phingo Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how phingo ("phingo", "the Company", "we", "us", "our") collects, processes, stores, and protects personal data provided by or generated by users ("you", "the User") of the phingo online gaming platform accessible at https://phingo.club and all associated pages (collectively, "the Platform").

phingo operates primarily to serve Filipino players and is committed to compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), and its Implementing Rules and Regulations. This Policy applies to all personal information collected through the Platform, our customer support channels, and any other interactions you have with phingo.

By registering an account and using the phingo Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller

phingo acts as the personal information controller in respect of all personal data collected through the Platform. For the purposes of the Data Privacy Act of 2012, phingo is responsible for determining the purposes and means by which your personal data is processed.

All data protection inquiries and requests to exercise your rights under the DPA should be directed to the phingo Data Privacy Officer at the contact details provided in Section 13 of this Policy.

3. Information We Collect

phingo collects and processes the following categories of personal data:

3.1 Registration Data. When you create a phingo account, we collect your full legal name, date of birth, Philippine residential address, mobile phone number (in +63 format), email address (where provided), and username of your choosing.

3.2 Identity Verification Data. To comply with Philippine anti-money laundering obligations and age verification requirements, phingo may collect copies of government-issued identification documents such as your Philippine passport, SSS/GSIS card, UMID, or LTO driver's licence, along with any supporting documents required during enhanced due diligence reviews.

3.3 Financial Data. We collect data relating to your financial transactions on the Platform, including deposit amounts, withdrawal requests, payment method references (e.g., your registered GCash or PayMaya account identifier), transaction timestamps, and balance history. phingo does not store full card numbers; card transactions are handled by certified payment processors.

3.4 Gaming Activity Data. phingo records your gameplay history, including games played, bets placed, outcomes, session durations, and bonus utilisation. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory reporting.

3.5 Device and Technical Data. When you access the Platform, phingo automatically collects certain technical data including your IP address, device type, operating system, browser type and version, session timestamps, and referral source. This data is used for security monitoring, fraud prevention, and platform performance optimisation.

3.6 Communications Data. If you contact phingo's customer support team via live chat, email, or any other channel, we retain records of those communications, including the content of messages and associated metadata, for quality assurance and dispute resolution purposes.

4. How We Use Your Information

phingo processes personal data for the following purposes:

• Account creation and management – to register your phingo account, verify your identity and age (21+), and maintain accurate account records
• Service delivery – to provide access to games, process deposits and withdrawals in Philippine Pesos via GCash, PayMaya, BPI, BDO, Metrobank, and other supported channels, and to manage your phingo wallet
• Security and fraud prevention – to detect, investigate, and prevent fraudulent transactions, unauthorised account access, and other prohibited conduct
• Regulatory compliance – to fulfil phingo's obligations under Philippine anti-money laundering laws (RA 9160, as amended), the DPA, and any applicable PAGCOR compliance requirements
• Responsible gaming – to monitor gameplay patterns, enforce deposit limits, process self-exclusion requests, and identify Users who may be experiencing gaming-related harm
• Customer support – to respond to your inquiries, resolve disputes, and provide assistance related to your phingo account
• Platform improvement – to analyse aggregated usage patterns, improve game loading performance (particularly for players in Cebu, Davao, and other regional areas of the Philippines), and develop new platform features
• Marketing communications – to send you information about phingo promotions, bonuses, and new game releases, where you have provided consent for such communications

5. Legal Basis for Processing

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

• Contractual necessity – processing necessary to perform the phingo service contract with you, including account management, payment processing, and gameplay delivery
• Legal obligation – processing required to comply with applicable Philippine laws, including age verification, AML compliance, and regulatory reporting
• Legitimate interests – processing necessary for phingo's legitimate interests in security, fraud prevention, and platform improvement, where these interests are not overridden by your data protection rights
• Consent – processing for marketing communications, where phingo has obtained your explicit consent, which you may withdraw at any time

6. Sharing and Disclosure of Information

phingo does not sell your personal data to third parties. phingo may share your personal data in the following limited circumstances:

• Payment processors – phingo shares necessary transaction data with certified payment processors (including GCash, PayMaya, and banking partners) to facilitate deposits and withdrawals
• Game providers – phingo shares session identifiers with game providers (such as JILI) to deliver gaming content; game providers receive only the minimum data necessary and are contractually bound to data protection obligations
• Regulatory and law enforcement authorities – phingo may disclose personal data to PAGCOR, AMLC, or other Philippine government authorities where required by law or in response to a valid legal order
• Professional advisors – phingo's legal, audit, and compliance advisors may have access to personal data on a confidential, need-to-know basis
• Business transfers – in the event of a merger, acquisition, or sale of assets involving phingo, personal data may be transferred to the relevant successor entity, subject to equivalent data protection commitments

In all cases, phingo applies appropriate contractual and technical safeguards to protect personal data shared with third parties.

7. Data Retention

phingo retains personal data for as long as necessary to fulfil the purposes for which it was collected, and thereafter for as long as required by applicable Philippine law. Specifically:

• Account and identity verification data is retained for a minimum of five (5) years following account closure, in compliance with AML record-keeping obligations
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction
• Gaming activity data is retained for three (3) years from the date of each session
• Customer support communications are retained for two (2) years from the date of the interaction

Where retention is no longer required by law or legitimate business purpose, phingo securely deletes or anonymises the relevant personal data.

8. Cookies and Tracking Technologies

phingo uses cookies and similar tracking technologies on the Platform to maintain your login session, remember your preferences, analyse traffic patterns, and support security functions. You can manage cookie preferences through your browser settings, but disabling certain cookies may affect the functionality of the phingo Platform.

phingo does not use tracking technologies to serve personalised advertising on behalf of third-party advertisers.

9. Security of Your Personal Data

phingo implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include SSL/TLS encryption for all data in transit, encrypted storage of sensitive account data, strict access controls limiting data access to authorised phingo personnel on a need-to-know basis, and regular security assessments of the Platform infrastructure.

While phingo takes all reasonable steps to protect your data, no online system is completely immune to risk. phingo will notify affected Users and the National Privacy Commission in the event of a data breach that poses a significant risk to your rights, in accordance with the DPA's breach notification requirements.

10. Your Rights Under the Data Privacy Act

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phingo:

• Right to be informed – the right to know what personal data phingo collects and how it is used
• Right of access – the right to request a copy of the personal data phingo holds about you
• Right to rectification – the right to have inaccurate or incomplete personal data corrected
• Right to erasure or blocking – the right to request deletion or blocking of personal data where processing is no longer lawful or necessary, subject to phingo'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 processing based on legitimate interests, including profiling for direct marketing purposes
• Right to damages – the right to claim compensation for harm resulting from a violation of your data privacy rights

To exercise any of these rights, please contact phingo's Data Privacy Officer at [email protected]. phingo will respond to verified requests within thirty (30) days. If you are dissatisfied with phingo's response, you may file a complaint with the National Privacy Commission of the Philippines.

11. Children and Minors

The phingo Platform is strictly for persons aged twenty-one (21) years and above. phingo does not knowingly collect personal data from individuals below the age of 21. If phingo becomes aware that a minor has provided personal data or created an account, that account will be immediately closed and all associated data deleted in accordance with this Policy and applicable law.

12. Changes to This Privacy Policy

phingo reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. Material changes will be communicated to registered Users via their registered mobile number or email address, or by prominent notice on the Platform, no less than seven (7) days before the changes take effect. Continued use of the phingo Platform after the effective date of any update constitutes acceptance of the revised Policy.

13. Contact and Complaints

For all data privacy inquiries, requests to exercise your rights, or complaints regarding phingo's handling of your personal data, please contact the phingo Data Privacy Officer:

Email: [email protected] (plain text — not a clickable link)
Response Time: Within thirty (30) days of receipt of a verified written request
Escalation: National Privacy Commission of the Philippines — www.privacy.gov.ph