1. Introduction
phearn ("we", "us", "our") is committed to protecting the privacy and personal data of all individuals who use or interact with the phearn platform at phearn.org ("Platform"). This Privacy Policy explains what personal data phearn collects, how it is used, with whom it may be shared, how long it is retained, and what rights you have as a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.
By accessing the phearn Platform, creating an account, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree, please discontinue use of the Platform immediately.
This policy should be read together with the phearn Terms & Conditions and our Responsible Gaming Policy.
2. Data Controller
phearn, the operator of phearn.org, acts as the Personal Information Controller (PIC) with respect to the personal data collected through the Platform, as that term is defined under the Philippine Data Privacy Act of 2012.
Questions or requests relating to this Privacy Policy or your personal data may be directed to the phearn Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.
3. Personal Data We Collect
Depending on how you interact with the phearn Platform, we may collect the following categories of personal data:
- Identity Data: Full legal name, date of birth, nationality, government-issued ID type and number (e.g., Philippine passport, driver's licence, SSS, UMID, PhilSys National ID), and any other information you provide for KYC/AML compliance purposes.
- Contact Data: Philippine mobile number, email address (if provided), and mailing address.
- Account Data: Username, account registration date, account status, login history, and phearn Login activity logs.
- Financial Data: Deposit and withdrawal transaction records, payment method identifiers (e.g., GCash-linked mobile number, bank account last four digits), transaction amounts, and timestamps. phearn does not store full payment card numbers.
- Gaming Data: Gameplay history, game session data, bet amounts, win/loss records, and bonus usage records.
- Technical Data: IP address, device type and identifier, browser type and version, operating system, session duration, page interaction data, and referral source.
- Communications Data: Records of your interactions with phearn customer support, including live chat transcripts and any correspondence submitted to us.
- Preference Data: Responsible gaming settings you configure within your phearn account, including deposit limits and self-exclusion preferences.
4. How We Collect Your Data
phearn collects personal data through the following means:
- Directly from you — when you register an account on phearn, complete KYC verification, make a deposit or withdrawal, contact our support team, or configure your account settings.
- Automatically — through cookies, server logs, and similar tracking technologies when you browse the phearn Platform, as described in Section 10.
- From third-party service providers — including payment processors (e.g., GCash, Maya, BDO, BPI, UnionBank), identity verification providers, fraud prevention services, and game software providers, to the extent necessary for platform operation and regulatory compliance.
- From public sources — where required for compliance purposes, phearn may verify information against publicly available records or databases.
5. Purposes of Processing
phearn processes your personal data for the following purposes:
- To create, maintain, and manage your phearn account and enable phearn Login access.
- To verify your identity and age (21+ requirement) in compliance with PAGCOR-aligned gaming regulations and anti-money laundering (AML) obligations.
- To process financial transactions, including deposits, withdrawals, and bonus crediting.
- To provide customer support and respond to inquiries, complaints, and disputes.
- To deliver personalised platform experiences, including relevant game recommendations and promotional offers where you have consented to receive these.
- To detect, prevent, and investigate fraud, abuse, money laundering, and other prohibited conduct.
- To operate, maintain, and improve the security and functionality of the phearn Platform.
- To comply with applicable Philippine law, including the Data Privacy Act, Anti-Money Laundering Act (AMLA), and gaming regulatory requirements.
- To support responsible gaming initiatives, including monitoring for potential problem gambling indicators and enforcing player-set limits.
6. Legal Basis for Processing
phearn processes your personal data on the following legal grounds under the Philippine Data Privacy Act:
- Consent: Where you have provided explicit, informed consent — for example, for receiving marketing communications or for optional profiling features.
- Contractual necessity: Where processing is necessary to perform our obligations under the phearn Terms & Conditions — including account management, transaction processing, and game provision.
- Legal obligation: Where processing is required to comply with applicable Philippine law, including AML obligations, KYC requirements, and gaming regulatory compliance.
- Legitimate interests: Where processing is necessary for phearn's legitimate interests — including fraud prevention, platform security, and service improvement — provided these interests are not overridden by your fundamental rights and freedoms.
7. Data Sharing and Disclosure
phearn does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:
- Payment Service Providers: GCash, Maya, BPI, BDO, UnionBank, Coins.ph, and other payment processors, solely for the purpose of processing your financial transactions.
- Identity Verification and KYC Providers: Third-party services that assist phearn in verifying player identity and age in compliance with regulatory requirements.
- Game Software Providers: Game studios and platform providers who supply games to phearn may receive limited session data necessary for gameplay delivery and auditing.
- Fraud Prevention and AML Services: Service providers that assist phearn in detecting and preventing fraud and money laundering.
- Regulatory and Law Enforcement Authorities: phearn will disclose personal data to government agencies, regulators, or law enforcement bodies where required by Philippine law or a valid legal order — including to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC).
- Professional Advisers: Legal, audit, and compliance advisers where disclosure is necessary for professional services rendered to phearn.
All third-party recipients are required to maintain appropriate data protection standards and to process your data only for the specified purpose of disclosure.
8. International Data Transfers
Some of phearn's service providers may process data outside the Philippines. Where personal data is transferred internationally, phearn ensures that appropriate safeguards are in place consistent with the requirements of the Philippine Data Privacy Act — including contractual data processing agreements that require recipients to maintain equivalent levels of data protection.
phearn will not transfer your personal data internationally unless the destination country or organisation provides an adequate level of protection, or appropriate contractual safeguards have been implemented.
9. Data Retention
phearn retains personal data for no longer than necessary for the purposes for which it was collected, subject to the following retention guidelines:
- Active account data is retained for the duration of your account's active status.
- Transaction records and KYC documentation are retained for a minimum of 5 years from the date of the transaction or account closure, in compliance with Philippine AML and gaming record-keeping requirements.
- Communication records (support interactions) are retained for up to 3 years.
- Technical and log data is retained for up to 12 months unless longer retention is required for security investigation purposes.
After the applicable retention period, personal data is securely deleted or anonymised. Anonymised or aggregated data may be retained indefinitely for statistical and analytical purposes.
10. Cookies and Tracking Technologies
The phearn Platform uses cookies and similar tracking technologies to deliver and improve its services. The following types of cookies may be used:
- Strictly Necessary Cookies: Required for the Platform to function — including session authentication (phearn Login), load balancing, and security tokens. These cannot be disabled without affecting Platform functionality.
- Functional Cookies: Remember your preferences (e.g., language, responsible gaming settings) to deliver a consistent phearn experience.
- Analytics Cookies: Collect aggregated, anonymised data about how players navigate the phearn Platform to help us improve user experience and content relevance.
phearn does not use advertising or cross-site tracking cookies. You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling strictly necessary cookies may impair your ability to use phearn.
11. Your Rights as a Data Subject
Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phearn:
- Right to be Informed: The right to know that your personal data is being collected and processed, including the purposes and extent of processing.
- Right of Access: The right to request a copy of the personal data phearn holds about you.
- Right to Rectification: The right to request correction of inaccurate or incomplete personal data in your phearn account.
- Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to phearn's legal retention obligations.
- Right to Data Portability: The right to receive your personal data in a structured, commonly used format.
- Right to Object: The right to object to certain types of processing, including direct marketing.
- Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.
To exercise any of these rights, please contact the phearn DPO as described in Section 15. phearn will respond to all valid data subject requests within 30 calendar days of receipt.
12. Children's and Minors' Privacy
The phearn Platform is strictly for adults aged 21 years and older. phearn does not knowingly collect personal data from individuals under 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.
If you are a parent or guardian and believe that a minor has registered on phearn, please contact our support team immediately so we can investigate and take appropriate action.
13. Security Measures
phearn implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:
- 256-bit SSL/TLS encryption for all data in transit between your device and phearn servers.
- Encryption of sensitive data at rest, including KYC documents and financial records.
- Role-based access controls ensuring that phearn personnel can only access personal data necessary for their specific function.
- Multi-factor authentication requirements for internal systems access.
- Regular security vulnerability assessments and penetration testing.
- Incident response procedures with mandatory breach notification in accordance with NPC reporting requirements.
While phearn takes all reasonable precautions, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phearn Login credentials and for promptly notifying phearn of any suspected unauthorised account access.
14. Changes to This Privacy Policy
phearn reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform functionality. Material changes will be communicated to registered players via SMS or on-platform notification at least 7 days before the changes take effect.
The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the phearn Platform after the effective date of any update constitutes your acceptance of the revised Policy. If you do not accept the updated Policy, please stop using the Platform and contact support to close your account.
15. Contact & Data Protection Officer
For all privacy-related inquiries, data subject requests, or concerns about how phearn handles your personal data, please contact:
- Data Protection Officer (DPO), phearn
- Email: [email protected]
- Live Chat: Available 24/7 on the phearn Platform
phearn is committed to resolving all privacy inquiries promptly and fairly. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC).