phroby Privacy Policy
for Philippine Players

phroby is the personal information controller in respect of the personal data collected and processed through the phroby platform at phroby.cam. phroby is responsible for determining the purposes for which and the means by which your personal data is processed, in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

phroby has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. Contact details for the phroby DPO are set out in Section 14 of this Policy.

This Privacy Policy applies to all personal data collected and processed by phroby in connection with:

• The registration and management of phroby player accounts.
• The use of any game, betting product, or service available on the phroby platform.
• Deposit and withdrawal transactions processed through the phroby platform, including via GCash, Maya, BPI, BDO, Metrobank, GrabPay, USDT, Coins.ph, and 7-Eleven.
• Communications between players and the phroby customer support team, including live chat, email, and any other support channel.
• phroby's marketing and promotional communications, where consent has been obtained or where such communications are permitted under applicable Philippine law.
• phroby's compliance with applicable Philippine laws and regulatory requirements, including PAGCOR regulations and the Anti-Money Laundering Act.

This Policy does not apply to third-party websites, applications, or services that may be linked to or from the phroby platform. phroby encourages players to review the privacy policies of any third-party services they access.

phroby collects the following categories of personal data from players and prospective players:

phroby does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive personal information (such as government ID numbers) is collected, it is handled with heightened security measures in accordance with the Data Privacy Act.

phroby processes your personal data for the following specific, legitimate purposes:

1. Account Registration and Management: To create and maintain your phroby player account, verify your identity through KYC processes, manage your account settings, and communicate essential account-related information.
2. Service Delivery: To provide access to phroby's game library, sports betting products, live casino tables, bingo rooms, and all other platform features and services available to registered players.
3. Payment Processing: To facilitate deposits and withdrawals through your chosen payment method, verify payment ownership, detect and prevent fraudulent transactions, and maintain accurate financial records.
4. Regulatory Compliance: To comply with phroby's obligations under PAGCOR regulations, the Anti-Money Laundering Act of the Philippines (RA 9160, as amended), the Data Privacy Act (RA 10173), and all other applicable Philippine laws and regulations.
5. Security and Fraud Prevention: To monitor platform activity for suspicious behavior, protect player accounts from unauthorized access, investigate potential fraud, and maintain the integrity of the phroby gaming environment.
6. Customer Support: To respond to player inquiries, resolve disputes, process complaints, provide responsible gaming assistance, and improve the quality of phroby's support services.
7. Responsible Gaming: To monitor gameplay patterns for indicators of problem gambling behavior, administer self-exclusion and cooling-off periods, and enforce deposit limits and other responsible gaming tools set by players.
8. Platform Improvement: To analyze aggregated, anonymized usage data to improve phroby's platform design, game offerings, payment experience, and overall service quality.
9. Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications, or where phroby has a legitimate interest in contacting existing players about relevant services.

phroby processes personal data on the basis of one or more of the following lawful grounds under the Philippine Data Privacy Act:

• Contractual Necessity: Processing necessary for the performance of the contract between phroby and the Player, including providing all platform services, processing payments, and managing the player account.
• Legal Obligation: Processing necessary for compliance with phroby's legal obligations under Philippine law, including KYC requirements under PAGCOR regulations and transaction monitoring obligations under the Anti-Money Laundering Act.
• Legitimate Interests: Processing necessary for phroby's legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided such interests are not overridden by the data subject's fundamental rights and freedoms.
• Consent: Processing based on the Player's freely given, specific, and informed consent, particularly in relation to direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

phroby does not sell, rent, or trade your personal data. phroby may disclose your personal data to the following categories of third parties strictly for the purposes described in this Policy:

• Payment Service Providers: GCash (GXI), Maya (PayMaya Philippines), BPI, BDO, Metrobank, GrabPay, and other payment partners — for the sole purpose of processing your deposits and withdrawals. These providers are subject to their own privacy policies and Philippine financial regulations.
• Game Technology Providers: Third-party game studios and platform technology providers (such as Ezugi, JILI Games, Pragmatic Play, and PG Soft) may receive anonymized session data necessary to deliver their games through the phroby platform. These providers operate under data processing agreements with phroby.
• Identity Verification Providers: Accredited KYC and identity verification service providers engaged by phroby to perform document and liveness verification as part of the player onboarding process.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government agencies, where phroby is legally required to disclose player information.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by court order, subpoena, or applicable law.
• Professional Advisors: Lawyers, auditors, and accountants engaged by phroby in their professional capacity, subject to appropriate confidentiality obligations.

Some of phroby's third-party technology providers and game studios are based outside the Philippines. Where phroby transfers personal data to a country outside the Philippines, phroby ensures that appropriate safeguards are in place to protect the transferred data to a standard equivalent to that required by the Philippine Data Privacy Act, including through contractual data processing agreements incorporating the standard clauses recognized by the National Privacy Commission.

By using the phroby platform, you acknowledge that your personal data may be transferred to, stored in, and processed in countries outside the Philippines as described in this section, subject always to the protections described above.

phroby retains personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law, including the following minimum retention periods:

• KYC Identity Documents: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years, in accordance with the Anti-Money Laundering Act and applicable tax regulations.
• Account and Gameplay Data: Retained for the duration of the active account relationship and for a minimum of three (3) years following permanent account closure.
• Customer Support Communications: Retained for a minimum of three (3) years from the date of the interaction.
• Marketing Consent Records: Retained for the duration of the marketing relationship and for three (3) years following opt-out or consent withdrawal.
• Technical and Access Logs: Retained for a minimum of twelve (12) months for security and fraud investigation purposes.

Upon expiry of applicable retention periods, phroby will securely delete or irreversibly anonymize personal data such that it can no longer be linked to any identifiable individual.

phroby implements appropriate technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phroby's servers.
• Encryption of sensitive personal data and financial information at rest in phroby's databases.
• Role-based access controls limiting access to personal data to phroby personnel who require it for legitimate operational purposes.
• Regular security assessments, vulnerability scans, and penetration testing of phroby's platform and infrastructure.
• Two-factor authentication (2FA) available for all player accounts and mandatory for phroby administrative systems.
• Secure data center facilities with physical access controls and environmental protections.
• Documented incident response procedures for identifying, containing, and remediating data security incidents.

While phroby takes all reasonable steps to protect your personal data, no internet-based platform can guarantee absolute security. Players are encouraged to maintain strong, unique passwords for their phroby accounts and to enable two-factor authentication as an additional layer of personal account protection.

phroby uses cookies and similar tracking technologies on the phroby platform to support core functionality, enhance the player experience, and collect analytics data. The categories of cookies used by phroby include:

• Strictly Necessary Cookies: Essential for the phroby platform to function, including session authentication cookies that keep you logged in during your visit. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Cookies that remember your preferences, such as your preferred language, game lobby layout, and other personalization settings within phroby.
• Analytics Cookies: Cookies used to collect anonymized, aggregated data about how players use the phroby platform — which pages are visited most, how long sessions last, and where players experience issues — to help phroby improve the platform. phroby uses privacy-respecting analytics tools that do not create individual player profiles for advertising purposes.
• Security Cookies: Cookies used by phroby's fraud detection and security systems to identify suspicious access patterns and protect player accounts.

Players can manage cookie preferences through their browser settings. Disabling strictly necessary cookies may impair the functionality of the phroby platform. phroby does not currently use third-party advertising cookies or cross-site tracking technologies.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by phroby. To exercise any of these rights, please contact the phroby Data Protection Officer using the details in Section 14.

The phroby platform is strictly intended for adults aged 21 years and above, as required by PAGCOR regulations. phroby does not knowingly collect or process the personal data of individuals under 21 years of age.

All players are required to complete identity verification during registration using a valid Philippine government-issued ID confirming they are 21 years of age or older. Where phroby discovers that personal data has been collected from a person under 21 years of age, phroby will immediately close the account concerned, delete the associated personal data to the extent permitted by law, and take appropriate measures in accordance with applicable regulations.

phroby reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or the operational nature of the phroby platform.

Where amendments are material — meaning they significantly affect the way phroby uses your personal data or your rights under this Policy — phroby will provide advance notice to registered players through the mobile number or email address on their phroby account, and will update the "Last Reviewed" date at the top of this Policy accordingly.

The operative version of phroby's Privacy Policy is always the version currently published at phroby.cam/privacy-policy. Players are encouraged to review this page periodically. Continued use of the phroby platform following publication of an amended Privacy Policy constitutes acceptance of the amended terms.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phroby, please contact phroby's Data Protection Officer:

If you are not satisfied with phroby's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), which is the Philippine government authority responsible for enforcing the Data Privacy Act. Information about filing a complaint with the NPC is available through the official Philippine government channels.

This Privacy Policy was last reviewed and updated in January 2026. The version published at phroby.cam/privacy-policy is always the current operative version governing the use of the phroby platform.