phlari Privacy
Policy
At phlari, your privacy is not an afterthought — it is a core commitment. This Privacy Policy explains exactly what personal data we collect from Filipino players, why we collect it, how we use it, who we share it with, and what rights you have over your own information under Philippine law.
Our Privacy Commitments
Six principles that guide how phlari handles every piece of personal data entrusted to us by Filipino players.
Data Minimisation
phlari only collects the personal data that is strictly necessary for account operation, identity verification, and regulatory compliance. We do not harvest data for its own sake, and we do not request information beyond what each specific purpose requires.
No Data Selling
phlari does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. Your information is used exclusively to operate your phlari account, satisfy legal obligations, and improve the platform experience.
Encryption at Every Layer
All data transmitted between your device and the phlari platform is protected by 256-bit SSL/TLS encryption. Sensitive fields — including passwords, payment details, and identity documents — are encrypted at rest using industry-standard methods.
Your Rights, Respected
As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the right to access, correct, object to processing, and request deletion of your personal data held by phlari. We honour all valid requests without unnecessary delay.
Transparent Processing
phlari maintains clear records of every category of personal data we process, the legal basis for each processing activity, and the retention period applied. This policy is the public-facing summary of those records, written in plain language you can actually follow.
NPC-Registered Processing
phlari's personal data processing activities are registered with the Philippines National Privacy Commission (NPC) as required under RA 10173 for personal information controllers of our scale. We comply fully with NPC advisories and circulars as they are issued.
Important Notice. This Privacy Policy applies to all personal data processed by phlari in connection with your use of the phlari platform, including the website, account dashboard, live chat support, and all games and services offered. Please read this policy carefully. By using phlari, you acknowledge that you have read and understood how we handle your personal data.
1. Who We Are
phlari ("the Platform," "we," "us," "our") is a Philippines-focused online gaming platform operating at phlari.cam. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "the DPA") and its Implementing Rules and Regulations (IRR), phlari acts as the Personal Information Controller with respect to the personal data of registered players, site visitors, and support contacts.
phlari operates in compliance with the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR) and processes personal data as required to fulfil its obligations under applicable Philippine gaming and financial regulations. All references to "you," "your," or "player" in this policy refer to any natural person who accesses or uses the phlari platform.
2. Personal Data We Collect
phlari collects the following categories of personal data from players and prospective players. We collect only what is necessary for the stated purposes and do not retain data beyond the applicable retention period.
Identity & Contact Data
Account & Financial Data
Usage & Technical Data
Sensitive Personal Information: Government-issued ID documents submitted for KYC verification constitute sensitive personal information under the DPA. phlari processes these documents solely for age and identity verification purposes and stores them in an encrypted, access-restricted environment. They are not shared with third parties except where required by PAGCOR or applicable AML regulations.
3. How We Collect Your Data
phlari collects personal data through the following channels:
- Account Registration: When you create a phlari account, you directly provide your name, date of birth, email address, mobile number, and residential address.
- KYC Verification: When you submit identity documents or selfie photos to verify your age and identity prior to withdrawal processing.
- Deposits & Withdrawals: When you initiate a financial transaction, phlari receives payment reference data from GCash, PayMaya, or your bank that is necessary to process and record the transaction.
- Platform Interaction: As you navigate and use the phlari website and games, our systems automatically collect technical data including your IP address, device information, browser type, session duration, and game activity logs.
- Customer Support: When you contact the phlari support team via live chat or email, the content of your communications is collected and stored to facilitate resolution of your inquiry and to maintain a service record.
- Cookies and Tracking Technologies: phlari uses cookies and similar technologies on its website. See Section 8 of this policy for a full description of how phlari uses cookies.
4. How We Use Your Personal Data
phlari uses personal data for the following purposes:
- Account Creation and Management: To register your account, authenticate your identity on login, maintain your account settings, and manage your player wallet.
- Age and Identity Verification (KYC): To confirm that you are at least 21 years of age and that the identity provided at registration is genuine, as required by PAGCOR regulations.
- Payment Processing: To process deposits to and withdrawals from your phlari wallet via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
- Regulatory Compliance and Anti-Money Laundering (AML): To monitor transactions and account activity for indicators of money laundering, fraud, or other financial crime as required under Philippine AML regulations and PAGCOR licensing conditions.
- Customer Support: To respond to your support inquiries, investigate complaints, and maintain a service interaction history for quality and training purposes.
- Platform Security: To detect, investigate, and prevent unauthorized account access, fraud, cheating, and other activities that breach phlari's Terms and Conditions.
- Responsible Gaming: To monitor gaming patterns and implement responsible gaming tools — including deposit limits, session reminders, and self-exclusion — in accordance with phlari's responsible gaming obligations.
- Service Improvement: To analyze aggregated, anonymized usage data for the purpose of improving platform performance, game offerings, and the overall phlari user experience.
- Communications: To send you transactional notifications (deposits, withdrawals, account changes) and, where you have opted in, promotional communications about phlari bonuses and new features. You may opt out of promotional communications at any time.
5. Legal Bases for Processing
Under the Philippine Data Privacy Act and its IRR, phlari processes your personal data on the following legal grounds:
- Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to operate your phlari account, process transactions, and deliver the gaming services you have registered to use.
- Legal Obligation: Processing is necessary to comply with applicable Philippine laws, including PAGCOR licensing requirements, AML regulations under Republic Act No. 9160 as amended, and the DPA itself.
- Legitimate Interests: Processing is necessary for the legitimate interests of phlari, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights and interests.
- Consent: Where phlari relies on your consent as the legal basis for processing — for example, for optional promotional communications — you may withdraw that consent at any time by contacting phlari support. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.
6. Sharing Your Personal Data
phlari does not sell your personal data. We share your data only in the following limited circumstances, and only to the extent necessary for each stated purpose:
- Payment Service Providers: Transaction reference data is shared with GCash, PayMaya, BPI, BDO, and Metrobank as required to process deposits and withdrawals. These providers process data under their own privacy policies and are bound by Philippine financial data protection standards.
- Identity Verification Services: KYC document data may be processed by phlari's contracted identity verification service provider for the sole purpose of confirming your age and identity. The provider is bound by confidentiality and data processing agreements.
- Regulatory Authorities: phlari is legally required to disclose player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities upon lawful request or as required by applicable regulations.
- Game Content Providers: Aggregated, anonymized gaming activity data may be shared with game suppliers for the purpose of optimizing game performance. No personally identifiable information is shared with game content providers.
- IT and Infrastructure Providers: phlari works with technology vendors — including cloud hosting and cybersecurity providers — who may process personal data on our behalf as data processors under binding data processing agreements that require GDPR-equivalent protections.
No Cross-Border Transfers Without Safeguards. Where personal data is processed by a service provider located outside the Philippines, phlari ensures that appropriate contractual safeguards are in place — including NPC-prescribed standard contractual clauses — before any transfer occurs. phlari does not transfer data to jurisdictions that do not provide an adequate level of data protection.
7. Data Retention
phlari retains personal data for only as long as is necessary for the purpose for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account & identity data | Duration of account + 5 years after closure | PAGCOR licensing & AML obligation |
| KYC documents (ID scans) | Duration of account + 5 years after closure | AML & PAGCOR regulatory requirement |
| Transaction records | 10 years from date of transaction | RA 9160 (AMLA) requirement |
| Game activity logs | 2 years from date of activity | Dispute resolution & PAGCOR audit |
| Customer support records | 3 years from date of interaction | Legitimate interest (dispute resolution) |
| Marketing preferences | Until consent is withdrawn | Consent-based processing |
| Technical / session logs | 12 months from date of generation | Security & fraud prevention |
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification.
8. Cookies & Tracking Technologies
phlari uses cookies — small text files stored on your device — and similar tracking technologies to operate and improve the platform. The cookies phlari uses fall into the following categories:
- Strictly Necessary Cookies: Required for the platform to function. These include session cookies that maintain your phlari login state and security cookies that protect against cross-site request forgery. You cannot opt out of these cookies without ceasing to use the platform.
- Functional Cookies: Remember your preferences such as language settings, game display preferences, and responsible gaming tool configurations. Disabling these cookies may degrade your experience on phlari.
- Analytics Cookies: Collect aggregated, anonymized data about how players use the phlari platform — such as which pages are visited most frequently and where technical errors occur. This data is used exclusively to improve platform performance and is never used to identify individual players.
- Security & Fraud-Prevention Cookies: Identify unusual patterns in session behavior that may indicate fraudulent activity, such as bot access, credential stuffing, or account takeover attempts.
You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Note that blocking strictly necessary cookies will prevent access to certain phlari platform functions. phlari does not use third-party advertising or behavioral tracking cookies.
9. Security Measures
phlari implements a layered technical and organizational security framework to protect your personal data against unauthorized access, accidental loss, destruction, or alteration. Key security measures in place include:
- 256-bit SSL/TLS encryption for all data in transit between your device and phlari's servers.
- AES-256 encryption for sensitive personal data stored in phlari's databases, including passwords, ID document files, and payment reference details.
- Multi-factor authentication options for player accounts, including SMS-based one-time password (OTP) verification.
- Role-based access controls ensuring that phlari employees can only access the personal data necessary for their specific job function.
- Regular penetration testing and vulnerability assessments conducted by independent cybersecurity firms.
- Security incident response procedures aligned with the NPC's mandatory data breach notification requirements under NPC Circular 16-03.
Data Breach Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phlari will notify the NPC within 72 hours of becoming aware of the breach and will notify affected players without undue delay in accordance with applicable NPC breach notification requirements.
10. Your Privacy Rights
Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phlari. phlari will respond to all valid rights requests within thirty (30) calendar days.
| Right | What It Means for Your phlari Data |
|---|---|
| Right to Access | Request a copy of the personal data phlari holds about you, including the categories of data, the purposes of processing, and the recipients with whom it has been shared. |
| Right to Correction | Request that inaccurate or incomplete personal data in your phlari account be corrected or updated. Many fields can be updated directly in your account dashboard. |
| Right to Erasure | Request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to phlari's legal retention obligations under PAGCOR and AML regulations. |
| Right to Object | Object to the processing of your personal data where phlari relies on legitimate interests as the legal basis, or to opt out of direct marketing communications at any time. |
| Right to Data Portability | Receive a structured, commonly-used, machine-readable copy of personal data you have provided to phlari, where technically feasible. |
| Right to Lodge a Complaint | File a complaint with the Philippines National Privacy Commission if you believe phlari has processed your personal data in violation of the DPA. |
To exercise any of the above rights, contact the phlari Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." phlari may need to verify your identity before processing a rights request to protect against unauthorized access to another player's data.
11. Children & Minors
phlari is strictly an adults-only platform. Access is restricted to individuals who are at least 21 years of age, as required by PAGCOR regulations governing online gaming in the Philippines.
phlari does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted through our KYC process before any withdrawal is processed, and phlari reserves the right to request proof of age at any stage of the account lifecycle.
If phlari becomes aware that personal data has been collected from an individual who is under 21 years of age, the relevant account will be immediately suspended, all data will be securely deleted, and any deposits made will be refunded to the original payment source.
21+ Only. If you are a parent or guardian and believe that a minor under your care has registered a phlari account, please contact us immediately at [email protected]. We will take immediate action to close the account and delete the associated data.
12. Updates to This Privacy Policy
phlari may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The "Effective Date" at the top of this policy indicates when the current version came into force.
Where a proposed update constitutes a material change to how phlari processes your personal data — such as introducing a new purpose for processing or a new category of data sharing — phlari will notify registered players via the email address associated with their account at least fourteen (14) days before the change takes effect. For non-material updates, continued use of the phlari platform after the updated policy is posted will constitute acceptance of the revised terms.
We encourage you to review this Privacy Policy periodically to stay informed about how phlari protects your data.
13. Contact & Data Protection Officer
If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or want to raise a privacy concern about how phlari handles your personal data, please contact phlari's Data Protection Officer (DPO):
data_controller :: phlari
Email: [email protected]
Subject Line: "Privacy Policy Inquiry" or "Data Subject Rights Request"
Response Time: Within 30 calendar days of receipt of a valid request.
If you are unsatisfied with phlari's response to a privacy concern, you have the right to lodge a complaint directly with the Philippines National Privacy Commission (NPC). Information about the NPC complaints process is available on the NPC's official website.
Play on phlari — Your Data, Protected
phlari is built on transparency and trust. Your personal data is protected under Philippine law, encrypted at every layer, and never sold. Create your account and experience a gaming platform that takes your privacy as seriously as your winnings. 21+ only.
Create Your Account Read Terms & Conditions