This Privacy Policy explains how phrush collects, uses, stores, and protects your personal information. As a PAGCOR-licensed online gaming operator serving Filipino players, phrush complies with the Philippine Data Privacy Act of 2012 and all applicable regulations from the National Privacy Commission.
phrush ("phrush," "we," "us," "our") is the operator of the online gaming platform accessible at phrush.biz (the "Platform"). phrush is a PAGCOR-licensed online gaming operator duly authorized to provide casino games, sports betting, bingo, e-sports wagering, and related services to eligible players within the Philippines.
This Privacy Policy ("Policy") describes how phrush collects, processes, uses, stores, shares, and protects personal data relating to individuals who access or use the Platform ("you," "Player," "User"). This Policy applies to all personal data collected through the phrush website, in-platform interactions, customer support communications, payment processing, and identity verification procedures.
Key Point: By registering an account on the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not access or use the Platform.
This Policy should be read in conjunction with the phrush Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference into the overall regulatory and contractual framework governing your use of the Platform.
For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations ("DPA"), phrush acts as the Personal Information Controller (PIC) with respect to the personal data of Players collected through the Platform.
As PIC, phrush determines the purpose and means of processing your personal data and is responsible for ensuring that all processing activities comply with the DPA, the regulations of the National Privacy Commission (NPC), and applicable PAGCOR data governance requirements.
Data Protection Officer: phrush has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the DPA. Players may contact the DPO via the support channels listed in Section 16 of this Policy.
phrush collects various categories of personal data depending on the nature of your interaction with the Platform. The following table sets out the principal categories of personal data collected:
| Category | Examples of Data Collected | When Collected |
|---|---|---|
| Registration Data | Full legal name, date of birth, Philippine mobile number, email address, account username, password (hashed) | Account registration |
| Identity Verification (KYC) | Government-issued Philippine ID type and number, photographic ID image, selfie image, proof of address document | Prior to first withdrawal; enhanced due diligence |
| Financial Data | GCash number, Maya account, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records | Deposit and withdrawal processing |
| Gameplay Data | Game sessions, Wager amounts, wins and losses, game preferences, betting history, bonus usage, session duration | During Platform use |
| Technical Data | IP address, device type and identifiers, browser type and version, operating system, referring URL, access timestamps | Each Platform visit |
| Communications Data | Live chat transcripts, email correspondence, support ticket content, feedback submissions | Customer support interactions |
| Responsible Gaming Data | Deposit limits set, loss limits set, self-exclusion status, cooling-off periods, session time limits | When responsible gaming tools are used |
Under the DPA, certain categories of personal data are classified as Sensitive Personal Information (SPI) and require heightened protection. phrush may collect government-issued identification numbers (e.g., Philippine National ID, Passport, SSS, TIN) as part of the mandatory KYC process. This SPI is collected solely for identity verification, age confirmation, and regulatory compliance purposes. phrush does not collect biometric data, health information, or political affiliations in the ordinary course of Platform operations.
Certain data collection is optional. For example, Players are not required to provide a profile photograph or contact address beyond what is required for KYC. However, failure to provide mandatory registration and KYC data will result in inability to register an account or process withdrawals.
phrush collects personal data through the following means:
phrush processes your personal data on the following legal bases as provided under the DPA and its Implementing Rules:
phrush uses the personal data it collects for the following purposes:
To create and maintain your phrush account, authenticate your identity at login, manage your account settings and preferences, and communicate with you about account-related matters including security alerts, transaction confirmations, and verification requests.
To process your deposits and withdrawals through GCash, Maya, BPI, BDO, Metrobank, and other accepted payment channels. Financial data is shared with payment processors only to the extent necessary to complete transactions. phrush does not store complete bank account credentials on its servers.
To verify that you meet the 21+ age requirement and other eligibility criteria, to comply with KYC obligations under Philippine anti-money laundering law, to perform source-of-funds checks where required, and to maintain records as required by PAGCOR licensing conditions and the DPA.
To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, Bonus abuse, and other prohibited conduct. Technical data including IP address, device identifiers, and session behavior is used for fraud detection and security monitoring. phrush uses automated and manual review processes for this purpose.
To enforce the phrush responsible gaming framework, including monitoring gameplay patterns for indicators of problem gambling, communicating with Players about responsible gaming tools and limits, administering self-exclusions, and complying with PAGCOR responsible gaming requirements.
To analyze aggregate and anonymized usage patterns, improve the Platform's performance, user experience, and game catalog, and to conduct market research. Where possible, phrush uses anonymized or pseudonymized data for analytics purposes to minimize privacy impact.
With your explicit opt-in consent, to send you promotional communications about phrush bonuses, new game launches, sports betting promotions, and platform updates. You may withdraw your consent to marketing communications at any time by updating your account notification preferences or contacting support.
To establish, exercise, or defend phrush's legal rights; to respond to regulatory inquiries from PAGCOR, the NPC, and other Philippine authorities; and to cooperate with law enforcement investigations as required by applicable Philippine law.
phrush does not sell your personal data to third parties for their independent commercial purposes. phrush shares personal data only in the following circumstances:
phrush engages third-party service providers who process personal data on phrush's behalf as Personal Information Processors (PIPs) under the DPA. These include payment processors (GCash/Maya/BPI/BDO), identity verification providers, cloud hosting providers, fraud detection services, and customer support infrastructure providers. All PIPs are contractually required to maintain appropriate security standards and to process data only for the purposes authorized by phrush.
Game providers whose titles are featured on the phrush Platform may receive limited anonymized or pseudonymized session and gameplay data to support game functionality, RTP verification, and fair play auditing. Identifiable personal data is not shared with game providers for marketing or commercial purposes.
phrush is required by Philippine law to share certain Player data with PAGCOR and, where applicable, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other relevant government bodies. This sharing is mandatory and does not require your separate consent. phrush will not share more data than is required by the applicable legal obligation.
phrush will disclose personal data to Philippine law enforcement authorities where required to do so by a valid court order, warrant, or other lawful legal process. phrush will, where permitted by law, notify you of such disclosures.
In the event that phrush's business or Platform assets are acquired by a successor entity, personal data held by phrush may be transferred as part of that transaction. You will be notified of any such transfer and the data protection obligations of the acquiring entity in advance of any transfer affecting your personal data.
phrush uses cookies and similar tracking technologies on the Platform for the following purposes:
Non-essential cookies (functional and analytics) can be managed through your browser's cookie settings. Disabling cookies may affect Platform functionality — some features including game lobby personalization and session state management rely on functional cookies. For guidance on managing cookies in your specific browser, refer to your browser's help documentation. phrush does not serve third-party advertising cookies on the Platform.
phrush retains personal data for the periods necessary to fulfill the purposes described in this Policy, subject to the following minimum retention requirements:
At the end of applicable retention periods, personal data is securely deleted or anonymized so that it can no longer be linked to an identifiable individual.
phrush implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:
Data Breach Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phrush will notify the NPC within seventy-two (72) hours of becoming aware of the breach and will notify affected Players without undue delay, as required by the DPA and NPC Circular No. 16-03.
As a data subject under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by phrush. To exercise any of these rights, contact phrush through the channels listed in Section 16.
The phrush Platform is strictly intended for persons who are at least twenty-one (21) years of age, as mandated by PAGCOR for online casino and sports betting services in the Philippines. phrush does not knowingly collect personal data from individuals under the age of 21.
phrush enforces the 21+ age requirement through mandatory KYC identity verification. Where phrush discovers that personal data has been collected from an individual who is under 21 at the time of collection, phrush will immediately suspend the associated account, notify the individual, void any Wagers placed, and securely delete or anonymize the personal data concerned, except where retention is required by law.
If you become aware that a person under 21 has registered an account on the phrush Platform, please notify phrush support immediately so that appropriate action can be taken.
phrush primarily stores and processes personal data within the Philippines and on servers located in jurisdictions with adequate data protection standards. In certain circumstances — including where phrush uses cloud infrastructure, game providers, or fraud detection services based outside the Philippines — personal data may be transferred to, stored in, or processed in jurisdictions outside the Philippines.
Where such transfers occur, phrush implements appropriate safeguards to ensure that the transferred data receives a level of protection equivalent to that provided under the Philippine DPA. These safeguards may include:
By using the Platform, you acknowledge that your personal data may be transferred outside the Philippines on the basis of the safeguards described above.
The phrush Platform may reference third-party services in the context of payment methods (GCash, Maya, BPI, BDO) and game providers. phrush is not responsible for the privacy practices of these third-party services. When you interact with third-party payment systems — for example, when completing a GCash deposit authorization through the GCash app — you are subject to GCash's own privacy policy and terms of service.
phrush does not control how third-party payment processors or game providers handle data that you provide directly to them through their own interfaces. phrush encourages you to review the privacy policies of any third-party service you use in connection with the Platform.
phrush may update this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR regulatory requirements, NPC guidance, Platform functionality, or data processing practices. The effective date at the top of this document reflects the date of the most recent revision.
Material changes to this Policy — for example, changes to the categories of data collected, the purposes for which data is used, or the third parties with whom data is shared — will be communicated to registered Players via email to the registered account address or via a prominent notice on the Platform at least fourteen (14) days before the change takes effect.
Continued use of the Platform after the effective date of any amended Policy constitutes your acceptance of the revised terms. If you do not accept the amended Policy, you must cease using the Platform and request account closure.
For questions, requests to exercise your data subject rights, or concerns about how phrush handles your personal data, please contact us through the following channels:
phrush will acknowledge receipt of a formal data subject rights request within five (5) business days and will respond substantively within the timeframes prescribed by the DPA — generally within thirty (30) calendar days of receipt, or fifteen (15) days for correction and access requests.
If you are not satisfied with phrush's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government body responsible for enforcing the Data Privacy Act and investigating complaints against Personal Information Controllers. Contact information for the NPC is publicly available through official Philippine government resources.
Note: phrush encourages Players to contact phrush directly in the first instance so that we have the opportunity to address concerns before escalating to the NPC. Our Data Protection Officer and support team are available to assist with all data privacy queries.
As a registered phrush Player and a data subject under Republic Act No. 10173, you have enforceable rights over the personal data phrush holds about you. Here is a plain-language summary of each right and how to exercise it.
You have the right to request a copy of the personal data phrush holds about you and information about how that data is being used. Submit your access request via Live Chat or by email with "Data Access Request" in the subject line. phrush will respond within 15 days of receiving a complete request.
If any personal data phrush holds about you is inaccurate, incomplete, or outdated, you have the right to request correction. For registration data such as your name or mobile number, corrections must be verified by the phrush compliance team using supporting documentation before they take effect.
You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where the data has been unlawfully processed. This right is subject to phrush's legal obligations to retain certain data under Philippine law — including AML record-keeping requirements — which take precedence.
You have the right to object to the processing of your personal data for marketing purposes at any time. You may also object to processing based on legitimate interests where you have grounds relating to your particular situation. Marketing opt-out can be actioned instantly through your account notification settings — no support ticket required.
Where processing is based on your consent or on a contract, and processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format. phrush can provide a data export in JSON or CSV format upon request. This right does not apply to data derived through our analysis and processing.
If you believe phrush has handled your personal data in a manner inconsistent with the Philippine Data Privacy Act, you have the right to lodge a complaint with phrush's Data Protection Officer or directly with the National Privacy Commission. phrush is committed to resolving all data privacy concerns raised by Filipino players promptly and transparently.
For the protection of all Players, phrush verifies your identity before acting on any data subject rights request. This prevents unauthorized third parties from accessing or modifying your personal data by impersonating you. Identity verification for rights requests follows the same KYC standards applied to withdrawal processing.
phrush acknowledges all rights requests within five (5) business days. Substantive responses are provided within fifteen (15) days for access and correction requests, and within thirty (30) days for deletion, portability, and objection requests. Where a request is complex or involves large volumes of data, phrush may extend the response period by a further thirty (30) days, notifying you of the extension before the initial period expires.
Certain rights are subject to limitations under Philippine law. phrush may decline an erasure request where retention is required for compliance with anti-money laundering or PAGCOR record-keeping obligations. Where phrush declines to act on a request, it will explain the reason in writing and inform you of your right to raise a complaint with the NPC.
phrush is committed to keeping your personal data secure under Philippine law. Join over a million Filipino players on a PAGCOR-licensed platform that takes privacy, security, and responsible gaming as seriously as it takes great games. Must be 21 or older to register.
PAGCOR-Licensed Online Gaming Operator. Data protected under RA 10173. 21+ only. Philippines only.