phingo Privacy Policy

1Who We Are — The Data Controller

phingo ("phingo," "we," "us," "our") is the data controller responsible for the personal information collected through the phingo platform at phingo.co. As the data controller, phingo determines the purposes and means of processing your personal data, and bears the corresponding obligations under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

phingo operates as an online gaming platform providing JILI slots, live dealer games, sports betting, sabong, bingo, and related services to registered players in the Philippines. All data processing activities described in this Privacy Policy are carried out in connection with the provision of these services.

phingo has designated a Data Protection Officer (DPO) responsible for overseeing compliance with data protection obligations. Contact details for the phingo DPO are provided in Section 14 of this Policy.

2Personal Data We Collect

phingo collects the following categories of personal data in connection with your registration, use of the platform, and compliance with applicable regulatory requirements:

2.1 Registration and Identity Data

When you create a phingo account, we collect: your full legal name, date of birth, Philippine mobile number, and the password you create. This information is necessary to establish your account and verify your eligibility to use the phingo platform.

2.2 Identity Verification (KYC) Data

Prior to processing withdrawal requests, phingo is required to verify your identity in accordance with applicable regulations. We collect copies of Philippine government-issued identification documents — which may include your UMID, PhilHealth ID, SSS ID, passport, or driver's licence — together with any supplementary documentation requested for source-of-funds verification.

2.3 Financial and Transaction Data

phingo collects and retains data related to all financial transactions conducted on the platform, including: deposit amounts and timestamps, withdrawal amounts and payment method details (GCash account number, PayMaya details, BPI/BDO/Metrobank account references), bonus fund activity, and your complete transaction history across all game categories.

2.4 Gaming Activity Data

phingo maintains a record of your gaming activity, including: games played, wager amounts, win and loss outcomes per session, bonus wagering progress, and time spent on the platform. This data is used for account management, responsible gaming monitoring, regulatory reporting, and game improvement purposes.

2.5 Technical and Device Data

When you access phingo, we automatically collect technical data including: your IP address, device type and operating system, browser type and version, mobile carrier (e.g., Globe, Smart, DITO), session timestamps, and crash and error logs. This data helps phingo maintain platform security and improve the player experience on Philippine mobile devices.

2.6 Communications Data

If you contact phingo via live chat, email, or any other support channel, we retain records of those communications — including the content of your messages and our responses — for quality assurance, dispute resolution, and training purposes.

3How We Collect Your Personal Data

phingo collects personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion;
• Automatically through the platform — when you access phingo, our servers and analytics systems automatically log technical and behavioural data as described in Section 2.5;
• From payment service providers — when you initiate a deposit or withdrawal via GCash, PayMaya, BPI, BDO, or Metrobank, those providers share the minimum transactional data necessary to process and confirm the payment;
• From identity verification services — phingo may use third-party KYC verification tools to confirm the authenticity of identity documents you submit during the verification process;
• From fraud prevention and security services — phingo uses risk assessment tools that process technical data to detect unusual login patterns, potential fraudulent activity, and account security threats.

4Why We Use Your Personal Data

phingo uses the personal data it collects for the following purposes:

• Account creation and management: To establish, operate, and maintain your phingo account, including authentication of logins, processing of deposits and withdrawals, and management of your account settings;
• Identity verification and KYC compliance: To verify your age (minimum 21 years), confirm your identity prior to withdrawal processing, and satisfy anti-money laundering obligations;
• Delivery of gaming services: To provide access to the games, sports betting markets, live dealer tables, and other services available on the phingo platform;
• Financial transaction processing: To process, record, and reconcile all deposits and withdrawals conducted through your phingo wallet, including GCash and PayMaya transactions;
• Regulatory compliance: To satisfy obligations under the Philippine Data Privacy Act, PAGCOR regulatory requirements, Anti-Money Laundering Act (AMLA) provisions, and other applicable Philippine laws;
• Responsible gaming monitoring: To monitor gaming activity for signs of problem gambling, enforce deposit and loss limits set by the player, and administer cooling-off and self-exclusion requests;
• Security and fraud prevention: To detect and prevent unauthorised access to accounts, fraudulent transactions, multi-accounting, bonus abuse, and other platform security threats;
• Customer support: To respond to your inquiries, resolve complaints, and provide account assistance through phingo's 24/7 live chat and email support channels;
• Platform improvement: To analyse aggregate usage patterns, identify technical issues, and improve the phingo platform's performance, especially on Philippine mobile devices and network conditions;
• Marketing communications (with consent): To send you promotional offers, bonus notifications, and platform news where you have provided explicit consent to receive such communications. You may withdraw this consent at any time from your account notification settings.

5Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), phingo processes your personal data on the following legal bases:

• Performance of a contract: The majority of data processing described in this Policy is necessary for phingo to fulfil its obligations under the Terms & Conditions you agreed to when registering — i.e., providing gaming services, processing payments, and managing your account;
• Legal obligation: Processing required to comply with applicable Philippine laws, including KYC obligations under AMLA, age verification under PAGCOR regulations, and tax reporting requirements;
• Legitimate interests: Processing conducted for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics — where phingo's legitimate interests are not overridden by your right to privacy;
• Consent: Where phingo sends you promotional communications or deploys non-essential tracking cookies, we will seek your explicit consent and provide a clear mechanism to withdraw that consent at any time.

6Sharing Your Personal Data

phingo does not sell, rent, or trade your personal information to third-party advertisers, data brokers, or marketing organisations. Your personal data is shared only in the following limited circumstances:

• Payment service providers: GCash (GXI), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank receive the minimum transaction data necessary to process deposits and withdrawals on your behalf;
• Identity verification providers: Third-party KYC service providers process your government-issued identification documents solely for the purpose of verifying your identity during the phingo account verification process;
• Game content providers: Game providers such as JILI, Pragmatic Play, and Evolution receive anonymised session data necessary to render games, calculate outcomes, and process in-game transactions. Game providers do not receive your full personal profile;
• Regulatory and law enforcement authorities: phingo is required by Philippine law to share certain data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies where legally mandated — including in response to valid legal process or where phingo is obligated to report suspicious financial activity;
• Fraud prevention and security services: Third-party risk and fraud detection tools process technical data (e.g., IP addresses, device fingerprints) to identify account security threats. These providers are bound by confidentiality agreements and may not use this data for their own purposes;
• Corporate transactions: In the event of a merger, acquisition, restructuring, or sale of phingo's business or assets, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

All third parties with whom phingo shares personal data are required to process that data in accordance with applicable Philippine data protection laws and phingo's data processing agreements. phingo does not authorise third parties to use your personal data for their own independent commercial purposes.

7Data Retention

phingo retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve any disputes that may arise. The following general retention periods apply:

• Account data and gaming history: Retained for the duration of your active phingo account and for a minimum of five (5) years following account closure, as required by applicable Philippine regulations;
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure, in compliance with AMLA retention requirements;
• Financial transaction records: Retained for a minimum of five (5) years, consistent with Philippine financial record-keeping obligations;
• Customer support communications: Retained for two (2) years from the date of the communication, or longer where the communication is relevant to an ongoing dispute or regulatory inquiry;
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year to demonstrate compliance history;
• Technical and device logs: Retained for up to twelve (12) months for security and platform improvement purposes, after which they are deleted or anonymised.

Upon expiry of the applicable retention period, phingo will securely delete or anonymise your personal data so that it can no longer be associated with your identity, unless continued retention is required by a specific legal obligation.

8Security Measures

phingo implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phingo platform;
• Encryption of sensitive data at rest, including financial records and KYC documents;
• Role-based access controls limiting access to personal data to authorised phingo personnel with a legitimate operational need;
• Two-factor authentication (2FA) options for player accounts as an additional security layer;
• Automated fraud detection systems monitoring login activity and transaction patterns for unusual behaviour;
• Regular security assessments and penetration testing of the phingo platform;
• Staff training on data protection obligations and secure data handling practices.

9Cookies and Tracking Technologies

The phingo platform uses cookies and similar tracking technologies to provide core platform functionality, enhance the player experience, and analyse usage patterns. The following categories of cookies are used:

• Essential cookies: Required for core platform functionality, including maintaining your login session, securing your account, and processing transactions. Essential cookies cannot be disabled without preventing you from using phingo;
• Performance cookies: Collect anonymised data on how players use the phingo platform — pages visited, features used, error encounters — to help phingo improve platform performance and identify technical issues;
• Functionality cookies: Remember your preferences and settings (e.g., language preference, notification settings) to provide a more personalised experience when you return to phingo;
• Analytics cookies: Used to analyse aggregate player behaviour on the phingo platform. phingo uses privacy-compliant analytics tools that do not share individual player data with third parties for commercial purposes.

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies will impair the core functionality of the phingo platform and may prevent you from logging in or accessing your account. Non-essential cookie preferences can be managed at any time without affecting core platform access.

10Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to the personal data phingo holds about you. phingo is committed to honouring these rights promptly and without unnecessary obstacles.

To exercise any of the above rights, contact phingo's Data Protection Officer via email at [email protected] with the subject line "Data Privacy Request." Please include your registered phingo mobile number and a clear description of the right you wish to exercise. phingo will acknowledge your request within 3 business days and will respond substantively within 30 days of receipt, or within such longer period as permitted by applicable law for complex requests. phingo may ask you to verify your identity before processing a data subject rights request to protect against fraudulent access to your personal information.

11Children's Privacy

The phingo platform is strictly intended for adults aged 21 years and older, in accordance with Philippine law and PAGCOR regulations governing real-money online gaming. phingo does not knowingly collect personal data from individuals under the age of 21. Age is verified during the phingo registration process, and identity verification documents are reviewed to confirm that all registered players meet the minimum age requirement.

If phingo becomes aware that personal data has been collected from an individual under the age of 21 — through misrepresentation, circumvention of the registration process, or any other means — phingo will immediately suspend the relevant account, delete the associated personal data in accordance with its regulatory obligations, and report the matter to appropriate authorities where required by law. Parents or guardians who believe a minor may have registered on phingo are urged to contact phingo support immediately via live chat.

12International Data Transfers

The phingo platform's primary data infrastructure is operated within or in connection with the Philippines. Where phingo uses third-party service providers — such as game content providers, KYC verification services, or fraud prevention tools — that are located outside the Philippines, personal data may be transferred to servers or processing facilities in other jurisdictions.

phingo ensures that any international transfer of personal data is subject to appropriate safeguards consistent with the requirements of the Philippine Data Privacy Act, including the execution of data processing agreements with all relevant third parties that impose obligations equivalent to those applicable under Philippine law. phingo does not transfer personal data to jurisdictions that do not offer an adequate level of data protection without implementing appropriate contractual safeguards.

13Changes to This Privacy Policy

phingo reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made — particularly those that affect your rights or the way phingo uses your personal data — phingo will notify you via your registered Philippine mobile number or through a prominent notice on the phingo platform, with at least 14 days' advance notice before the changes take effect.

The effective date at the top of this Privacy Policy will be updated to reflect the date on which the latest version came into force. We encourage you to review this page periodically to stay informed about how phingo protects your personal data. The current version of this Privacy Policy is always accessible at phingo.co/privacy-policy. Your continued use of the phingo platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes.

14Contact & Data Protection Officer

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

• Email: [email protected] — please use the subject line "Data Privacy Request" for all data protection matters
• Live Chat: Available 24/7 via the phingo platform — Filipino-English speaking agents are available at all hours
• Response Time: phingo acknowledges all data protection inquiries within 3 business days and provides substantive responses within 30 days

If you are not satisfied with phingo's response to your data protection concern, or if you believe that phingo has not complied with its obligations under the Philippine Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about how to file a complaint with the NPC is available through official Philippine government channels.