Privacy Policy

1. Introduction

phenjoy.com ("the Platform," "we," "us," or "our") is committed to protecting the privacy and personal data of all users, particularly Filipino players who access our services from the Philippines. This Privacy Policy ("Policy") describes how phenjoy.com collects, processes, stores, and protects personal information in connection with your use of the Platform, including all games, account services, promotions, and customer support interactions.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It should be read together with our Terms & Conditions, which govern your use of phenjoy.com.

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

2. Personal Data We Collect

phenjoy.com collects personal data that is necessary to provide a safe, compliant, and high-quality gaming experience. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., PhilSys ID number, passport number, driver's license number).
• Contact Data: Email address, Philippine mobile number, and residential address.
• Financial Data: GCash account details, PayMaya / Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and debit card details used for deposits and withdrawals.
• Account Data: Username, encrypted password, account preferences, deposit and withdrawal history, game history, and bonus usage records.
• Technical Data: IP address, device type, operating system, browser type and version, time zone, and session duration data collected automatically when you access the Platform.
• Usage Data: Information about how you navigate and interact with phenjoy.com, including pages visited, games played, and features used.
• Communications Data: Records of your interactions with phenjoy.com customer support, including live chat transcripts and support ticket history.
• Verification Documents: Copies of government-issued IDs and supporting documents submitted during the Know Your Customer (KYC) verification process.

phenjoy.com does not 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 or religious affiliations.

3. How We Use Your Personal Data

phenjoy.com processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your phenjoy.com account, including processing deposits, withdrawals, and bonus claims.
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR regulations and anti-money laundering (AML) requirements under Philippine law.
• Service Delivery: To provide access to all games, features, and services available on phenjoy.com, and to personalise your experience on the Platform.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, and other prohibited conduct.
• Regulatory Compliance: To fulfil our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws.
• Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance.
• Communications: To send you transactional notifications such as deposit confirmations, withdrawal updates, and security alerts related to your phenjoy.com account.
• Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to administer self-exclusion, deposit limits, and other responsible gaming tools.
• Platform Improvement: To analyse usage patterns and technical performance data in order to improve the functionality, security, and user experience of phenjoy.com.

phenjoy.com will not use your personal data for purposes incompatible with those listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

4. Legal Basis for Processing

phenjoy.com processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game delivery.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA obligations, and NPC directives.
• Legitimate Interests: Processing is necessary for the legitimate interests of phenjoy.com, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: Where processing is not covered by the above bases, phenjoy.com will seek your explicit consent before processing your personal data. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

phenjoy.com does not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary and permitted by law:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government agencies, where disclosure is required by law or regulatory directive.
• Payment Service Providers: GCash, PayMaya / Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals. These providers are bound by their own privacy and data security obligations.
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to assist with identity verification and fraud screening. All such providers are contractually bound to process data only on phenjoy.com's instructions and in accordance with applicable data protection law.
• Game Software Providers: Licensed game developers and platform providers whose software powers the games available on phenjoy.com. These providers may receive limited technical data necessary to deliver game services.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and technical infrastructure providers engaged to operate and secure the Platform. All such providers are subject to strict data processing agreements.
• Legal and Professional Advisers: Lawyers, auditors, and other professional advisers engaged by phenjoy.com, subject to professional confidentiality obligations.

Any third party with whom phenjoy.com shares personal data is required to implement appropriate technical and organisational security measures and to process data only for the specified purpose. phenjoy.com remains responsible for ensuring that such sharing complies with the Data Privacy Act of 2012.

6. Cookies & Tracking Technologies

phenjoy.com uses cookies and similar technologies to operate the Platform effectively and to provide a secure, personalised experience. The types of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in to your phenjoy.com account and security tokens that protect against cross-site request forgery (CSRF). These cookies cannot be disabled.
• Performance Cookies: Used to collect anonymised data about how players interact with phenjoy.com, such as pages visited and error messages encountered. This data helps us identify and fix technical issues and improve Platform performance.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, so that you do not need to re-enter them on each visit.

phenjoy.com does not use advertising cookies, cross-site tracking pixels, or any third-party behavioural profiling technologies. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair your ability to use the Platform.

7. Data Security

phenjoy.com 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:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent required for their specific function.
• Regular security audits, vulnerability assessments, and penetration testing conducted by qualified cybersecurity professionals.
• Multi-factor authentication (MFA) options available to players to protect account access.
• Incident response procedures to detect, contain, and notify affected individuals and the NPC of any personal data breach within the timeframes required by law.

While phenjoy.com takes all reasonable steps to protect your personal data, no system is entirely immune to security risks. You are responsible for maintaining the confidentiality of your account credentials and for notifying phenjoy.com immediately if you suspect any unauthorised access to your account.

8. Data Retention

phenjoy.com retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with phenjoy.com, and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act and PAGCOR regulations.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory directive or legal hold.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and Usage Data: Retained for up to twelve (12) months from collection, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents reconstruction of the original data.

9. Your Data Privacy Rights

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

• Right to be Informed: The right to be notified of how your personal data is collected, processed, and used, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data phenjoy.com 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 held by phenjoy.com.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data on grounds relating to your particular situation, where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data 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 National Privacy Commission (NPC) if you believe that phenjoy.com has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact phenjoy.com customer support. We will respond to all verified requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. We may request proof of identity before processing your request to protect against unauthorised access to your data.

10. Children's Privacy & Age Restriction

phenjoy.com is strictly an adult platform. In accordance with Philippine law and PAGCOR regulations, access to and use of phenjoy.com is permitted only to individuals who are 21 years of age or older. phenjoy.com does not knowingly collect personal data from individuals under the age of 21.

If phenjoy.com becomes aware that personal data has been collected from a person under the age of 21, the relevant account will be immediately suspended, all associated data will be deleted, and any funds held in the account will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that a minor has registered on phenjoy.com, please contact our customer support team immediately so that we can take appropriate action.

11. Third-Party Links

phenjoy.com may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to phenjoy.com and does not extend to any third-party websites or platforms. phenjoy.com is not responsible for the privacy practices, content, or data handling of any third-party site. We encourage you to review the privacy policies of any third-party sites you visit.

12. Changes to This Privacy Policy

phenjoy.com 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. The date of the most recent revision is indicated at the top of this page.

Where changes are material, phenjoy.com will notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of phenjoy.com following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to the amended Policy, you must cease using the Platform and may request account closure.

13. Contact & Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phenjoy.com, please contact our Data Privacy Officer through the following channel:

phenjoy.com Data Privacy Officer
Email: privacy phenjoycom.org
Customer Support: Available 24/7 via live chat on the Platform

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. Information on how to file a complaint is available on the NPC's official website.