phrown Privacy Policy

1Introduction

This Privacy Policy ("Policy") applies to all personal information collected by phrown ("phrown," "we," "us," "our") through the website located at https://phrown.cam (the "Platform") and any related services, features, content, or applications offered by phrown. This Policy should be read in conjunction with our Terms and Conditions, which govern your use of the Platform.

By accessing, browsing, registering an account, or using any service on the phrown Platform, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with any provision herein, you must not use the Platform or provide any personal information to phrown.

phrown reserves the right to modify this Privacy Policy at any time. Material changes will be communicated to registered users via email or in-platform notification at least fourteen (14) calendar days prior to the effective date of such changes. Your continued use of the Platform following the effective date of any amendments constitutes your acceptance of the revised Policy.

2Data Controller

For the purposes of Philippine data protection law, phrown acts as the Data Controller for personal information collected through the Platform. This means phrown determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable legal requirements.

phrown is registered and operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR), which imposes strict obligations regarding the collection, use, storage, and disclosure of player information. All data processing activities undertaken by phrown adhere to PAGCOR's licensing conditions and regulatory framework.

3Information We Collect

3.1 Information You Provide Directly

When you register an account or use services on the phrown Platform, you voluntarily provide the following categories of personal information:

• Identity Information: Full legal name, date of birth, gender, nationality
• Contact Information: Email address, mobile phone number, residential address (city, province, postal code)
• Account Credentials: Username, password (stored in encrypted form), security questions and answers
• Financial Information: Payment method details (e-wallet account identifiers such as GCash or PayMaya mobile numbers, bank account details for withdrawals), transaction history, deposit and withdrawal records
• Verification Documents: Government-issued identification (passport, Philippine National ID, driver's license), proof of address (utility bills, bank statements), selfie photographs for identity verification purposes
• Communications: Content of customer support inquiries, live chat transcripts, emails, feedback submissions, and other correspondence with phrown
• Responsible Gaming Data: Self-imposed deposit limits, loss limits, session duration preferences, self-exclusion requests, cooling-off period selections

3.2 Information Collected Automatically

When you access the phrown Platform, certain information is collected automatically through cookies, web beacons, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers
• Usage Information: IP address, geographic location (country, city), pages visited, time spent on pages, links clicked, referral URLs, search terms entered
• Gaming Activity: Games played, wagers placed, winnings and losses, bonus usage, session start and end times, gameplay patterns
• Connection Data: Internet service provider, connection speed, timestamps of Platform access

3.3 Information from Third Parties

phrown may receive limited personal information from third-party service providers including payment processors (GCash, PayMaya, banks), identity verification services, fraud detection agencies, and credit reference agencies. This information is used exclusively for account verification, payment processing, fraud prevention, and regulatory compliance purposes.

4How We Use Your Data

phrown processes your personal information for the following purposes:

4.1 Account Management and Service Delivery

• Creating and maintaining your player account
• Processing registrations, logins, and authentication
• Providing access to games, betting markets, and platform features
• Recording and tracking gaming transactions, wagers, wins, and losses
• Managing your account balance and bonus funds
• Responding to customer support inquiries and resolving disputes

4.2 Payment Processing

• Processing deposits from GCash, PayMaya, bank transfers, and other approved payment methods
• Executing withdrawal requests to verified payment instruments
• Maintaining accurate financial records and transaction histories
• Preventing payment fraud, chargebacks, and money laundering

4.3 Compliance and Legal Obligations

• Verifying your identity and age to ensure compliance with the 21+ age requirement mandated by PAGCOR
• Conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures
• Detecting and preventing fraud, money laundering, terrorist financing, and other illegal activities
• Complying with regulatory reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other government authorities
• Enforcing our Terms and Conditions, including investigating breaches and imposing sanctions
• Responding to lawful requests from law enforcement agencies, courts, and regulatory bodies

4.4 Responsible Gaming and Player Protection

• Implementing deposit limits, loss limits, and session time restrictions you have set
• Processing self-exclusion and cooling-off period requests
• Monitoring gameplay patterns to identify potential problem gambling behaviors
• Providing reality checks, responsible gaming tools, and access to support resources

4.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve user experience and platform functionality
• Conducting market research and statistical analysis
• Testing new features, games, and services
• Identifying and fixing technical issues, bugs, and security vulnerabilities

4.6 Marketing and Communications

• Sending promotional offers, bonuses, free spins, and tournament invitations
• Providing updates on new games, features, and platform improvements
• Delivering personalized recommendations based on your gaming preferences
• Conducting customer satisfaction surveys and soliciting feedback

5Legal Basis for Processing

Under Philippine data protection law, phrown must have a valid legal basis for processing your personal information. We rely on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms and Conditions governing your use of the Platform, including providing gaming services, processing transactions, and managing your account.
• Legal Obligation: Processing is required to comply with Philippine laws and regulations, including PAGCOR licensing conditions, anti-money laundering obligations, tax reporting requirements, and responses to lawful government requests.
• Legitimate Interests: Processing is necessary for phrown's legitimate business interests, including fraud prevention, security monitoring, platform improvement, and direct marketing, provided such interests do not override your fundamental rights and freedoms.
• Consent: In certain circumstances, we may seek your explicit consent for specific processing activities, such as sending marketing communications or using optional tracking technologies. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

6Sharing Your Information

phrown does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your information with the following categories of recipients:

6.1 Service Providers and Business Partners

We engage trusted third-party service pro viders to support our operations, including payment processors (GCash, PayMaya, Philippine banks), identity verification services, fraud detection agencies, cloud hosting providers, customer support platforms, email service providers, and analytics tools. These service providers are contractually bound to process your information solely for the purposes specified by phrown and in accordance with applicable data protection laws.

6.2 Regulatory and Government Authorities

We may disclose your personal information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), tax authorities, law enforcement agencies, courts, and other government bodies when required by law or when necessary to comply with legal process, regulatory requests, or court orders.

6.3 Legal and Professional Advisors

phrown may share your information with lawyers, accountants, auditors, and other professional advisors who assist us in conducting our business and ensuring regulatory compliance. These advisors are bound by professional confidentiality obligations.

6.4 Business Transfers

In the event of a merger, acquisition, reorganization, asset sale, or bankruptcy proceeding involving phrown, your personal information may be transferred to the successor entity or purchaser, subject to the same privacy protections outlined in this Policy.

7Data Security Measures

phrown implements industry-standard technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS/SSL protocols. Passwords are stored using strong cryptographic hashing algorithms.
• Access Controls: Strict access controls ensure that only authorized personnel with a legitimate business need can access personal information. Multi-factor authentication is required for administrative access.
• Network Security: Firewalls, intrusion detection systems, and regular security audits protect our infrastructure from external threats.
• Secure Data Centers: Personal information is stored in secure, ISO-certified data centers with physical security controls including 24/7 monitoring, biometric access, and redundant backup systems.
• Employee Training: All phrown staff undergo regular data protection training and are bound by confidentiality agreements.
• Incident Response: We maintain an incident response plan to detect, respond to, and mitigate data breaches. In the event of a breach affecting your personal information, we will notify you and the National Privacy Commission in accordance with legal requirements.

While we employ robust security measures, no system is entirely immune to security risks. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

8Data Retention

phrown retains your personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Our retention periods are as follows:

• Active Accounts: Personal information associated with active accounts is retained for the duration of your relationship with phrown.
• Closed Accounts: After account closure, we retain personal information for a minimum of five (5) years to comply with PAGCOR regulatory requirements, tax obligations, and anti-money laundering laws.
• Financial Records: Transaction histories, deposit and withdrawal records, and related financial information are retained for seven (7) years in accordance with accounting and tax regulations.
• Marketing Preferences: If you unsubscribe from marketing communications, we will retain your email address on our suppression list to ensure we do not contact you again.
• Legal Claims: If your information is relevant to a legal dispute, regulatory investigation, or pending claim, we will retain it until the matter is resolved and all applicable appeal periods have expired.

Upon expiration of the applicable retention period, your personal information will be securely deleted or anonymized in accordance with our data destruction policies.

9Cookies & Tracking Technologies

phrown uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content.

9.1 Types of Cookies We Use

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive notifications when cookies are placed. However, disabling essential cookies may impair the functionality of the Platform and prevent you from accessing certain features.

To learn more about cookies and how to manage them, visit www.aboutcookies.org or consult your browser's help documentation.

10Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal information:

• Right to Information: You have the right to be informed about how your personal information is collected, used, and shared.
• Right of Access: You may request access to the personal information we hold about you and obtain a copy of that information.
• Right to Rectification: You may request correction of inaccurate or incomplete personal information.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal information, subject to legal and regulatory retention obligations.
• Right to Object: You may object to processing of your personal information for direct marketing purposes or based on legitimate interests.
• Right to Data Portability: You may request a machine-readable copy of your personal information for transfer to another service provider.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 15 of this Policy. We will respond to your request within thirty (30) calendar days or notify you if additional time is required.

11Children's Privacy

The phrown Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations and Philippine gaming laws. phrown does not knowingly collect, use, or disclose personal information from individuals under the age of 21.

If we become aware that we have inadvertently collected personal information from a minor, we will take immediate steps to delete that information from our systems and terminate the associated account. Parents or guardians who believe their child has provided personal information to phrown should contact us immediately using the contact details in Section 15.

We encourage parents and guardians to monitor their children's internet usage and to help enforce this Policy by instructing minors never to provide personal information to online gaming platforms without parental permission.

12International Data Transfers

phrown primarily processes personal information within the Philippines. However, some of our service providers and business partners may be located outside the Philippines, including in jurisdictions that may not provide the same level of data protection as Philippine law.

When transferring personal information internationally, phrown ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by the National Privacy Commission
• Adequacy determinations recognizing equivalent data protection standards in the destination country
• Binding corporate rules for intra-group transfers
• Service provider contractual commitments to maintain security and confidentiality standards

By using the phrown Platform, you acknowledge and consent to the transfer of your personal information outside the Philippines in accordance with the safeguards described above.

13Marketing Communications

phrown may send you promotional emails, SMS messages, push notifications, and in-platform messages about bonuses, free spins, tournaments, new games, and special offers. You can opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link in any promotional email
• Replying "STOP" to any promotional SMS message
• Adjusting your notification preferences in your account settings
• Contacting customer support to request removal from marketing lists

Please note that even if you opt out of marketing communications, we will continue to send you transactional messages related to your account, such as deposit confirmations, withdrawal notifications, security alerts, and important policy updates.

14Changes to This Policy

phrown reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will:

• Update the "Effective Date" and version number at the top of this Policy
• Notify registered users via email at least fourteen (14) calendar days before the changes take effect
• Display a prominent notice on the Platform homepage and within user account dashboards
• Maintain an archive of previous Policy versions for your reference

Your continued use of the phrown Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you must discontinue use of the Platform and may request account closure in accordance with our Terms and Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

15Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact our Data Protection Officer: