improving user experience.
- Training customer support staff and quality assurance teams.
- Protecting our intellectual property rights and enforcing our Terms & Conditions.
- Managing business transactions such as mergers, acquisitions, or asset sales (your data may be transferred to the acquiring entity).
4. Legal Basis for Processing (Data Privacy Act Compliance)
Under the Data Privacy Act of 2012, funph processes your personal information based on the following legal grounds:
- Consent: You have explicitly consented to the processing of your personal information for specific purposes, such as receiving marketing communications.
- Contract Performance: Processing is necessary to fulfill our contractual obligations under the Terms & Conditions, including providing gaming services, processing transactions, and maintaining your account.
- Legal Obligation: Processing is required to comply with Philippine laws and regulations, including PAGCOR gaming regulations, AML/KYC requirements, tax reporting obligations, and data retention laws.
- Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform optimization, and customer support, provided these interests do not override your fundamental rights and freedoms.
5. How We Share Your Information
funph does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for the purposes described in this Privacy Policy:
5.1 Service Providers and Business Partners
- Payment Processors: GCash, PayMaya, banks, and other financial institutions that process deposits and withdrawals on our behalf.
- Game Providers: Third-party software developers whose games are featured on funph (e.g., Pragmatic Play, Microgaming, JILI Games) receive anonymized gameplay data to operate their games and calculate payouts.
- Identity Verification Services: Third-party providers that conduct KYC checks, verify identity documents, and perform background screening.
- Cloud Hosting Providers: Companies that host our servers, databases, and application infrastructure (all data is stored in encrypted form).
- Customer Support Platforms: Live chat software, ticketing systems, and customer relationship management (CRM) tools used by our support team.
- Marketing and Analytics Partners: Email marketing platforms, SMS providers, advertising networks, and analytics tools that help us communicate with you and analyze platform performance (we share only the minimum data necessary for these services).
5.2 Regulatory Authorities and Legal Compliance
- PAGCOR: We report to the Philippine Amusement and Gaming Corporation as required by gaming regulations, including suspicious transaction reports and compliance audits.
- Law Enforcement: We cooperate with police, prosecutors, and other government agencies investigating fraud, money laundering, cybercrime, or other illegal activity.
- Tax Authorities: We report gaming winnings and tax withholding information to the Bureau of Internal Revenue (BIR) as required by Philippine tax law.
- Courts and Legal Processes: We disclose information when required by court order, subpoena, or other legal process.
5.3 Corporate Transactions
If funph undergoes a merger, acquisition, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you of any such change and provide you with choices regarding your information.
6. Data Retention
funph retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law. Specific retention periods include:
- Account Information: Retained for the duration of your active account plus five (5) years after account closure to comply with PAGCOR record-keeping requirements.
- Transaction Records: Retained for seven (7) years after the transaction date to comply with tax, anti-money laundering, and financial regulations.
- Identity Verification Documents: Retained for five (5) years after account closure or last verification, whichever is later.
- Communication Records: Customer support chat logs and emails retained for three (3) years for quality assurance and dispute resolution purposes.
- Marketing Consent Records: Retained until you withdraw consent, plus three (3) years to prove compliance with marketing regulations.
After the applicable retention period expires, we securely delete or anonymize your personal information so that it can no longer identify you.
7. Data Security
funph implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:
- Encryption: All data transmitted between your device and our servers is encrypted using SSL/TLS protocols. Sensitive data such as passwords and financial information is encrypted at rest using industry-standard algorithms.
- Access Controls: Only authorized personnel have access to personal information, and access is granted based on the principle of least privilege. All access is logged and monitored.
- Multi-Factor Authentication: Our internal systems require multi-factor authentication for administrative access.
- Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing to identify and remediate security weaknesses.
- Employee Training: All employees undergo data protection and security training and are bound by confidentiality agreements.
- Incident Response: We maintain an incident response plan to quickly detect, contain, and remediate security breaches.
Despite these measures, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You acknowledge that you provide information at your own risk.
8. Cookies and Tracking Technologies
funph uses cookies and similar tracking technologies to enhance your experience, analyze platform performance, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize your browser and remember certain information.
8.1 Types of Cookies We Use
- Essential Cookies: Required for basic site functionality, such as maintaining your login session, remembering your language preference, and enabling secure transactions. These cookies cannot be disabled.
- Performance Cookies: Collect anonymous data about how you use funph, including pages visited, time spent on site, and error messages encountered. We use this information to improve platform performance.
- Functionality Cookies: Remember your preferences and settings, such as preferred game filters, sound settings, and display options.
- Marketing Cookies: Track your activity across websites to deliver targeted advertising and measure campaign effectiveness. These cookies are only used with your consent.
8.2 Managing Cookies
Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. Note that disabling essential cookies may prevent you from using certain features of funph. To manage cookie preferences, access your browser settings or click the cookie preferences link in the footer of our website.
9. Your Rights Under the Data Privacy Act
As a Philippine data subject, you have the following rights regarding your personal information:
- Right to be Informed: You have the right to know what personal information we collect, how we use it, and who we share it with (this Privacy Policy fulfills this obligation).
- Right to Access: You have the right to request a copy of the personal information we hold about you.
- Right to Rectification: You have the right to correct inaccurate or incomplete personal information.
- Right to Erasure: You have the right to request deletion of your personal information, subject to legal retention requirements.
- Right to Object: You have the right to object to processing of your personal information for direct marketing purposes.
- Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, machine-readable format and transmit it to another service provider.
- Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.
To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond to your request within fifteen (15) calendar days, as required by the Data Privacy Act.
10. Children's Privacy
funph services are not intended for individuals under the age of 21. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected information from a person under 21, we will immediately delete that information and close the associated account. If you believe a minor has provided personal information to funph, contact us immediately at [email protected].
11. International Data Transfers
Your personal information is primarily stored on servers located in the Philippines. However, some of our service providers (such as cloud hosting platforms and analytics tools) may process data on servers located outside the Philippines. When we transfer data internationally, we ensure that adequate safeguards are in place, such as standard contractual clauses, adequacy decisions, or Privacy Shield certification (where applicable). By using funph services, you consent to the international transfer of your personal information as described in this Privacy Policy.
12. Changes to This Privacy Policy
funph reserves the right to modify this Privacy Policy at any time. We will notify you of material changes by posting the updated Privacy Policy on our website with a new effective date and sending notice to your registered email address. Your continued use of funph services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes. If you do not agree to the revised Privacy Policy, you must stop using funph services and close your account. We recommend reviewing this Privacy Policy periodically to stay informed about how we protect your information.
13. Contact Information and Data Protection Officer
If you have questions, concerns, or complaints regarding this Privacy Policy or our data protection practices, please contact us:
Data Protection Officer
Email: [email protected]
Customer Support: Available 24/7 via live chat on the funph website
You may also file a complaint with the National Privacy Commission:
National Privacy Commission (Philippines)
5th Floor, Philippine International Convention Center
Vicente Sotto Street, Pasay City, Metro Manila
Website: privacy.gov.ph