phonejoy Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how phonejoy ("the Company," "we," "us," "our") collects, uses, stores, protects, and discloses personal information when you visit or use the phonejoy website and all associated digital products, games, and services (collectively, the "Platform").

This Policy applies to all registered players, visitors to the Platform, and any individual whose personal data is processed by phonejoy in connection with the provision of our services. It covers information collected through the phonejoy website, mobile browser interface, customer support channels, and any communications you have with us by email or chat.

By registering a phonejoy account or by continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal information as described herein. If you do not agree to this Policy, please do not use the Platform.

This Policy should be read alongside our Terms & Conditions and any specific product terms that may apply to particular features or promotions offered on the Platform.

2. Data Controller Identity

phonejoy is the data controller responsible for your personal information processed in connection with the Platform. As data controller, phonejoy determines the purposes and means of processing personal data and is accountable under the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules and regulations.

phonejoy operates in compliance with the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing activities are conducted in accordance with PAGCOR's requirements for licensed online gaming operators, which include mandatory retention of certain player records for audit and anti-money-laundering purposes.

If you have any questions about how phonejoy handles your personal data, or if you wish to exercise your data subject rights, please contact our Data Protection Officer via email at [email protected] with the subject line "Data Privacy Request."

3. Personal Data We Collect

phonejoy collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Sensitive Personal Information

In the course of KYC verification, phonejoy may process government-issued identification documents that contain sensitive personal information as defined under the Philippine Data Privacy Act (e.g., PSA National ID, Passport, UMID). Such sensitive information is collected solely for identity and age verification purposes and is handled with enhanced security measures commensurate with its sensitivity.

4. How We Collect Your Data

phonejoy collects personal data through the following means:

• Directly from you — when you register a phonejoy account, submit KYC documents, make deposits or withdrawal requests, contact customer support, or respond to surveys and promotions.
• Automatically through the Platform — through cookies, log files, and similar tracking technologies that record technical data about your device and how you interact with the phonejoy Platform.
• From third-party service providers — including payment processors (GCash, Maya, BPI, BDO), identity verification service providers, game providers, and fraud detection services, which may provide us with data about your transactions or identity confirmation.
• From publicly available sources — such as government registries, credit reference agencies, or sanctions screening lists, where we are required to check such sources for AML or PAGCOR compliance purposes.

5. Legal Basis for Processing

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

• Performance of a contract: Processing is necessary to provide you with the phonejoy services you have registered for, including account management, game access, payment processing, and customer support.
• Compliance with a legal obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR gaming regulations, the Anti-Money Laundering Act (AMLA), and mandatory reporting obligations.
• Legitimate interests: Processing is necessary for phonejoy's legitimate interests in operating a safe, secure, and fair gaming platform, including fraud detection, security monitoring, and platform improvement, provided these interests are not overridden by your fundamental rights.
• Consent: For optional processing activities — such as sending promotional communications or personalising your gaming experience — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. How We Use Your Data

phonejoy uses your personal data for the following purposes:

6.1 Service Provision

• Creating, managing, and maintaining your phonejoy account.
• Processing deposits and withdrawal requests via GCash, Maya, and other Philippine payment channels.
• Providing access to games, live casino rooms, sports betting, and other Platform features.
• Awarding bonuses, processing wagering requirements, and managing promotions.
• Responding to customer support requests, complaints, and account queries.

6.2 Identity Verification & Compliance

• Verifying your identity and age in compliance with PAGCOR requirements (minimum age: 18 years).
• Conducting anti-money laundering (AML) screening and transaction monitoring as required under the Philippines Anti-Money Laundering Act.
• Reporting to PAGCOR and other Philippine regulatory authorities as required by law.
• Detecting and investigating suspicious account activity, fraud, cheating, or Terms violations.

6.3 Responsible Gaming

• Monitoring gaming patterns to identify players who may be exhibiting signs of problem gambling.
• Administering responsible gaming tools including deposit limits, session reminders, and self-exclusion.
• Honouring self-exclusion requests and ensuring excluded players cannot re-register.

6.4 Platform Improvement & Communications

• Analysing aggregated and anonymised usage data to improve Platform performance, user experience, and game selection.
• Sending transactional communications (account confirmations, withdrawal notifications, security alerts) via SMS and email.
• Sending promotional and marketing communications where you have consented to receive them. You may opt out at any time by contacting support.

7. Data Retention

phonejoy retains personal data for as long as necessary to fulfil the purpose for which it was collected, or for as long as required by applicable Philippine law, whichever is longer. The following general retention periods apply:

After the applicable retention period expires, phonejoy will securely delete or anonymise personal data such that it can no longer be attributed to an identified or identifiable individual.

8. Sharing & Disclosure of Personal Data

phonejoy does not sell, rent, or trade your personal data to third-party marketers or data brokers. We may share your personal data with the following categories of recipients only where necessary and proportionate:

• Payment Service Providers: GCash, Maya, BPI, BDO, Metrobank, GrabPay, and other payment processors receive the minimum information necessary to process your deposit or withdrawal transactions.
• Identity Verification Providers: Third-party KYC service providers that assist phonejoy in verifying the identity and age of players.
• Game Providers: Licensed game studios and live dealer operators (such as PG Soft, Evolution Gaming, JiLi) may receive a session token and game-specific data necessary to deliver the game. These providers do not receive your full identity data.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine governmental bodies as required by law or regulation.
• Law Enforcement: Philippine law enforcement agencies, where phonejoy is legally compelled to disclose information pursuant to a court order, warrant, or other lawful process.
• Fraud Prevention & Security Services: Third-party providers of fraud detection, cybersecurity, and risk assessment services that help protect the phonejoy Platform and its players.
• Professional Advisers: Legal counsel, auditors, and compliance advisers bound by professional obligations of confidentiality, where engagement is necessary to protect phonejoy's legitimate business interests.

All third-party service providers processing personal data on behalf of phonejoy are subject to contractual data processing agreements requiring them to process data only on phonejoy's documented instructions and to implement appropriate technical and organisational security measures.

9. International Data Transfers

Some of phonejoy's third-party service providers — including game providers and technical infrastructure partners — may be located outside the Philippines. Where personal data is transferred to a recipient in another country, phonejoy ensures that appropriate safeguards are in place to protect your data, including:

• Transferring only to countries that provide an adequate level of data protection as determined by the Philippine National Privacy Commission.
• Implementing contractual clauses in data processing agreements that impose data protection obligations equivalent to those under Philippine law.
• Applying enhanced oversight to service providers in jurisdictions with differing legal standards.

If you would like more information about the safeguards phonejoy applies to international data transfers, please contact our Data Protection Officer at [email protected].

10. Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the phonejoy Platform. They allow the Platform to recognise your device, maintain your session, remember your preferences, and gather analytics data.

10.2 Types of Cookies We Use

• Essential / Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that maintain your logged-in state and security cookies that help protect your account. These cannot be disabled without impacting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred lobby view, and responsible gaming tool configurations.
• Analytics Cookies: Collect anonymised data about how players use the Platform — pages visited, features used, session duration — to help us improve the user experience. We use aggregated, non-identifiable data only.
• Security & Fraud Prevention Cookies: Assist in detecting unusual activity, suspicious login patterns, and potential security threats.

10.3 Managing Cookies

You can manage non-essential cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies from specific websites. Note that disabling essential cookies may prevent you from logging in to your phonejoy account or using certain Platform features. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

11. Security Measures

phonejoy implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, and destruction:

• Encryption: All data transmitted between your device and the phonejoy Platform is protected by 256-bit Transport Layer Security (TLS) encryption. Sensitive stored data (including KYC documents and payment information) is encrypted at rest using AES-256.
• Two-Factor Authentication: phonejoy offers and strongly encourages players to enable 2FA using SMS one-time passwords for account login.
• Access Controls: Access to personal data within phonejoy is restricted on a strict need-to-know basis. Staff members are granted only the minimum level of access required for their role and are bound by confidentiality obligations.
• Security Monitoring: phonejoy operates 24/7 monitoring of Platform infrastructure and account activity to detect and respond to security incidents in a timely manner.
• Incident Response: In the event of a personal data breach that poses a risk to your rights and freedoms, phonejoy will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay in accordance with the requirements of the Philippine Data Privacy Act.

12. Your Rights Under the Data Privacy Act of 2012

As a data subject under Republic Act 10173 (Philippine Data Privacy Act of 2012), you have the following rights in relation to your personal data held by phonejoy:

To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Privacy Request." We will acknowledge your request within five (5) business days and respond substantively within thirty (30) calendar days, in accordance with NPC requirements. We may request proof of identity before processing your request.

If you are not satisfied with phonejoy's response to a data privacy request or believe we have handled your personal data in violation of the Data Privacy Act of 2012, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC).

13. Children & Minors

The phonejoy Platform is strictly for persons who are 18 years of age or older. phonejoy does not knowingly collect personal data from individuals under 18. All accounts are subject to mandatory KYC identity verification confirming the account holder meets the minimum age requirement.

If you are a parent or guardian and believe that a minor has provided personal data to phonejoy or registered an account without your knowledge, please contact us immediately at [email protected]. We will investigate, close the account, and delete the associated personal data as quickly as practicable.

14. Third-Party Links

The phonejoy Platform may contain links to third-party websites, payment portals, or services (such as your GCash or Maya app) that are not operated by phonejoy. This Privacy Policy does not apply to the data practices of those third parties. We encourage you to review the privacy policies of any third-party services you access through or in connection with your use of phonejoy.

phonejoy is not responsible for the privacy practices, content, or data handling of third-party websites or services. The inclusion of a link to a third-party website on the phonejoy Platform does not constitute an endorsement of that website or its privacy practices.

15. Changes to This Privacy Policy

phonejoy may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes, we will notify all registered phonejoy players via the email address associated with their account or through a prominent notice on the Platform, at least fourteen (14) days before the changes take effect.

The updated Policy will be posted on this page with the revised "Last Updated" date. Your continued use of the phonejoy Platform after the effective date of any update constitutes your acknowledgment of the revised Policy. We encourage you to review this page periodically.

16. Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or to phonejoy's handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected] (subject: "Data Privacy Request")
• Live Chat: Available 24/7 on the phonejoy Platform — fastest response channel for general queries.

If you are not satisfied with phonejoy's handling of a data privacy matter, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). Details on how to file a complaint with the NPC can be found on the NPC's official website.