funph Privacy Policy

1. Introduction

1.1 funph is committed to protecting the privacy and personal data of all players who use the funph online gaming platform. This Privacy Policy describes how funph collects, uses, stores, shares, and protects your personal data in connection with your use of the funph website and all associated services (collectively, the "Platform").

1.2 This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC"). funph is registered as a personal information controller under applicable Philippine law.

1.3 This Privacy Policy should be read together with the funph Terms & Conditions and Responsible Gaming Policy, each of which is incorporated herein by reference.

1.4 If you have any questions about this Privacy Policy or how funph handles your personal data, please contact our Data Protection Officer using the details set out in Section 16 of this document.

2. Who We Are

2.1 For the purposes of the Data Privacy Act of 2012, funph acts as the Personal Information Controller in respect of the personal data collected through the funph Platform. funph is the entity responsible for determining the purposes and means of processing your personal data.

2.2 funph operates the online gaming platform accessible at funph.club, offering casino games, slots, bingo, and other gaming products to eligible players in the Philippines. All gaming activities on the funph Platform are conducted in Philippine Peso (PHP).

2.3 funph has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with the DPA and this Privacy Policy. Contact details for the DPO are provided in Section 16.

3. Personal Data We Collect

3.1 funph collects the following categories of personal data from players and prospective players:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Gender;
• Nationality and country of residence;
• Government-issued ID number (e.g., PhilSys National ID, SSS, UMID, Passport, Driver's Licence);
• Username and encrypted password.

3.2 Contact Data

• Residential address (including barangay, city/municipality, province, and postal code);
• Email address;
• Philippine mobile number.

3.3 Financial Data

• GCash or PayMaya account number (where used for deposits or withdrawals);
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where used for transactions;
• Transaction history, including deposit amounts, withdrawal amounts, and dates;
• Account balance information.

3.4 Gaming & Activity Data

• Game history, including games played, wagers placed, and outcomes;
• Session duration and login/logout timestamps;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, self-exclusion status, etc.).

3.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Cookie identifiers and session tokens;
• Platform access logs and error reports.

3.6 Communications Data

• Records of communications between you and funph customer support;
• Feedback, complaints, and dispute records;
• Marketing preference settings.

4. How We Collect Your Data

4.1 funph collects your personal data through the following means:

• Direct collection: Information you provide when registering for a funph account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and device data collected automatically when you access the funph Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from third-party KYC (Know Your Customer) service providers; fraud prevention data from anti-fraud partners; payment data from e-wallet and banking partners such as GCash, PayMaya, BPI, BDO, and Metrobank.

4.2 funph does not collect personal data from social media platforms or third-party data brokers for marketing purposes without your explicit consent.

5. How We Use Your Personal Data

5.1 funph uses your personal data for the following purposes:

5.2 funph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing another lawful basis for processing.

6. Legal Basis for Processing

6.1 funph processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and funph (i.e., to provide gaming services, process payments, and manage your account);
• Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act;
• Legitimate interests: Processing necessary for funph's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

7.1 funph does not sell, rent, or trade your personal data to third parties. funph may share your personal data with the following categories of recipients only where necessary and lawful:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other Philippine payment service providers, for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with PAGCOR and AMLA requirements;
• Fraud prevention and security partners: Service providers engaged to detect and prevent fraudulent activity on the funph Platform;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulatory obligation;
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate criminal activity;
• Professional advisers: Legal, accounting, and auditing firms engaged by funph, subject to strict confidentiality obligations;
• IT and platform service providers: Cloud hosting, data storage, and platform infrastructure providers engaged by funph, subject to data processing agreements that require them to handle your data in accordance with the DPA.

7.2 All third parties with whom funph shares personal data are required to implement appropriate technical and organisational measures to protect that data and to process it only in accordance with funph's instructions and applicable Philippine law.

8. Cookies & Tracking Technologies

8.1 funph uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the funph website. They help funph recognise your device, maintain your session, and remember your preferences.

8.2 funph uses the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that maintain your login state and security tokens. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Used to collect anonymised data about how players use the Platform, helping funph identify areas for improvement. No personally identifiable information is collected through analytics cookies.
• Marketing cookies: Used only with your explicit consent to deliver relevant promotional content. You may opt out of marketing cookies at any time through your account settings.

8.3 You may control cookie settings through your browser. Note that disabling strictly necessary cookies may affect the functionality of the funph Platform.

9. Data Retention

9.1 funph retains your personal data for the following periods, or longer where required by applicable Philippine law:

• Account data: Retained for the duration of your account and for five (5) years following account closure, in compliance with PAGCOR record-keeping requirements;
• Financial transaction data: Retained for five (5) years from the date of the transaction, in compliance with the Anti-Money Laundering Act and its implementing regulations;
• KYC and identity verification documents: Retained for five (5) years following account closure or the completion of the relevant transaction;
• Customer support communications: Retained for three (3) years from the date of the communication;
• Marketing consent records: Retained for the duration of your consent and for two (2) years following withdrawal of consent.

9.2 Upon expiry of the applicable retention period, funph will securely delete or anonymise your personal data in accordance with its data disposal procedures.

10. Data Security

10.1 funph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmissions between your device and the funph Platform;
• Encryption of sensitive data at rest, including financial account details and government ID numbers;
• Role-based access controls limiting access to personal data to authorised funph personnel on a need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning of the funph Platform;
• Multi-factor authentication for administrative access to systems containing personal data;
• Staff training on data privacy and security obligations under the DPA.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, funph will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

10.3 While funph takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your funph account credentials and for notifying funph immediately if you suspect unauthorised access to your account.

11. Your Data Subject Rights

11.1 Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by funph:

• Right to be informed: The right to be informed of how your personal data is collected, used, and processed — as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data funph holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• 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 funph's legal retention obligations;
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, or to object to processing for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that funph has processed your personal data in violation of the DPA.

11.2 To exercise any of the above rights, please contact the funph Data Protection Officer using the details provided in Section 16. funph will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12. Children & Minors

12.1 The funph Platform is strictly intended for use by individuals who are at least 21 years of age, in accordance with Philippine law and PAGCOR regulations governing online gaming. funph does not knowingly collect personal data from individuals under the age of 21.

12.2 If funph discovers that personal data has been collected from a person under 21 years of age, funph will immediately close the associated account, delete the personal data collected, and return any deposited funds in accordance with its Terms & Conditions.

12.3 If you believe that funph has inadvertently collected personal data from a minor, please contact the funph Data Protection Officer immediately using the details in Section 16.

13. International Data Transfers

13.1 funph primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data outside the Philippines — for example, to cloud infrastructure providers or KYC service providers operating in other jurisdictions — funph will ensure that such transfers are conducted in accordance with the Data Privacy Act and NPC regulations on cross-border data transfers.

13.2 funph will only transfer personal data to recipients in countries that provide an adequate level of data protection, or where appropriate safeguards are in place, such as data processing agreements incorporating standard contractual clauses approved by the NPC.

13.3 You may request information about the safeguards in place for any international transfer of your personal data by contacting the funph Data Protection Officer.

14. Third-Party Links

14.1 The funph Platform may contain links to other websites or services operated by third parties. This Privacy Policy applies solely to the funph Platform and does not extend to any third-party websites or services. funph is not responsible for the privacy practices of any third-party website.

14.2 funph recommends that you review the privacy policy of any third-party website you visit before providing any personal data to that website.

15. Amendments to This Privacy Policy

15.1 funph reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, or funph's data processing practices. Where changes are material, funph will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

15.2 The effective date of the current version of this Privacy Policy is stated at the top of this document. Your continued use of the funph Platform following the effective date of any amendment constitutes your acknowledgement of the revised Privacy Policy.

15.3 The most current version of this Privacy Policy will always be available on the funph website at funph.club/privacy-policy.

16. Contact & Data Protection Officer

16.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by funph, please contact our Data Protection Officer:

16.2 For general customer support enquiries, you may also contact the funph support team at:

16.3 If you are not satisfied with funph's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC complaints process is available through official Philippine government channels.

16.4 For information on the terms governing your use of the funph Platform, please review our Terms & Conditions. For information on responsible gaming tools and support, please visit our Responsible Gaming page.