phyaya Privacy Policy

1. Introduction

phyaya ("phyaya," "we," "us," "our") operates the online gaming platform accessible at phyaya.org and all associated mobile applications and services. We are the data controller responsible for the personal information you provide when using the phyaya platform.

This Privacy Policy ("Policy") describes how phyaya collects, processes, stores, shares, and protects the personal data of players, visitors, and any other individuals who interact with phyaya's services. This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

By creating a phyaya account, making a deposit, or using any phyaya service, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree to this Policy, please do not use phyaya.

2. Personal Data We Collect

phyaya collects personal data through several channels: directly from you during account registration and ongoing use, automatically through your interactions with our platform, and from third parties where permitted by law.

Information You Provide Directly:

• Full legal name and date of birth
• Philippine mobile number and email address
• Government-issued ID details (for KYC verification)
• Billing and payment information (GCash number, bank account details for withdrawals)
• Residential address (where required for identity verification)
• Customer support communications — chat transcripts, email correspondence
• Voluntary survey or feedback responses

Information Collected Automatically:

• IP address, device type, operating system, and browser version
• Login timestamps and session duration records
• Game history, wagering records, and betting activity logs
• Deposit and withdrawal transaction records
• Platform interaction data (pages visited, features used, navigation paths)
• Cookie and tracking technology data (see Section 6)

3. How We Use Your Personal Data

phyaya uses the personal data we collect for the following purposes:

• Account Management: Creating, maintaining, and verifying your phyaya player account.
• Identity Verification (KYC): Fulfilling our legal obligations to verify player identity, age (21+), and eligibility to use phyaya.
• Transaction Processing: Processing deposits, withdrawals, and bonus payments via GCash, PayMaya, and other supported payment channels.
• Platform Personalization: Customizing game recommendations and promotional offers based on your gameplay preferences and account history.
• Customer Support: Responding to inquiries, complaints, and account-related requests submitted to our support team.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct.
• Legal & Regulatory Compliance: Meeting obligations under the Data Privacy Act, anti-money laundering regulations, and any requirements imposed by PAGCOR or other competent Philippine authorities.
• Marketing Communications: Sending promotional offers, bonus notifications, and product updates where you have consented to receive such communications. You may opt out at any time.
• Analytics & Improvement: Analysing platform usage patterns to improve phyaya's features, performance, and user experience.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, phyaya relies on the following legal bases for processing your personal data:

• Contractual Necessity: Processing required to perform the phyaya player agreement — including account creation, game access, and payment processing.
• Compliance with a Legal Obligation: KYC/AML verification, age verification, regulatory reporting, and fraud investigation as required under Philippine law.
• Legitimate Interests: Fraud detection, platform security monitoring, and service improvement, where these interests do not override your privacy rights.
• Consent: Marketing communications and optional personalization features, where we rely on your freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

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

• Game Providers: JILI and other licensed game suppliers may receive limited transactional data necessary to deliver game services and certify fairness outcomes.
• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners receive financial data necessary to execute deposit and withdrawal transactions.
• KYC/AML Service Providers: Third-party identity verification providers assist phyaya in fulfilling regulatory verification obligations.
• Legal & Regulatory Authorities: phyaya will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, or courts when required by law or a valid legal order.
• Corporate Transactions: In the event of a merger, acquisition, or sale of phyaya's business, personal data may be transferred to the successor entity, subject to equivalent privacy protections.

All third-party processors engaged by phyaya are contractually bound to process personal data only as instructed and to implement appropriate security measures.

6. Cookies & Tracking Technologies

phyaya uses cookies and similar tracking technologies to operate and improve the platform. The cookie categories we use are:

• Strictly Necessary Cookies: Essential for platform functionality — login sessions, security tokens, and player authentication. These cannot be disabled.
• Performance & Analytics Cookies: Collect anonymized data about how players use phyaya to identify performance issues and improve the user experience. Data is aggregated and not linked to individual identities.
• Functional Cookies: Remember your preferences such as language settings and game lobby filters to provide a personalized experience.
• Marketing Cookies: Used to deliver relevant promotions to your phyaya account. Only activated with your consent.

You may manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect platform functionality.

7. Data Security

phyaya implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phyaya servers.
• Salted hashing for stored passwords — phyaya staff cannot view your password in plaintext.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits and penetration testing by independent security professionals.
• Two-factor authentication available for account access.
• Automated intrusion detection systems monitoring for suspicious activity.

8. Data Retention

phyaya retains personal data for only as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. Our general retention periods are:

• Active Account Data: Retained for the duration of your phyaya account and for a minimum of 5 years after account closure, as required by Philippine AML regulations.
• KYC Documents: Retained for a minimum of 5 years following the end of the business relationship, per AMLC requirements.
• Transaction Records: Retained for 5 years in compliance with anti-money laundering and financial record-keeping obligations.
• Customer Support Records: Retained for 2 years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained until consent is withdrawn, plus a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, phyaya will securely delete or anonymize your personal data.

9. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phyaya:

• Right to Be Informed: You have the right to know how phyaya collects and processes your personal data — which this Policy fulfills.
• Right of Access: You may request a copy of the personal data phyaya holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data in your phyaya account.
• Right to Erasure: You may request deletion of your personal data in circumstances where retention is no longer legally required. Note that certain data must be retained for AML and regulatory compliance purposes.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: You may request a structured, machine-readable copy of personal data you have provided to phyaya.
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission if you believe phyaya has processed your data unlawfully.

To exercise any of these rights, contact our Data Protection Officer at: [email protected] (plain text — not a clickable link). We will respond to verified requests within 30 days.

10. Children's Privacy

phyaya is strictly an adults-only platform. We do not knowingly collect personal data from individuals under 21 years of age. If phyaya determines that personal data has been collected from an underage individual, we will immediately delete that data and close the associated account.

Parents and guardians who believe their child has registered on phyaya should contact our support team immediately. phyaya will investigate and take appropriate action within 24 hours of receiving a verified report.

11. International Data Transfers

phyaya's primary operations are based in the Philippines. In certain circumstances, personal data may be processed by game providers, payment processors, or technology infrastructure partners located outside the Philippines.

Where such international transfers occur, phyaya ensures that adequate safeguards are in place, including contractual data processing agreements that obligate receiving parties to apply protection standards equivalent to those required by Philippine law. phyaya does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual safeguards.

12. Changes to This Privacy Policy

phyaya reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will notify active players via a prominent notice on the phyaya platform and, where required by law, seek fresh consent for any new processing activities.

The date of the most recent revision is displayed at the top of this page. Your continued use of phyaya following any update to this Policy constitutes your acknowledgment of the revised terms. We encourage you to review this Policy periodically to stay informed about how phyaya protects your information.

13. Contact Our Data Protection Officer

phyaya has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have questions, concerns, or requests related to your personal data, please contact the phyaya DPO:

Data Protection Officer
phyaya — phyaya.org
Email: [email protected] (plain text — not a clickable link)
Response Time: Within 5 business days for general inquiries; within 30 days for formal rights requests.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your privacy rights have been violated.