ph.modern Privacy Policy

This Privacy Policy ("Policy") describes how ph.modern ("we," "us," "our") collects, processes, stores, shares, and protects personal information obtained from individuals ("you," "your," "Data Subject") who access or use the ph.modern online gaming platform at phmodern.bio (the "Platform").

This Policy applies to all personal data processed by ph.modern in connection with:

• The registration and maintenance of player accounts on the Platform;
• The provision of online casino gaming, sports betting, and related services;
• The processing of financial transactions including deposits and withdrawals;
• The fulfilment of regulatory obligations under PAGCOR licensing conditions;
• The fulfilment of legal obligations under Philippine law, including Republic Act No. 9160 (Anti-Money Laundering Act, as amended) and Republic Act No. 10927 (Casino Regulation); and
• Customer support, communications, and marketing activities.

This Policy is incorporated into and forms part of ph.modern's Terms and Conditions. By registering an Account or using the Platform, you acknowledge that you have read, understood, and consented to the data processing practices described in this Policy.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, ph.modern is the Personal Information Controller ("PIC") in respect of personal data collected and processed through the Platform.

ph.modern operates the Platform under a valid license issued by the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing activities are conducted in compliance with RA 10173 and are subject to the regulatory oversight of both the National Privacy Commission (NPC) and PAGCOR.

ph.modern collects the following categories of personal data, depending on your interaction with the Platform:

• Legal full name (as it appears on government-issued identification)
• Date of birth
• Gender
• Residential address (including barangay, city/municipality, province)
• Philippine mobile number
• Email address
• Username chosen for the Account
• Government-issued identification numbers and copies of identification documents (for KYC purposes)
• Proof of address documentation
• Selfie or live photograph where required for biometric identity verification

• GCash account number and registered name
• Maya (PayMaya) account details
• Bank account details (for BPI, BDO, Metrobank, UnionBank, and other supported banks)
• Transaction history — deposits, withdrawals, game wagers, and bonuses
• Wallet balance and transaction timestamps
• Source of funds documentation where required by AML protocols

• IP address at time of registration and each subsequent login
• Device type, operating system, and browser information
• Session timestamps and session duration
• Geolocation data (derived from IP address — not GPS)
• Cookies and similar tracking technologies (see Section 7)

• Game titles played, bet amounts, game outcomes, and session durations
• Bonus claims, wagering activity, and promotion participation
• Responsible gaming tool usage (deposit limits set, self-exclusion history)
• Customer support interaction logs, including chat transcripts and email correspondence

ph.modern collects personal data through the following means:

• Directly from you: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automatically through the Platform: Technical and gameplay data collected through our gaming systems, servers, and cookies as you interact with the Platform.
• From third-party identity verification services: Where ph.modern uses licensed third-party KYC providers to cross-verify the identity documents you submit, those providers may return verification results to ph.modern.
• From payment service providers: Payment processors such as GCash, Maya, and partner banks may provide transaction confirmation data to ph.modern as part of standard payment processing flows.
• From publicly available sources: ph.modern may verify information against publicly available Philippine government databases or self-exclusion registries where required by PAGCOR compliance obligations.

ph.modern processes your personal data for the following purposes, each supported by a lawful basis under RA 10173:

• Account Registration and Service Provision: Processing your registration data and maintaining your Account. Legal basis: performance of a contract to which you are a party.
• Identity Verification (KYC): Verifying your identity and eligibility to use the Platform, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act. Legal basis: compliance with a legal obligation.
• Payment Processing: Processing deposits and withdrawals through your chosen payment method. Legal basis: performance of a contract; compliance with a legal obligation.
• Anti-Money Laundering Compliance: Monitoring and reporting transactions as required under RA 9160 (Anti-Money Laundering Act, as amended) and PAGCOR regulations. Legal basis: compliance with a legal obligation.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, multi-accounting, and unauthorized access. Legal basis: legitimate interests of ph.modern; compliance with a legal obligation.
• Responsible Gaming: Administering responsible gaming tools including deposit limits, self-exclusion, and age verification. Legal basis: compliance with a legal obligation (PAGCOR); performance of a contract.
• Customer Support: Responding to your inquiries, disputes, and account-related requests. Legal basis: performance of a contract; legitimate interests.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates where you have opted in. Legal basis: consent. You may withdraw consent at any time via Account settings or by contacting support.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the Platform's features, game selection, and user experience. Legal basis: legitimate interests. This processing uses de-identified data only.

ph.modern does not sell your personal data. We may share your data with the following categories of recipients, to the extent strictly necessary for the stated purpose:

• Payment Service Providers: GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT processing providers — solely to process your financial transactions on the Platform.
• Licensed Game Providers: Providers including PG Soft, Pragmatic Play, JILI, Evolution, SA Gaming, and others — who may receive your Account identifier and session token to authenticate and deliver game content. These providers operate under data processing agreements with ph.modern.
• KYC & Identity Verification Services: Third-party identity verification providers engaged by ph.modern to process KYC document checks. All such providers are bound by data processing agreements and applicable Philippine privacy law.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities — as required by law or upon lawful demand.
• Legal Advisers and Auditors: External legal counsel and auditors engaged by ph.modern — under strict confidentiality obligations and only to the extent necessary for the engagement.
• Business Transfers: In the event of a merger, acquisition, reorganisation, or sale of ph.modern's business assets, your data may be transferred to the acquiring entity, subject to equivalent privacy protections and notification to you.

The ph.modern Platform uses cookies and similar tracking technologies to operate, maintain, and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function, including maintaining your login session, securing your Account, and enabling the cashier. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game lobby view, and responsible gaming tool configurations.
• Analytical Cookies: Collect aggregated, anonymised data about how players use the Platform, enabling ph.modern to identify performance issues and improve user experience. No individual player is identifiable from analytical cookie data.
• Security Cookies: Used to detect unusual login patterns, prevent fraud, and enforce one-account-per-player policies.

ph.modern does not use third-party advertising cookies or cross-site tracking technologies that would share your data with advertising networks outside the Platform.

You may manage non-essential cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent the Platform from functioning correctly and will result in an inability to log in to your Account.

ph.modern retains personal data for as long as necessary to fulfil the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, ph.modern will securely delete or permanently anonymise your personal data, unless we are required by law to retain it for a longer period or an ongoing legal matter necessitates extended retention.

ph.modern implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, and disclosure. These measures include:

• Encryption: All personal data is encrypted at rest using AES-256 encryption and in transit using TLS 1.2 or higher (256-bit SSL).
• Access Controls: Access to personal data is restricted on a role-based, need-to-know basis. All internal access to player records is logged and subject to regular audit.
• Password Security: Player passwords are one-way hashed using industry-standard algorithms. ph.modern personnel cannot view your password in plain text at any time.
• Two-Factor Authentication: ph.modern provides optional 2FA for player accounts and mandates 2FA for all internal administrative access to personal data systems.
• Penetration Testing: ph.modern's Platform undergoes regular independent penetration testing and vulnerability assessments.
• Incident Response: ph.modern maintains a documented data breach incident response procedure consistent with NPC notification requirements.

While ph.modern takes all reasonable measures to protect your data, no internet-based system is entirely impervious to all possible threats. Players are encouraged to use strong unique passwords, enable 2FA on their Accounts, and report any suspicious activity immediately to our 24/7 support team.

Some of ph.modern's licensed game providers and technical service providers operate servers outside the Philippines. Where personal data is transferred to a jurisdiction outside the Philippines in the course of game delivery or platform operation, ph.modern ensures that such transfers are subject to appropriate safeguards, including:

• Data processing agreements incorporating the standard contractual clauses recognised under Philippine data privacy law;
• Restrictions on the recipient's use of data to the specific purpose for which it was transferred; and
• Requirements for the recipient to maintain security standards equivalent to those applied by ph.modern.

Personal data is never transferred to any jurisdiction that does not provide an adequate level of protection for personal data without appropriate contractual safeguards in place. Players may contact ph.modern's DPO to obtain information about the specific safeguards applied to cross-border data transfers affecting their Account.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by ph.modern:

• Right to be Informed: You have the right to know whether ph.modern holds personal data about you, and to receive clear information about how it is used — which this Policy provides.
• Right of Access: You may request a copy of the personal data ph.modern holds about you, along with information about the purposes for which it is processed and the third parties with whom it has been shared.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to have it corrected. Minor corrections (email address, contact number) can be made directly in your Account settings. For corrections to identity data, contact support with supporting documentation.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (where consent was the legal basis), or where the data has been unlawfully processed. This right is subject to ph.modern's legal retention obligations, which may require us to retain certain records for the periods stated in Section 8.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to processing based on ph.modern's legitimate interests. You also have the right to withdraw consent for marketing communications at any time, which will not affect the lawfulness of processing prior to withdrawal.
• Right to File a Complaint: If you believe ph.modern has processed your personal data in violation of RA 10173, you have the right to file a complaint with the National Privacy Commission of the Philippines.

The ph.modern Platform is strictly prohibited to persons under 21 years of age in accordance with PAGCOR licensing conditions. ph.modern does not knowingly collect personal data from individuals under 21 years of age.

If ph.modern becomes aware that personal data has been submitted by a person under 21 years of age — whether discovered through KYC review, identity verification, or other means — ph.modern will immediately suspend and terminate the relevant Account, void any associated game results and financial transactions, and securely delete the personal data in accordance with our legal obligations. Suspected underage access may be reported to PAGCOR as required by our licensing conditions.

The ph.modern Platform may contain references to or interfaces with third-party services including licensed game studios, payment processors, and identity verification providers. These third parties operate under their own privacy policies, which are separate from this Policy and governed by their own terms.

ph.modern is not responsible for the privacy practices of third-party services. Players who have concerns about how a specific game provider or payment processor handles their data should review the privacy policy of that third party directly.

ph.modern does not embed third-party social media tracking pixels, advertising networks, or cross-site audience profiling technologies within the Platform.

ph.modern may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The effective date at the top of this Policy indicates when the current version came into force.

Where changes are material — such as a new purpose for processing, a new category of data collected, or a change in your rights — ph.modern will notify registered players via the email address on file before the changes take effect. Non-material clarifications may be made without prior notice.

Continued use of the Platform following the effective date of an amended Policy constitutes acceptance of the revised terms. The current version of this Policy is always available at phmodern.bio/privacy-policy.

For all privacy-related inquiries, data rights requests, or complaints regarding ph.modern's data processing practices, please contact ph.modern's Data Protection Officer through the following channels:

• Email: [email protected] — Subject line: "Data Protection Officer — [Your Inquiry Type]"
• Live Chat: Available 24/7 through the ph.modern Platform at phmodern.bio. For routine privacy questions, live chat provides the fastest response. For formal data rights requests, email is required to create a written record.

If you are not satisfied with ph.modern's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through the NPC's official complaint channels. ph.modern respects and cooperates with NPC investigations and takes all NPC determinations seriously.