phbest Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how phbest ("phbest," "we," "us," or "our") collects, uses, discloses, and safeguards personal information relating to players and visitors ("you" or "your") who access or use the phbest online gaming platform at phbest.club and all associated services (collectively, the "Platform").

phbest is committed to protecting the privacy and personal data of every Filipino player on the Platform. This Policy is drafted in compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC).

By accessing the phbest Platform, creating an account, making a deposit, or otherwise interacting with our services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform and close your phbest account.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, phbest is the personal information controller responsible for the personal data collected through the Platform. phbest determines the purposes and means of processing your personal data.

phbest has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection laws. Queries directed to the DPO may be submitted via the contact details set out in Section 14 of this Policy.

3 Personal Data We Collect

phbest collects personal data in several ways: directly from you when you register or use the Platform, automatically through your use of the Platform, and from third parties in the course of identity verification and payment processing. The categories of personal data we collect include the following:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used for age verification — phbest requires all players to be 21 years of age or older);
• Philippine mobile number;
• Email address;
• Username chosen at registration;
• Residential address.

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification documents (passport, driver's license, UMID, SSS card, PhilHealth ID, or other accepted Philippine government IDs);
• Proof of address documentation (utility bills, bank statements, or similar);
• Selfie or biometric verification images where required by phbest's KYC process;
• Source of funds documentation where required under anti-money laundering obligations.

3.3 Financial & Transaction Data

• Payment method identifiers (GCash mobile number, Maya account reference, bank account number, or e-wallet token — phbest does not store complete card numbers);
• Deposit and withdrawal transaction records including amounts, timestamps, and payment method used;
• Wallet balance history;
• Bonus and promotion redemption history.

3.4 Gaming Activity Data

• Game session records including game title, wager amounts, game outcomes, and session duration;
• Sports and sabong betting records;
• Responsible gaming tool settings (deposit limits, self-exclusion status, session time limits).

3.5 Technical & Device Data

• IP address and approximate geographic location derived from IP;
• Device type, operating system, browser type and version;
• Session login and logout timestamps;
• Platform usage logs and clickstream data;
• Cookie identifiers and similar tracking data (see Section 6).

3.6 Communications Data

• Records of your communications with phbest customer support, including live chat transcripts and email correspondence;
• Preferences you express regarding promotional communications.

4 How phbest Uses Your Personal Data

phbest processes your personal data for the following specific purposes:

phbest will not process your personal data for any purpose incompatible with those listed above without first obtaining your explicit consent or establishing a new lawful basis for such processing.

5 Legal Basis for Processing

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

1. Contractual Necessity: Processing required to perform the contract between phbest and the Player — including account management, game provision, payment processing, and customer support.
2. Legal Obligation: Processing required to comply with Philippine law, including anti-money laundering legislation, gaming regulatory requirements, and tax reporting obligations.
3. Legitimate Interests: Processing necessary for phbest's legitimate interests, including fraud prevention, security monitoring, platform analytics, and responsible gaming monitoring — where such interests are not overridden by your fundamental rights and freedoms.
4. Consent: Processing for promotional communications, optional cookies, and other non-essential data uses where phbest has obtained your explicit prior consent. You may withdraw consent for these processing activities at any time without affecting the lawfulness of prior processing.

6 Cookies & Tracking Technologies

6.1 What Are Cookies

Cookies are small text files placed on your device when you access the phbest Platform. They help phbest recognise your device, maintain your session, remember your preferences, and collect analytics data about how the Platform is used.

6.2 Types of Cookies Used by phbest

• Strictly Necessary Cookies: Required for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled without disrupting Platform functionality.
• Functional Cookies: Remember your preferences (such as language settings) and personalise your phbest experience. These are set with your consent.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform to help phbest improve performance and user experience. phbest uses privacy-respecting analytics tools for this purpose.
• Responsible Gaming Cookies: Store your responsible gaming tool settings (such as session time preferences) between visits to ensure continuity of your chosen protections.

6.3 Managing Cookies

You may manage non-essential cookie preferences through the phbest cookie consent manager accessible from the Platform footer. You may also configure your browser to refuse or delete cookies; however, disabling strictly necessary cookies will impair Platform functionality, including your ability to log in to your phbest account.

7 Data Sharing & Third-Party Disclosure

phbest does not sell, rent, or trade your personal data. We share personal data only in the following circumstances:

7.1 Service Providers

phbest engages third-party service providers to support platform operations, including payment processors (GCash, Maya, BPI, BDO, and other supported Philippine payment gateways), identity verification providers, live game streaming technology providers, customer support platform operators, and cloud infrastructure providers. These providers process your data only on phbest's instructions and are contractually bound to protect it in accordance with this Policy and applicable Philippine law.

7.2 Regulatory & Law Enforcement Authorities

phbest discloses personal data to Philippine regulatory authorities (including gaming regulators and the Anti-Money Laundering Council — AMLC) and law enforcement agencies where required or permitted by Philippine law. Such disclosures are made only to the extent necessary and in compliance with applicable legal procedures.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of phbest's assets, your personal data may be transferred to the acquiring entity. phbest will provide notice of such a transfer and the acquirer will be required to honour this Privacy Policy.

7.4 With Your Consent

phbest may share your personal data with other parties where you have given explicit prior consent to such sharing. You may withdraw this consent at any time by contacting phbest support.

8 Data Retention

phbest retains personal data for the periods set out below, after which data is securely deleted or irreversibly anonymised:

9 Security Measures

phbest implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data processed, including:

• Encryption at rest and in transit: All personal data stored by phbest is encrypted at rest using AES-256 encryption. All data transmitted between your device and phbest is protected by TLS (Transport Layer Security) with SSL certificates.
• Access controls: Access to personal data within phbest is restricted on a strict need-to-know basis. Staff with access to sensitive player data complete mandatory data protection training and are subject to confidentiality obligations.
• Infrastructure security: phbest's platform infrastructure is hosted on enterprise-grade cloud providers with physical and logical security certifications. Regular penetration testing and vulnerability assessments are conducted.
• Incident response: phbest maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to affected individuals, phbest will notify the National Privacy Commission and affected players in accordance with the timelines prescribed by the Data Privacy Act of 2012.
• Payment security: phbest does not store complete payment card numbers or GCash/Maya PINs. Payment processing is handled through certified payment gateway providers that comply with applicable payment security standards.

10 Your Privacy Rights

Under the Data Privacy Act of 2012, Philippine players have the following rights with respect to their personal data held by phbest:

11 Children & Minors

The phbest Platform is strictly limited to individuals who are 21 years of age or older under Philippine gaming law. phbest does not knowingly collect personal data from individuals under the age of 21. The phbest registration process and KYC verification procedures are specifically designed to identify and prevent access by underage individuals.

12 International Data Transfers

phbest's primary data processing activities are conducted within the Philippines. Where personal data is transferred to service providers or infrastructure located outside the Philippines (for example, cloud providers with data centres in other countries), phbest ensures that such transfers are subject to appropriate safeguards — including data processing agreements that require the recipient to maintain data protection standards consistent with the Data Privacy Act of 2012 and this Policy.

phbest does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual protections. Players who wish to obtain information about the specific international transfers applicable to their data may submit a request to phbest's Data Protection Officer.

13 Changes to This Privacy Policy

phbest reserves the right to update this Privacy Policy at any time. When material changes are made — for example, changes to the categories of data collected, the purposes for which data is used, or the rights available to players — phbest will notify registered players via their registered email address and/or by a prominent notice on the Platform no less than fourteen (14) days before the changes take effect.

The effective date at the top of this Policy indicates when the current version was last updated. Continued use of the phbest Platform after the effective date of an updated Policy constitutes acceptance of the revised terms. phbest recommends that players review this Policy periodically to stay informed of how their personal data is handled.

14 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or phbest's data processing activities, please contact phbest through the following channels:

• Data Protection Officer / General Privacy Enquiries:
  [email protected] — subject line: "Privacy Policy Enquiry"
• Data Rights Requests:
  [email protected] — subject line: "Data Privacy Rights Request"
• VIP Account Support:
  [email protected]
• Live Chat: Available 24/7 via the phbest Platform after login — for urgent privacy concerns

phbest commits to acknowledging all privacy-related enquiries within five (5) Philippine business days. If you are unsatisfied with phbest's response to your privacy concern, you may refer the matter to the National Privacy Commission of the Philippines. Complete information about filing a complaint with the NPC is available on the NPC's official government information portal.