philbos Privacy Policy

1. Who We Are (Data Controller)

philbos ("philbos," "we," "us," or "the Company") is the data controller responsible for personal data collected through the philbos website at philbos.vip and all associated services. philbos operates as a PAGCOR-licensed online gaming platform serving Filipino players across the Philippines.

As data controller, philbos determines the purposes and means by which your personal data is processed. Where philbos engages third-party processors — such as payment service providers or identity verification providers — those processors act on philbos's documented instructions and are bound by data processing agreements consistent with applicable Philippine law.

This Privacy Policy applies to all personal data collected from registered players, visitors to the philbos website, and individuals who interact with philbos through any channel including customer support. It does not apply to third-party websites or services linked from the philbos platform.

2. Personal Data We Collect

philbos collects personal data that is necessary for the operation of a PAGCOR-licensed gaming platform. The categories of personal data we collect include:

philbos does not collect sensitive personal information as defined under the Data Privacy Act (such as health data, religious beliefs, or political affiliation) unless required by specific regulatory obligations and with your explicit prior consent.

3. How We Use Your Personal Data

philbos processes your personal data for the following purposes:

• Account Registration & Management: To create and maintain your philbos account, verify your identity pursuant to PAGCOR KYC requirements, and manage your account preferences and settings.
• Payment Processing: To facilitate deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported Philippine payment methods, and to maintain accurate financial records.
• Regulatory Compliance: To comply with PAGCOR licensing obligations, Anti-Money Laundering Act (AMLA) reporting requirements, and directives issued by the Anti-Money Laundering Council (AMLC).
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other prohibited conduct on the platform.
• Responsible Gaming: To monitor gaming patterns and identify players who may be exhibiting problem gambling behaviour, in order to deliver responsible gaming interventions as required by our PAGCOR license.
• Platform Improvement: To analyse aggregate gaming and usage data to improve the philbos platform, fix technical issues, and enhance the player experience.
• Marketing Communications: To send promotional offers, bonus notifications, and news about philbos — only where you have provided explicit consent. You may withdraw this consent at any time.
• Customer Support: To respond to your enquiries, resolve disputes, and maintain records of communications for quality and compliance purposes.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, philbos processes your personal data on the following legal bases:

• Contractual Necessity: Processing your identity, contact, and financial data is necessary to perform the contract between you and philbos — specifically, to operate your account and execute your bets and transactions.
• Legal Obligation: Processing for KYC verification, AMLA reporting, and PAGCOR regulatory compliance is required by applicable Philippine law and our operating license. This processing cannot be refused.
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring is necessary for the legitimate interests of philbos and its players, provided those interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications is conducted only on the basis of your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Third-Party Disclosure

philbos does not sell your personal data. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: GCash (Mynt), Maya (Voyager Innovations), GrabPay, BPI, BDO, Metrobank, and InstaPay/QR Ph operators receive the minimum financial data necessary to process your transactions.
• Identity Verification Providers: Third-party KYC service providers process your identity documents solely for verification purposes under a data processing agreement with philbos.
• PAGCOR: As the national gaming regulator, PAGCOR has the right to access player data and transaction records pursuant to its regulatory and licensing functions. philbos complies fully with all PAGCOR data requests.
• AMLC and Law Enforcement: philbos is legally required to report suspicious transactions to the Anti-Money Laundering Council and to disclose player data to Philippine law enforcement authorities pursuant to valid legal process.
• Game Software Providers: Third-party game studios and live dealer operators may receive limited technical data necessary to deliver game content to your session. These providers do not receive your financial or identity data.
• Cloud and Hosting Providers: philbos uses cloud infrastructure services to store and process data. All providers are contractually required to implement data protection measures consistent with the Data Privacy Act.

Where philbos transfers personal data to processors or sub-processors located outside the Philippines, such transfers are subject to appropriate contractual protections consistent with NPC cross-border transfer requirements.

6. Cookies & Tracking Technologies

philbos uses cookies and similar tracking technologies on the philbos.vip website. The categories of cookies in use include:

• Strictly Necessary Cookies: Required for the platform to function — including session management, login state, and security tokens. These cannot be disabled without preventing platform use.
• Functional Cookies: Used to remember your preferences such as language settings, game favourites, and display options. These improve your experience but are not essential.
• Analytics Cookies: Used to collect aggregate, anonymised data on how players navigate and use the platform. This data is used to improve the platform and identify technical issues.
• Security Cookies: Used to detect fraud, unusual login patterns, and potential account takeover attempts. These are treated as strictly necessary.

philbos does not use third-party advertising cookies or cross-site tracking technologies for external advertising purposes. You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the platform.

7. Data Retention

philbos retains your personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to the following specific retention periods:

• Account data and gaming records are retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AMLA record-keeping obligations.
• Financial transaction records are retained for a minimum of five (5) years from the date of each transaction, consistent with AMLA requirements applicable to covered persons.
• KYC documents and identity verification records are retained for the duration of the account relationship and for five (5) years following account closure.
• Customer support communications are retained for two (2) years from the date of the last communication in a given case.
• Marketing consent records are retained for the duration of your account relationship and for two (2) years following withdrawal of consent, to demonstrate compliance with consent requirements.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with philbos's data destruction procedures.

8. Your Rights Under the Data Privacy Act

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

• Right to Access: You have the right to obtain confirmation of whether philbos holds personal data about you, and to receive a copy of that data in a readily accessible format.
• Right to Correction: You have the right to require philbos to correct inaccurate or incomplete personal data held about you. Many corrections can be made directly from your account settings.
• Right to Erasure: You have 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 overriding legal retention obligations (e.g., AMLA requirements).
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where you believe your rights outweigh those interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where processing is carried out by automated means.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request — [Right Requested]." philbos will respond to all valid requests within fifteen (15) business days. You also have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe philbos has not complied with its obligations under the Data Privacy Act.

9. Data Security

philbos implements a multi-layered security framework to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• TLS 1.3 encryption for all data in transit between your browser and philbos servers;
• AES-256 encryption for sensitive data at rest, including payment credentials and identity documents;
• Multi-factor authentication requirements for administrative access to systems holding personal data;
• Regular penetration testing and vulnerability assessments conducted by independent security professionals;
• Role-based access controls ensuring that philbos employees access only the data necessary for their specific job function;
• Intrusion detection systems and real-time security monitoring on all production infrastructure;
• Documented incident response procedures consistent with NPC breach notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, philbos will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where the breach is assessed as high-risk.

10. Children's Privacy & Age Restriction

The philbos platform is strictly intended for persons aged 21 years and above. philbos does not knowingly collect personal data from individuals under the age of 21. The mandatory age verification process at registration is specifically designed to prevent underage access to the platform.

If philbos becomes aware that personal data has been collected from an individual under 21 years of age, such data will be deleted immediately, the associated account will be permanently closed, and any deposited funds will be refunded to the payment source. If you believe a minor has accessed or registered a philbos account, please contact our Data Protection Officer immediately at [email protected].

11. Changes to This Privacy Policy

philbos reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Where changes are material, philbos will provide advance notice by posting the updated Policy on the philbos platform with a revised "Last Updated" date, and by notifying registered players via their registered email address.

Your continued use of the philbos platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. We recommend reviewing this Policy periodically to stay informed of how philbos protects your personal data.

12. Contact Us & Data Protection Officer

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