phdarna Privacy Policy

1.Introduction

Welcome to the phdarna Privacy Policy. phdarna ("the Platform," "we," "us," or "our") is committed to protecting the personal information of every individual who uses our online gaming services at phdarna.one. This Privacy Policy ("Policy") describes the types of personal data phdarna collects, the purposes for which we process it, the parties with whom we may share it, and the rights you hold over your own information.

This Policy applies to all users of phdarna, whether you are a registered account holder, a visitor browsing our site without an account, or a former player whose account has been closed. By accessing phdarna or creating an account, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read in conjunction with phdarna's Terms & Conditions, which govern the overall relationship between you and phdarna. In the event of any inconsistency between this Policy and the Terms & Conditions on a privacy-specific matter, this Policy shall prevail.

2.Who We Are (Data Controller)

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, phdarna is the personal information controller responsible for determining the purposes and means of processing personal data collected through phdarna.one.

phdarna operates as an online gaming platform serving Filipino players under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Our operations are subject to the applicable requirements of PAGCOR and to the data protection obligations established by the National Privacy Commission (NPC) of the Philippines.

3.Personal Data We Collect

phdarna collects personal data that is necessary, relevant, and limited to the purposes for which it is processed. The following categories of personal data may be collected:

phdarna does not collect sensitive personal information (as defined by the Data Privacy Act) beyond what is strictly required for identity verification and legal compliance. We do not collect biometric data, religious affiliation, political views, or health information unless directly relevant to a responsible gaming intervention and provided voluntarily by the player.

4.How We Collect Your Data

phdarna collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or completing any form on phdarna.one.
• Automated collection: Technical and behavioural data collected automatically when you access phdarna.one, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; payment transaction data from GCash, PayMaya, and partner banks; fraud screening data from anti-fraud service providers; and, where applicable, data from PAGCOR or law enforcement agencies in connection with regulatory obligations.
• Publicly available sources: In limited circumstances, publicly available information may be used to supplement identity verification, such as confirming that a provided ID number format is valid.

5.How We Use Your Personal Data

phdarna uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your phdarna player account, including authentication, password resets, and communication of account updates.
• KYC and age verification: Fulfilling mandatory player identity and age verification obligations required by PAGCOR before permitting real-money gaming activity. Players must be 21 years or older.
• Game operation and dispute resolution: Processing bets, calculating outcomes, crediting winnings, and maintaining game records that may be used to resolve player disputes.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers, and maintaining financial records in compliance with applicable law.
• Regulatory compliance: Meeting obligations under PAGCOR regulations, the Philippine Anti-Money Laundering Act (AMLA), the Data Privacy Act, and any other applicable Philippine law or regulatory directive.
• Fraud prevention and platform security: Detecting, investigating, and preventing fraud, money laundering, identity theft, account takeover, and other illegal or dishonest activity.
• Responsible gaming: Monitoring gaming behaviour to identify potential problem gambling patterns, applying player-set limits, and intervening where required by PAGCOR responsible gaming guidelines.
• Customer support: Responding to and resolving player enquiries, complaints, and support requests submitted through live chat or email.
• Marketing and promotions: Where you have provided consent, sending you promotional communications about phdarna offers, new games, and special events. You may withdraw this consent at any time from your account settings.
• Platform improvement: Analysing aggregated, anonymised usage data to improve phdarna's user interface, game library, and overall player experience.

6.Legal Basis for Processing

phdarna processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Consent: Where you have provided explicit, informed consent to the processing of your personal data for a specific purpose (e.g., marketing communications). Consent may be withdrawn at any time without prejudice to the lawfulness of processing prior to withdrawal.
• Contractual necessity: Processing necessary for the performance of the player agreement between you and phdarna — including account operation, game delivery, and payment processing.
• Legal obligation: Processing required for phdarna to comply with its legal and regulatory obligations under Philippine law, including PAGCOR requirements, the AMLA, and directions from the National Privacy Commission.
• Legitimate interests: Processing necessary for phdarna's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided those interests are not overridden by your fundamental rights and freedoms.

7.Data Sharing & Disclosure

phdarna does not sell, rent, or otherwise trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and identity verification providers: Third-party service providers that assist in verifying the identity and age of players in compliance with PAGCOR requirements.
• Payment processors: GCash (Mynt – Globe Fintech Innovations), PayMaya (Maya Bank), and Philippine banking partners (BPI, BDO, Metrobank) as necessary to process deposits and withdrawals.
• Game software providers: Licensed third-party game studios and RNG certification bodies that supply games available on phdarna.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), and other Philippine government bodies as required by applicable law or regulatory directive.
• Law enforcement agencies: Philippine law enforcement authorities, in response to a lawful request, court order, or legal process.
• Professional advisers: Legal counsel, auditors, and accountants, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or substantially all of phdarna's assets, your data may be transferred to the successor entity, subject to equivalent data protection obligations.

8.Cookies & Tracking Technologies

phdarna uses cookies and similar tracking technologies on phdarna.one to ensure the platform functions correctly, to maintain session security, and to improve the user experience. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that maintain your logged-in state and security cookies that protect against cross-site request forgery. These cannot be disabled without impairing core platform functionality.
• Functional cookies: Remember your preferences such as language, currency display, and last-played game to improve your experience on return visits.
• Analytics cookies: Collect anonymised and aggregated data about how visitors use phdarna.one — which pages are visited most, where users drop off in the registration flow, and similar operational insights. This data is used solely to improve the platform and is not used to identify individual users.
• Security and fraud detection cookies: Track device fingerprint signals and session anomalies to detect and prevent fraudulent access and account takeover attempts.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may prevent you from logging in to phdarna or using core platform features.

9.Data Retention

phdarna retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account data and KYC documents: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR regulations and AMLA requirements.
• Financial transaction records: Retained for a minimum of five (5) years in compliance with AMLA and BIR obligations.
• Gaming records: Retained for a minimum of three (3) years for dispute resolution purposes.
• Support communications: Retained for two (2) years or until the relevant matter is fully resolved, whichever is longer.
• Technical and log data: Retained for twelve (12) months for security and fraud detection purposes.

Upon expiry of the applicable retention period, phdarna will securely delete or anonymise your personal data in a manner that prevents reconstruction or identification.

10.Data Security

phdarna implements technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phdarna.one.
• Encryption at rest for sensitive personal data including KYC documents and financial account references stored in phdarna's systems.
• Role-based access controls ensuring that phdarna staff only access personal data necessary for their specific job functions.
• Multi-factor authentication for phdarna staff accessing internal systems containing personal data.
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent security specialists.
• Incident response procedures aligned with NPC Circular 16-03 requirements for personal data breach notification.

11.Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phdarna:

• Right to be informed: The right to know what personal data phdarna collects about you, the purposes for which it is processed, and with whom it may be shared. This Policy fulfils phdarna's obligation to inform you.
• Right of access: The right to request a copy of the personal data phdarna 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 data held by phdarna. You may update most account details directly in your phdarna account settings.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose it was collected, or where you have withdrawn consent and no other legal basis applies. Note that this right is subject to phdarna's legal retention obligations under PAGCOR regulations and the AMLA.
• Right to data portability: The right to receive a structured, commonly used copy of your personal data that you have provided to phdarna, in a format that allows it to be transferred to another service provider.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time from your phdarna account settings or by contacting support.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phdarna has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact phdarna's Data Protection Officer using the contact information provided in Section 15 of this Policy. phdarna will respond to all verified data subject requests within fifteen (15) days of receipt, or within the extended period permitted by applicable law where the request is complex.

12.Children's Privacy

phdarna's services are strictly restricted to individuals aged 21 years and above, in compliance with Philippine law governing gambling activities. phdarna does not knowingly collect personal data from any person under the age of 21.

If phdarna discovers that personal data has been collected from a person under 21 years of age, phdarna will immediately close the relevant account, return any funds to the source payment method after withholding any winnings generated during the period of underage access, and delete the personal data of the underage individual from its systems as soon as practicable and to the extent not otherwise required by applicable law to retain.

If you believe a person under 21 has created a phdarna account, please notify us immediately at the contact details in Section 15.

13.Cross-Border Data Transfers

phdarna's primary data processing infrastructure is located within the Philippines. Where phdarna engages third-party service providers whose systems are located outside the Philippines — such as international game software providers or cloud infrastructure services — personal data may be transferred to and processed in jurisdictions outside the Philippines.

In such cases, phdarna takes steps to ensure that any cross-border transfer of personal data is subject to appropriate safeguards, including contractual data protection clauses consistent with NPC standards, and that the recipient jurisdiction provides an adequate level of data protection. phdarna will not authorise cross-border transfers to jurisdictions that do not provide adequate protection without implementing additional safeguards as required by the Data Privacy Act and NPC regulations.

14.Changes to This Privacy Policy

phdarna may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify you via email to your registered address or via an in-platform notification upon your next login, at least seven (7) days before the updated Policy takes effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how phdarna protects your personal information. Your continued use of phdarna following the effective date of an updated Policy constitutes acceptance of the revised terms.

15.Contact Us & Data Protection Officer

phdarna has designated a Data Protection Officer (DPO) as required by the Philippine Data Privacy Act. If you have any questions, concerns, or requests relating to this Privacy Policy or phdarna's processing of your personal data, please contact our DPO through the following channel: