phrush Privacy Policy

1. Introduction

phrush ("we," "us," "our," or the "Company") is the operator of the online gaming platform accessible at phrush.lat (the "Platform"). We are committed to protecting the personal data of every player and visitor who interacts with phrush, and to processing that data transparently, lawfully, and fairly.

This Privacy Policy applies to all personal data processed by phrush in connection with the operation of the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and general use of phrush services. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.

We encourage Filipino players — whether you're logging in from Quezon City, Cebu, Davao, or anywhere else in the archipelago — to read this Policy carefully. It tells you exactly what phrush knows about you, why we know it, and what you can do about it.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, phrush is the personal information controller in respect of the personal data described in this Policy. Our designated Data Protection Officer (DPO) is responsible for overseeing our data protection practices and may be contacted via the support contact information provided in Section 14 of this Policy.

3. Personal Data We Collect

phrush collects the following categories of personal data, depending on the services you use:

4. How We Collect Your Data

phrush collects personal data through the following means:

• Direct provision: Data you provide when registering a phrush account, completing KYC verification, making a deposit or withdrawal, contacting support, or responding to surveys and promotions.
• Automated collection: Data collected automatically when you use the Platform, including through cookies, pixel tags, web beacons, and server logs. This includes your IP address, device identifiers, session duration, pages viewed, and in-game actions.
• Third-party sources: Data received from identity verification providers, payment processors (such as GCash and Maya), fraud detection services, and regulatory databases — for the purpose of verifying your identity and preventing financial crime.

5. Legal Basis for Processing

phrush processes your personal data on the following lawful grounds as recognised under the Philippine Data Privacy Act of 2012:

• Performance of contract: Processing is necessary to operate your phrush account, process transactions, and deliver the gaming services you have requested.
• Compliance with a legal obligation: Processing is required to comply with applicable Philippine laws, including Anti-Money Laundering Act (AMLA) obligations, PAGCOR regulatory requirements, and National Privacy Commission directives.
• Legitimate interests: Processing is necessary for phrush's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as marketing communications and non-essential cookies — phrush will seek your explicit consent, which you may withdraw at any time.

6. How We Use Your Personal Data

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

• Creating, managing, and securing your phrush account, including verifying your identity and age (21+) as required by Philippine gaming regulations.
• Processing deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported Philippine payment channels.
• Providing, maintaining, and improving the phrush gaming platform and all associated services.
• Detecting, preventing, and investigating fraud, money laundering, cheating, bonus abuse, and other prohibited conduct on the Platform.
• Monitoring gameplay patterns to identify potential problem gambling behaviour and fulfilling our responsible gaming obligations.
• Communicating with you regarding your account, transactions, support requests, and material changes to phrush policies.
• Sending marketing communications about phrush promotions, new games, and offers — where you have provided consent or where permitted under applicable law.
• Complying with reporting, record-keeping, and audit obligations imposed by PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine regulatory bodies.

7. Sharing Your Personal Data

phrush does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment service providers: GCash, Maya, BPI, BDO, Metrobank, and other payment processors through which your financial transactions are processed. These providers receive only the data necessary to process the specific transaction.
• Identity verification providers: KYC and document verification service providers who verify your identity and government-issued Philippine identification documents on phrush's behalf.
• Game content providers: Third-party game studios and live dealer operators whose games are available on the phrush Platform. Data shared is limited to session tokens and game-interaction data necessary to operate the game.
• Fraud prevention and security providers: Third-party services that assist phrush in detecting and preventing fraud, money laundering, and account compromise.
• Regulatory and law enforcement authorities: PAGCOR, AMLC, the National Privacy Commission, Philippine law enforcement agencies, and courts — where we are required or permitted to disclose personal data by applicable Philippine law or valid legal process.
• Professional advisers: Lawyers, auditors, and accountants engaged by phrush where disclosure is necessary for the conduct of their professional services, subject to professional confidentiality obligations.

All third parties with whom phrush shares personal data are required to process that data only in accordance with phrush's instructions and applicable Philippine law.

8. Cookies & Tracking Technologies

phrush uses cookies and similar tracking technologies on the Platform to ensure proper functionality, enhance your experience, and support analytics and fraud detection. The categories of cookies used are:

• Essential cookies: Necessary for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled without impairing Platform functionality.
• Analytics cookies: Used to collect aggregated information about how players interact with the phrush Platform — pages visited, time spent, error reports — to help us improve performance.
• Security cookies: Support fraud detection and account protection features, including login anomaly detection and device fingerprinting.
• Preference cookies: Remember your language and display settings to personalise your phrush experience.

You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect Platform functionality. Your continued use of the phrush Platform constitutes acceptance of our use of essential cookies.

9. Data Retention

phrush retains personal data for no longer than is necessary for the purposes for which it was collected, subject to applicable legal retention requirements. Our general retention periods are as follows:

• Account and transaction data: Retained for a minimum of five (5) years from the date of account closure, as required by Philippine AML regulations and PAGCOR record-keeping obligations.
• KYC and identity verification documents: Retained for five (5) years post-account closure.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained for as long as the consent remains valid and for three (3) years thereafter for audit purposes.

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

10. Data Security

phrush implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS 256-bit encryption for all data in transit between your device and phrush servers.
• Encryption of sensitive data fields (including payment details and government ID numbers) at rest in phrush databases.
• Role-based access controls ensuring that phrush staff can access personal data only to the extent required for their specific job function.
• Regular security audits and vulnerability assessments of phrush infrastructure and application code.
• Fraud and intrusion detection systems that monitor for anomalous access patterns and data exfiltration attempts.

In the event of a personal data breach that is likely to result in risk to the rights and freedoms of affected players, phrush will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay as required by the Data Privacy Act and NPC Circular No. 16-03.

11. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to the personal data that phrush holds about you:

• Right to be informed: The right to be notified of the manner in which your personal data is being, or will be, processed by phrush.
• Right to access: The right to obtain a copy of your personal data held by phrush and information about how it is being processed.
• Right to correct: The right to have inaccurate or incomplete personal data corrected. You may update most account information directly through your phrush account settings.
• Right to erasure / blocking: The right to request the deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, subject to applicable legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe that phrush has violated your rights under the Data Privacy Act.

To exercise any of the above rights, contact the phrush Data Protection Officer via Live Chat support or the email address displayed in the footer of this page. phrush will respond to all data subject requests within fifteen (15) business days of receipt.

12. Children's Privacy

The phrush Platform is strictly intended for individuals aged 21 years and above. phrush does not knowingly collect, process, or retain personal data from any individual below 21 years of age. If phrush becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the phrush Platform, please contact our support team immediately via Live Chat.

13. Changes to This Privacy Policy

phrush reserves the right to update or modify this Privacy Policy at any time. The revised Policy will be published on the phrush Platform with the updated effective date. Where changes are material, phrush will notify registered players by email or platform notification. Your continued use of the Platform following publication of the updated Policy constitutes your acceptance of those changes. We recommend reviewing this Policy periodically to stay informed of how phrush protects your personal data.

14. Contact & Complaints

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phrush, please contact our Data Protection Officer via Live Chat (available 24/7) or by email at the address displayed in the footer of this page. phrush will acknowledge receipt of your enquiry within two (2) business days and endeavour to resolve all matters within fifteen (15) business days.

If you are not satisfied with phrush's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through its official channels.