phluv Privacy Policy

1 Introduction

phluv operates an online gaming platform accessible at phluv.cam (the "Platform"). phluv is committed to protecting the privacy and personal information of its users in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (the "DPA"), and its Implementing Rules and Regulations.

This Privacy Policy applies to all personal information collected by phluv through the Platform, including information provided during account registration, gameplay, payment transactions, customer support interactions, and marketing communications. It also applies to information collected through cookies and similar tracking technologies when you access the Platform.

Please read this Privacy Policy carefully. If you do not agree with any provision of this policy, you should not use the phluv Platform.

2 Data Controller & Privacy Officer

For the purposes of the Philippine Data Privacy Act, phluv is the data controller responsible for the personal information processed through the Platform. phluv determines the purposes and means of processing your personal data in accordance with this Privacy Policy and applicable law.

phluv has appointed a Data Privacy Officer (DPO) as required under Section 11 of the DPA. The DPO is responsible for monitoring phluv's compliance with the DPA and this Privacy Policy, handling data subject requests, and serving as the point of contact between phluv and the National Privacy Commission (NPC).

You may contact phluv's Data Privacy Officer at:

• Email: [email protected] (plain text, not a clickable link)
• Mail: Data Privacy Officer, phluv, Metro Manila, Philippines

3 Information We Collect

phluv collects the following categories of personal information:

3.1 Information You Provide Directly

• Registration Information: When you create a phluv account, we collect your full name, date of birth, email address, mobile phone number, residential address, and username.
• Identity Verification (KYC) Information: To comply with PAGCOR requirements and prevent fraud, we collect copies of government-issued identification documents (such as PhilSys ID, UMID, driver's licence, or passport), selfie photographs for biometric verification, and proof of payment method ownership.
• Payment Information: We collect payment method details including GCash account information, Maya account information, bank account numbers (for bank transfer deposits and withdrawals), and transaction history. Card numbers, where applicable, are tokenised and not stored in plain text by phluv.
• Communications: When you contact phluv customer support via live chat, email, or other channels, we collect the content of your communications, any documents you submit, and metadata such as timestamps.
• Responsible Gaming Preferences: We collect information about any deposit limits, loss limits, session time limits, or self-exclusion requests you set on your account.

3.2 Information We Collect Automatically

• Device & Technical Information: IP address, browser type and version, operating system, device type (mobile, tablet, desktop), screen resolution, language settings, and referring URL.
• Gameplay Information: Game selections, bet amounts, game outcomes, session duration, time and date of each gaming session, and gameplay patterns.
• Transaction Information: Deposit amounts, deposit methods, deposit timestamps, withdrawal requests, withdrawal amounts, and withdrawal processing times.
• Cookies & Tracking Data: Session cookies, authentication tokens, analytics data, and advertising identifiers. See Section 10 for details on cookies.

4 How We Use Your Information

phluv processes your personal information for the following purposes:

• Account Management: To create and maintain your phluv account, authenticate your identity at login, and provide customer support.
• Service Delivery: To enable you to play games on the Platform, process deposits and withdrawals, maintain your wallet balance, and deliver the phluv gaming experience.
• Regulatory Compliance: To verify your age and identity as required by PAGCOR regulations, conduct Know Your Customer (KYC) checks to prevent money laundering and fraud, maintain required records for regulatory audits, and report suspicious activity to relevant authorities.
• Payment Processing: To process deposits and withdrawals through our payment service providers (GCash, Maya, banks, etc.) and to prevent payment fraud.
• Security & Fraud Prevention: To detect and prevent unauthorised access to accounts, monitor for unusual betting patterns or collusion, identify and investigate fraud or abuse of the Platform, and protect the integrity of games.
• Responsible Gaming: To enforce age restrictions (21+ only), apply deposit limits, loss limits, and other responsible gaming controls you set, process self-exclusion requests, and identify potentially problematic gambling behaviour.
• Communications: To send account-related notifications (deposits, withdrawals, password changes), respond to your customer support inquiries, send promotional offers and bonuses (where you have consented), and notify you of changes to our Terms or this Privacy Policy.
• Analytics & Improvement: To analyse Platform usage and performance, understand player preferences and behaviour, improve game selection offerings, and troubleshoot technical issues.
• Legal Obligations: To comply with applicable Philippine law, PAGCOR licensing conditions, court orders, and requests from law enforcement or regulatory authorities.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act, phluv processes your personal information on the following legal bases:

• Contractual Necessity: Processing required to provide the phluv service to you under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and gameplay delivery.
• Legal Obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws, the Cybercrime Prevention Act, and other applicable Philippine legislation.
• Legitimate Interest: Processing for fraud prevention, security monitoring, analytics, and Platform improvement, where phluv's legitimate interests do not override your privacy rights.
• Consent: Processing for direct marketing communications, personalised promotions, and non-essential cookies, where you have provided explicit consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Information

phluv does not sell your personal information. We share your personal information only in the following circumstances:

• Payment Service Providers: We share relevant transaction and identity information with payment processors such as GCash, Maya / PayMaya, GrabPay, BPI, BDO, and Metrobank solely to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable data protection obligations.
• Identity Verification Providers: We share KYC documentation with accredited identity verification service providers to authenticate your identity as required under PAGCOR regulations and Philippine anti-money laundering law.
• Game Content Providers: We share limited gameplay data (session IDs, bet amounts, game outcomes) with our licensed game suppliers — including live dealer studio operators and RNG game developers — to the extent necessary to deliver game services and resolve game disputes.
• Regulatory Authorities: We are required to share information with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies upon lawful request or as required by our operating licence conditions.
• IT & Security Service Providers: We share limited data with cloud infrastructure providers, cybersecurity vendors, and platform monitoring tools that support the operation and security of the phluv Platform. All such providers are contractually bound to process data only on phluv's instructions and to maintain appropriate security standards.
• Professional Advisers: We may share information with legal counsel, auditors, and compliance advisers where strictly necessary and subject to confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of phluv's business, your personal information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

In all cases where phluv shares personal information with third parties, we require those parties to implement appropriate technical and organisational safeguards consistent with the requirements of the Philippine Data Privacy Act.

7 Data Security

phluv implements a comprehensive set of technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration, and destruction. Our security framework includes:

• Encryption: All data transmitted between your device and the phluv Platform is encrypted using TLS 1.3. Personal data stored in phluv's systems is encrypted at rest using AES-256.
• Access Controls: Access to personal data is restricted to authorised phluv personnel on a strict need-to-know basis. All staff with access to personal data undergo background checks and regular data protection training.
• Two-Factor Authentication: phluv offers two-factor authentication (2FA) to all account holders as an additional layer of account security. We strongly encourage all players to enable 2FA.
• Penetration Testing: The phluv Platform undergoes regular independent security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: phluv maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, phluv will notify the National Privacy Commission and affected data subjects in accordance with NPC Circular No. 16-03 and applicable law.

8 Data Retention

phluv retains your personal information for as long as necessary to fulfil the purposes described in this Privacy Policy, comply with legal and regulatory obligations, and resolve disputes. The following retention periods apply:

• Account Information: Retained for the duration of your account and for a minimum of five (5) years following permanent account closure, as required by PAGCOR record-keeping obligations and the Anti-Money Laundering Act.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification, in accordance with Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer Support Communications: Retained for three (3) years from the date of the communication, or longer if the communication relates to an active dispute or investigation.
• Gameplay Logs: Retained for two (2) years from the date of each gaming session.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, whichever comes first.

Upon expiry of the applicable retention period, phluv will securely delete or anonymise your personal information in accordance with our data disposal procedures. Where anonymisation is used, the resulting data can no longer be attributed to you and may be retained for statistical and analytical purposes without restriction.

9 Your Rights Under the Philippine DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by phluv:

• Right to Be Informed: The right to be informed of how your personal information is collected and processed — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of the personal information phluv holds about you and to receive information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal information phluv holds about you.
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal information where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful. This right is subject to phluv's legal and regulatory retention obligations.
• Right to Object: The right to object to the processing of your personal information for direct marketing purposes or on grounds relating to your particular situation where processing is based on legitimate interest.
• Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe phluv has processed your personal information in breach of the Data Privacy Act.

To exercise any of the above rights, please submit a written request to phluv's Data Privacy Officer at [email protected]. phluv will acknowledge your request within 72 hours and respond substantively within 30 calendar days, in accordance with NPC requirements. Identity verification may be required before phluv acts on your request.

10 Cookies & Tracking Technologies

phluv uses cookies and similar tracking technologies to operate and improve the Platform, authenticate your login session, remember your preferences, and measure Platform performance. The following categories of cookies are used on the phluv Platform:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies, security tokens, and load balancing cookies. These cookies cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: Used to remember your preferences such as language settings, game layout preferences, and responsible gaming settings you have configured on your account.
• Analytics Cookies: Used to collect aggregated, anonymised information about how players use the Platform — including pages visited, session duration, and error reports — to help phluv improve Platform performance and user experience.
• Marketing Cookies: Used to deliver relevant promotional content about phluv on our own Platform. These cookies are only set with your prior consent.

You can manage your cookie preferences through the cookie settings panel accessible from the Platform footer. Disabling non-essential cookies will not affect your ability to play games or manage your phluv account, but may affect the personalisation features available to you.

11 Third-Party Links & Services

The phluv Platform may contain references to third-party payment processors and game content providers whose services are integrated into the Platform experience. These third parties operate under their own privacy policies and data processing practices, which are independent of phluv's Privacy Policy.

phluv is not responsible for the privacy practices of third-party service providers. We recommend reviewing the privacy policies of any third-party services you interact with in connection with your phluv account, including your GCash or Maya app when initiating a deposit or withdrawal.

12 Children's Privacy

If phluv discovers or has reason to believe that an account has been registered by or on behalf of an individual under the age of 21, phluv will immediately suspend that account, delete the associated personal information, and refund any net real-money balance to the registered payment method. If you believe a minor has registered a phluv account, please notify us immediately at [email protected].

13 Changes to This Privacy Policy

phluv reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Any material changes to this Privacy Policy will be communicated to registered players via email at least 14 days before the revised policy takes effect, and the updated policy will be published on this page with a revised effective date.

Your continued use of the phluv Platform after the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes and your continued consent to the processing of your personal information as described therein. If you do not agree with the revised Privacy Policy, you must cease using the Platform and may request account closure by contacting phluv support.

Previous versions of this Privacy Policy are archived and available upon written request to phluv's Data Privacy Officer.

14 Contact & Complaints

If you have questions about this Privacy Policy, wish to exercise your data subject rights, or have a complaint about phluv's handling of your personal information, please contact phluv's Data Privacy Officer using the details below:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 on the phluv Platform — average response under 90 seconds
• Mail: Data Privacy Officer, phluv, Metro Manila, Philippines

If you are not satisfied with phluv's response to your privacy complaint, you have the right to escalate your complaint to the Philippine National Privacy Commission (NPC). For more information about filing a complaint with the NPC, please refer to the NPC's published complaint procedures.

For questions about your account, deposits, withdrawals, or game disputes, please visit our FAQ page or contact phluv support via live chat.

This Privacy Policy was last reviewed and updated on 1 January 2026. phluv is operated under PAGCOR regulation and is registered with the Philippine National Privacy Commission in accordance with the Data Privacy Act of 2012.