PhlRuby Privacy Policy

PhlRuby ("PhlRuby," "we," "us," "our") is committed to protecting the privacy and personal data of all users of the PhlRuby online gaming platform (the "Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, sharing, and protection of personal data in connection with your use of the Platform.

This Privacy Policy applies to all personal data collected through the PhlRuby website at phlruby.one, the PhlRuby mobile application, and any related services, features, or communications. It should be read together with our Terms & Conditions and Responsible Gaming Policy.

By registering for an account or using the PhlRuby 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 Privacy Policy, you must not use the Platform.

PhlRuby operates in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as well as applicable PAGCOR data governance requirements.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, the data controller responsible for your personal information is:

PhlRuby has appointed a Data Protection Officer (DPO) as required under the Data Privacy Act. The DPO is responsible for overseeing PhlRuby's data protection strategy and ensuring compliance with applicable privacy laws. You may contact the DPO directly at [email protected] for any privacy-related concerns.

PhlRuby collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include:

PhlRuby collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from government-accredited KYC providers; payment data from GCash, PayMaya, BPI, BDO, and Metrobank; fraud detection signals from our security partners.
• Regulatory sources: Information shared by PAGCOR or other Philippine regulatory authorities in connection with our licensing and compliance obligations.

All data collection is conducted transparently and in accordance with the principles of the Data Privacy Act of 2012. You will always be informed of the purpose of data collection at the point of collection.

PhlRuby uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your PhlRuby account, including password resets and login verification.
• Identity and age verification: Confirming that you meet the 21+ age requirement and verifying your identity as required by PAGCOR and anti-money laundering regulations.
• Transaction processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Game delivery: Providing access to PhlRuby games including Jackpot Fishing, Go Rush, Relax Fishing, Super Keno, and the Daily Wheel, and maintaining accurate game records.
• Promotions and bonuses: Administering promotional offers, verifying eligibility, and crediting bonus rewards to your account.
• Customer support: Responding to your inquiries, resolving disputes, and improving our support services.
• Security and fraud prevention: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering self-exclusion and limit-setting tools.
• Legal and regulatory compliance: Meeting our obligations under PAGCOR regulations, the Data Privacy Act, the Anti-Money Laundering Act, and other applicable Philippine laws.
• Platform improvement: Analyzing usage patterns to improve the PhlRuby Platform's performance, features, and user experience.
• Communications: Sending you account notifications, security alerts, and — where you have opted in — promotional communications about PhlRuby offers.

PhlRuby will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

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

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your PhlRuby account, process transactions, and deliver gaming services.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws and regulations.
• Legitimate interests: Processing necessary for PhlRuby's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — for example, for optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

PhlRuby does not sell, rent, or trade your personal data to any third party. We may share your personal data only in the following limited circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your financial transactions.
• Identity verification providers: Accredited KYC and age verification service providers engaged to verify your identity and confirm you meet the 21+ age requirement.
• Fraud and security partners: Third-party fraud detection and cybersecurity providers who assist PhlRuby in protecting the Platform and its users.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory mandate.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process.
• Professional advisors: Legal counsel, auditors, and other professional advisors engaged by PhlRuby, subject to strict confidentiality obligations.

PhlRuby does not transfer personal data outside the Philippines except where strictly necessary for the operation of the Platform and subject to appropriate data transfer safeguards as required by the NPC.

PhlRuby retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

Upon expiry of the applicable retention period, PhlRuby will securely delete or anonymize your personal data in accordance with NPC-approved data disposal procedures.

PhlRuby implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and PhlRuby servers is encrypted using TLS 1.2 or higher. Sensitive data at rest is encrypted using AES-256.
• Access controls: Personal data is accessible only to PhlRuby personnel who require it to perform their job functions, subject to role-based access controls and multi-factor authentication.
• Network security: PhlRuby's infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and regular penetration testing.
• Secure development: PhlRuby follows secure software development lifecycle (SDLC) practices, including regular code reviews and vulnerability assessments.
• Incident response: PhlRuby maintains a documented data breach response plan. In the event of a personal data breach, we will notify affected users and the NPC within the timeframes required by the Data Privacy Act.
• Staff training: All PhlRuby personnel with access to personal data receive regular data privacy and security training.

PhlRuby uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. We use the following types of cookies:

• Essential cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game display options to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the Platform — such as which pages are visited most frequently — to help us improve performance and user experience. PhlRuby uses only first-party analytics tools.
• Security cookies: Help detect and prevent fraudulent activity, unauthorized logins, and bot traffic.

PhlRuby does not use third-party advertising cookies or behavioral tracking cookies. You can manage or delete cookies through your browser settings at any time. Please note that disabling essential cookies may affect the functionality of the Platform.

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

• Right to be informed: The right to know what personal data PhlRuby collects about you, how it is used, and with whom it is shared.
• Right of access: The right to request a copy of the personal data PhlRuby holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our 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 and to transmit it to another data controller.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge 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 submit a written request to our Data Protection Officer at [email protected]. PhlRuby will respond to all data subject requests within 15 business days of receipt. We may request proof of identity before processing your request to protect against unauthorized access to your data.

PhlRuby employs mandatory age verification procedures during the registration process to prevent underage access. If PhlRuby becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the relevant account, delete the associated personal data, and report the incident to PAGCOR as required.

If you are a parent or guardian and believe that your child under the age of 21 has registered on the PhlRuby Platform, please contact us immediately at [email protected] so that we can take prompt action.

PhlRuby reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email and/or in-platform notification at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. Your continued use of the PhlRuby Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We recommend reviewing this Privacy Policy periodically to stay informed about how PhlRuby protects your personal data. If you have any concerns about a change to this policy, please contact our DPO before continuing to use the Platform.

For any questions, concerns, or requests relating to this Privacy Policy or PhlRuby's data processing practices, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly 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 their official government channels.