phroyale Privacy Policy

1. Overview

This Privacy Policy ("Policy") describes how phroyale ("we," "us," "our") collects, processes, stores, and protects the personal information of players and visitors who access the phroyale platform at phroyale.com ("the Platform"). This Policy applies to all users of the Platform, including registered players, prospective players, and visitors who browse without registering.

phroyale is committed to protecting your privacy in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its implementing rules and regulations. We are registered with the National Privacy Commission (NPC) as required by Philippine law.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy. By registering on or using phroyale, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2. Data We Collect

2.1 Registration Data

When you create a phroyale account, we collect the information you provide, including:

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Email address and mobile number
• Residential address (city, province, postal code)
• Username and encrypted password
• Preferred currency (Philippine Peso / ₱)

2.2 Identity Verification (KYC) Data

To comply with Philippine anti-money laundering regulations and to verify your identity and age, we may collect:

• Copies of government-issued identification (Philippine passport, driver's license, SSS/UMID card, PhilSys ID)
• Proof of address (utility bill, bank statement dated within 3 months)
• Selfie or live photo for identity matching
• Source of funds documentation where required by law

2.3 Financial Data

When you make deposits or request withdrawals, we collect transaction data including payment method details (GCash account reference, PayMaya reference, BPI/BDO/Metrobank account details), transaction amounts in PHP, timestamps, and transaction IDs. We do not store full bank account numbers or card numbers on our servers — these are handled by our certified payment processors.

2.4 Gaming Activity Data

We record your gaming activity on phroyale, including games played, wagers placed, outcomes, session durations, and bonus usage. This data is used for account management, responsible gaming monitoring, dispute resolution, and regulatory compliance.

2.5 Technical and Device Data

When you access phroyale, we automatically collect certain technical data, including:

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session timestamps and page interaction data
• Referral source (how you arrived at phroyale)

2.6 Communications Data

If you contact phroyale support via live chat or email, we retain records of those communications, including the content of messages, timestamps, and the resolution of any issues raised.

3. How We Use Your Data

phroyale uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your phroyale account, including processing deposits and withdrawals.
• Identity and Age Verification: To verify that you meet the 21+ age requirement and to confirm your identity as required by Philippine law.
• Regulatory Compliance: To comply with the Anti-Money Laundering Act (AMLA), PAGCOR regulations, the Data Privacy Act, and other applicable Philippine laws.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible Gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, and to enforce self-exclusion and limit requests.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze usage patterns and improve the phroyale platform, game selection, and user experience.
• Promotions and Bonuses: To administer bonuses and promotions you have opted into, and to communicate relevant offers where you have consented to receive them.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to when registering — including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with Philippine law, including AMLA reporting obligations, PAGCOR regulatory requirements, and NPC data protection obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional analytics, where you have given explicit consent. You may withdraw consent at any time.

5. Sharing Your Data

phroyale does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification services used to confirm your identity and age.
• Game Suppliers: Licensed game providers whose games are available on phroyale, to the extent required for game operation and fairness auditing.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where required by law or court order.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and fraud detection providers who process data on our behalf under strict data processing agreements.

All third parties with whom phroyale shares personal data are required to handle that data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose other than the specific service they provide to phroyale.

6. Data Retention

phroyale retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. Specific retention periods include:

• Account and KYC data: Retained for a minimum of 5 years after account closure, as required by Philippine AMLA regulations.
• Transaction records: Retained for a minimum of 5 years from the date of the transaction.
• Gaming activity logs: Retained for 3 years from the date of the session, or longer if required for dispute resolution or regulatory purposes.
• Support communications: Retained for 2 years from the date of the last communication.
• Marketing consent records: Retained until consent is withdrawn, plus 1 year thereafter for compliance documentation.

When data is no longer required, phroyale will securely delete or anonymize it in accordance with our data retention schedule.

7. Security

phroyale implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phroyale servers
• Encryption of sensitive data at rest, including KYC documents and payment references
• Multi-factor authentication options for player accounts
• Regular penetration testing and security audits by independent third parties
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• 24/7 automated fraud detection and anomaly monitoring

While phroyale takes all reasonable steps to protect your data, no electronic transmission or storage system is 100% secure. You are responsible for keeping your phroyale login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

8. Cookies and Tracking Technologies

phroyale uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyze usage patterns. The types of cookies we use include:

• Essential Cookies: Required for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and game lobby layout.
• Analytics Cookies: Collect anonymized data about how players use phroyale to help us improve the Platform. Used only with your consent.

You can manage your cookie preferences through your browser settings. Disabling essential cookies may affect the functionality of the Platform. phroyale does not use third-party advertising cookies or share cookie data with advertising networks.

9. Your Rights Under the Data Privacy Act

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phroyale:

• Right to be Informed: The right to know what personal data phroyale collects and how it is used — which this Policy fulfills.
• Right of Access: The right to request a copy of the personal data phroyale holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact phroyale's Data Protection Officer via the contact details in Section 13. We will respond to all verified requests within 15 business days in accordance with NPC guidelines.

10. Minors

phroyale is strictly for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under 21. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account, delete the data, and report the matter as required by applicable law.

If you believe that a minor has registered on phroyale, please contact us immediately at the address in Section 13.

11. International Data Transfers

phroyale's primary data processing infrastructure is located within the Philippines. Where data is transferred to service providers located outside the Philippines (for example, cloud infrastructure providers or game suppliers), phr oyale ensures that such transfers are subject to appropriate safeguards, including contractual clauses that require the recipient to protect your data to a standard equivalent to that required by Philippine law.

By using phroyale, you consent to the transfer of your personal data to third-party service providers outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

12. Policy Changes

phroyale may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. When we make material changes, we will post the revised Policy on this page with an updated effective date and, where appropriate, notify registered players via email or an in-platform notification.

Your continued use of phroyale following the posting of any changes constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how we protect your data.

13. Contact Us

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

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.