Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how ph.modern ("ph.modern," "We," "Us," "the Platform") collects, uses, stores, shares, and protects the personal data of users ("Player," "You," "Data Subject") who access and use the ph.modern online gaming platform at phmodern.lat.

ph.modern operates as a personal information controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. We take our obligations under Philippine data privacy law seriously and have implemented organizational, technical, and administrative measures designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction.

By registering an account, logging in to ph.modern, making a deposit, or otherwise using 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, please discontinue use of the Platform.

02 Who We Are

ph.modern is the operator of the online gaming platform accessible at phmodern.lat, a platform built specifically for the Philippine market and governed by the regulations of the Philippine Amusement and Gaming Corporation (PAGCOR). ph.modern acts as the personal information controller in respect of all personal data collected through the Platform.

ph.modern has appointed a Data Protection Officer (DPO) in compliance with the requirements of the National Privacy Commission (NPC) of the Philippines. Contact details for the DPO are provided in Section 15 of this Policy. The DPO is responsible for overseeing ph.modern's data protection practices, monitoring compliance with RA 10173, and serving as the primary point of contact for all data privacy inquiries from Filipino players and the NPC.

03 Data We Collect

ph.modern collects personal data that is adequate, relevant, and limited to what is necessary for the purposes described in this Policy. The categories of personal data we collect are described in the table below.

ph.modern does not intentionally collect special categories of personal data (also known as sensitive personal information under RA 10173), such as health data, religious beliefs, or political affiliations, unless specifically required by applicable law or provided voluntarily by the Player in support-related communications.

04 How We Collect Data

ph.modern collects personal data through the following channels:

4.1 Direct Collection

Personal data provided directly by you when you register an account on ph.modern, complete the KYC verification process, make deposits or withdrawal requests, contact ph.modern's support team, participate in promotions, or update your account settings.

4.2 Automated Collection

Technical data including IP addresses, device identifiers, session logs, and browser information are collected automatically when you access and use the ph.modern Platform. This data is collected using server logs, cookies, and similar tracking technologies described in Section 8.

4.3 Third-Party Sources

ph.modern may receive personal data from third-party service providers engaged to assist with payment processing (GCash, BPI, BDO, Metrobank, PayMaya), identity verification services, and fraud detection systems. All third-party data sources used by ph.modern are required to have obtained your data lawfully and are subject to appropriate data processing agreements.

05 Purposes of Processing

ph.modern processes your personal data only for specific, legitimate purposes. The primary purposes for which your data is used are as follows:

• Account creation and management — registering and maintaining your ph.modern account, verifying your identity, and managing account security;
• Age and eligibility verification — confirming that you meet the 21+ age requirement and all other eligibility criteria under PAGCOR regulations and these Terms;
• Transaction processing — processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank in Philippine Pesos;
• KYC and AML compliance — fulfilling Know Your Customer (KYC) obligations and complying with the Anti-Money Laundering Act of 2001 (RA 9160) and related PAGCOR directives;
• Platform operation and improvement — delivering and improving ph.modern's games, features, and services;
• Security and fraud prevention — detecting, preventing, and investigating unauthorized access, fraudulent activity, and abuse of the Platform;
• Responsible gaming — monitoring gaming activity for indicators of problem gambling and delivering responsible gaming tools and interventions where appropriate;
• Customer support — responding to your support inquiries and resolving disputes;
• Legal and regulatory compliance — complying with applicable Philippine laws, PAGCOR regulations, NPC requirements, and lawful requests from regulatory and law enforcement authorities;
• Marketing communications — sending you promotional offers, bonus notifications, and platform updates where you have provided consent or where a legitimate interest exists, in accordance with applicable law.

ph.modern will not use your personal data for any purpose that is incompatible with the purposes described above without your prior consent or without a lawful basis under RA 10173.

06 Legal Bases for Processing

ph.modern processes your personal data on one or more of the following legal bases as provided under Republic Act No. 10173 and its Implementing Rules and Regulations:

• Consent — where you have given clear, informed, and freely given consent to the processing of your personal data for a specific purpose (e.g., direct marketing communications);
• Contractual necessity — where processing is necessary to perform the contract between you and ph.modern (i.e., your account agreement and these Terms), including account registration, payment processing, and service delivery;
• Legal obligation — where processing is necessary for ph.modern to comply with a legal obligation under Philippine law, including the Data Privacy Act, the Anti-Money Laundering Act, and PAGCOR regulatory directives;
• Legitimate interest — where processing is necessary for the legitimate interests pursued by ph.modern (e.g., fraud prevention, platform security, responsible gaming monitoring), provided that such interests do not override your fundamental rights and freedoms;
• Vital interest — in exceptional circumstances where processing is necessary to protect your vital interests or those of another person.

07 Data Sharing & Third Parties

ph.modern does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared with third parties only in the following circumstances and to the minimum extent necessary:

7.1 Service Providers

ph.modern engages third-party service providers who process personal data on our behalf, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), game software providers, identity verification services, cloud hosting providers, and customer support platform operators. All service providers are bound by data processing agreements that require them to process your data only on ph.modern's documented instructions and in compliance with applicable data protection law.

7.2 Regulatory and Legal Disclosures

ph.modern may be required to disclose your personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), law enforcement agencies, or courts of competent jurisdiction, where such disclosure is required by law, court order, or lawful regulatory directive. Disclosures are made only to the extent required and, where permitted by law, ph.modern will notify you of such a disclosure.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ph.modern's business, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and the Privacy Policy of the successor entity will apply to your data from the effective date of the transfer.

08 Cookies & Tracking Technologies

ph.modern uses cookies and similar tracking technologies (including session tokens, local storage, and pixel tags) to operate and improve the Platform. The types of cookies used by ph.modern are as follows:

• Essential Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to ph.modern during your session and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without impacting core Platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, responsible gaming limits you have set, and display preferences within your ph.modern account.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform, including pages visited, session duration, and device type. This data helps ph.modern improve the user experience. Analytics cookies do not identify you individually.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized login attempts, and unusual account behaviour. These cookies are essential for maintaining the security of your ph.modern account.

You can manage cookie preferences through your browser settings. Disabling essential cookies may affect your ability to log in to ph.modern or access certain features. ph.modern does not use third-party advertising cookies or serve behavioural advertising through cookie data.

09 Data Retention

ph.modern retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements applicable under Philippine law.

As a general principle, ph.modern retains account and transaction data for a minimum of five (5) years from the date of account closure, in compliance with the Anti-Money Laundering Act's record-keeping requirements and PAGCOR regulatory obligations. Gaming activity logs are retained for a minimum of three (3) years. KYC verification documents are retained for a minimum of five (5) years from the date of the last transaction, in accordance with AMLC guidelines.

Where personal data is no longer required for any legitimate purpose and no legal obligation requires its continued retention, ph.modern will securely delete or anonymise the data in accordance with its internal data disposal procedures.

10 Data Security

ph.modern has implemented comprehensive technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, and disclosure. These measures include:

• TLS 1.3 / 256-bit SSL encryption for all data transmitted between your device and ph.modern's servers;
• Encryption of sensitive personal data and financial data at rest;
• Role-based access controls ensuring that only authorized ph.modern personnel with a legitimate need can access personal data;
• Regular security assessments, penetration testing, and vulnerability scanning of ph.modern's infrastructure;
• Multi-factor authentication requirements for internal system access by ph.modern staff;
• Secure, access-controlled data centres with physical security protocols;
• Staff data privacy training and confidentiality obligations for all personnel who handle personal data.

While ph.modern takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You play an important role in maintaining account security by keeping your ph.modern login credentials confidential and notifying us immediately if you suspect unauthorized access to your account.

11 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by ph.modern:

• Right to be Informed: You have the right to be informed about how ph.modern collects and processes your personal data, as set out in this Privacy Policy;
• Right of Access: You have the right to obtain confirmation from ph.modern as to whether personal data concerning you is being processed and, if so, to receive a copy of that data;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held by ph.modern about you;
• Right to Erasure or Blocking: You have the right to request the deletion or blocking of your personal data where the data is no longer necessary for its original purpose, where you have withdrawn consent, or where the data has been unlawfully processed;
• Right to Object: You have the right to object to the processing of your personal data, including processing for direct marketing purposes;
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format and to request that this data be transmitted to another controller where technically feasible;
• Right to File a Complaint: You have the right to file a complaint with the National Privacy Commission (NPC) if you believe ph.modern has violated your data privacy rights under RA 10173.

To exercise any of these rights, please contact ph.modern's Data Protection Officer using the contact details in Section 15. ph.modern will respond to all verified data privacy requests within thirty (30) days of receipt. In complex cases, this period may be extended by an additional thirty (30) days with prior notification to you.

12 Minors and Age Restriction

If ph.modern becomes aware that personal data has been collected from a person under 21 years of age without verifiable parental or guardian consent, ph.modern will take immediate steps to delete that data and close the associated account. If you believe that ph.modern may have inadvertently collected data from an underage individual, please contact the DPO using the details in Section 15.

13 Cross-Border Data Transfers

Some of ph.modern's service providers, including cloud infrastructure providers and game software suppliers, may be located outside the Philippines. Where personal data is transferred to a country or territory outside the Philippines, ph.modern ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under RA 10173.

Appropriate safeguards for cross-border transfers used by ph.modern include contractual clauses that impose equivalent data protection obligations on the recipient, and transfer to countries that the National Privacy Commission has determined to provide an adequate level of protection for personal data.

14 Amendments to This Policy

ph.modern reserves the right to update or modify this Privacy Policy at any time. Material changes to this Policy will be communicated to registered players via the email address associated with their account or through a prominent notice on the Platform, at least seven (7) days before the changes take effect where reasonably practicable.

Where changes are required immediately for legal or regulatory compliance reasons, ph.modern may implement amendments without prior notice. The current version of this Privacy Policy is always accessible at phmodern.lat/privacy-policy. The effective date at the top of this document indicates when the most recent version came into force.

Your continued use of the ph.modern Platform after the effective date of any amendment to this Policy constitutes acceptance of the updated Policy. If you do not agree with any change to this Policy, you should discontinue use of the Platform and may request account closure and deletion of your personal data in accordance with Section 11.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or ph.modern's processing of your personal data, you may contact ph.modern's Data Protection Officer (DPO) through the following channels:

ph.modern aims to resolve all data privacy inquiries within thirty (30) days of receipt. If you are not satisfied with ph.modern's response to your inquiry, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing RA 10173.