ph64 Privacy Policy

1. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, ph64 is the Personal Information Controller (PIC) responsible for the personal data you provide when registering and using the ph64 platform at ph64.vip.

ph64 operates under a PAGCOR licence and is legally required to maintain records of certain player data as part of its regulatory compliance obligations. Where ph64 engages third-party service providers to process data on its behalf, those providers act as Personal Information Processors (PIPs) under written data processing agreements that bind them to the same data protection standards ph64 applies.

2. Data We Collect

ph64 collects personal data through different points of interaction with the Platform. The categories of data collected, and the context in which they are collected, are described below.

ph64 does not collect sensitive personal information (as defined under RA 10173) such as racial or ethnic origin, religious beliefs, health data, or political affiliations, except where specifically required by PAGCOR anti-money laundering obligations.

3. How We Use Your Data

ph64 uses the personal data it collects for the following purposes:

• Account management: Creating, verifying, and maintaining your ph64 account, including identity and age verification.
• Service delivery: Processing deposits and withdrawals, enabling gameplay, and personalising your ph64 experience.
• Regulatory compliance: Meeting ph64's obligations under PAGCOR regulations, Philippine AML laws (Republic Act 9160 as amended), and the Data Privacy Act.
• Fraud prevention and security: Detecting and preventing unauthorised account access, fraudulent transactions, and money laundering.
• Responsible gaming: Monitoring play patterns to identify at-risk behaviour and enforcing self-exclusion or limit requests made by players.
• Communications: Sending transactional messages (deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about ph64 offers.
• Analytics and improvement: Understanding how the ph64 Platform is used in aggregate to improve game selection, performance, and user experience.

ph64 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or PAGCOR regulations.

4. Legal Basis for Processing

ph64 processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and ph64 — i.e., operating your account, enabling gameplay, and processing financial transactions.
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations and Anti-Money Laundering Act reporting requirements.
• Legitimate interests: Processing necessary for ph64's legitimate interests in fraud prevention, security, and platform improvement, provided those interests are not overridden by your rights.
• Consent: Where ph64 relies on consent — specifically for optional marketing communications — you may withdraw consent at any time by updating your ph64 account preferences or contacting support.

5. Data Sharing

ph64 does not sell, rent, or trade your personal information to any third party for their own marketing purposes. ph64 shares data only in the following circumstances:

• Service providers: ph64 shares data with carefully vetted third-party providers who process data on ph64's behalf under written agreements — including payment processors (GCash, PayMaya, BPI), identity verification providers, game platform operators, and cloud hosting services.
• Regulatory authorities: ph64 is legally obligated to disclose player data to PAGCOR, the Anti-Money Laundering Council (AMLC), and Philippine law enforcement upon lawful request.
• Business transfers: In the event of a merger, acquisition, or sale of ph64's business, player data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

All third-party data processors engaged by ph64 are contractually prohibited from using ph64 player data for any purpose other than providing the specific services for which they were engaged.

6. Cookies & Tracking Technologies

ph64 uses cookies and similar tracking technologies on ph64.vip to ensure the Platform functions correctly and to understand how it is used. The types of cookies ph64 uses are:

• Strictly necessary cookies: Required for basic Platform functions such as login session management, shopping cart, and security. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display preferences across sessions on ph64.
• Analytics cookies: Collect anonymised data about how players use ph64 — which pages are visited, how long sessions last, and which games are most popular — to help ph64 improve the Platform.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing ph64's core services, but may affect some Platform features.

7. Data Retention

ph64 retains personal data for as long as necessary to fulfil the purposes described in this policy, and for the periods required by Philippine law. Specific retention periods applicable to ph64 are:

• Account and identity data: Retained for the duration of your active ph64 account plus a minimum of five (5) years after account closure, as required by PAGCOR and AML regulations.
• Financial transaction data: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act.
• Support communications: Retained for two (2) years from the date of the interaction.
• Technical and usage data: Retained in identifiable form for up to twelve (12) months, after which it is anonymised or deleted.

When retention periods expire, ph64 securely deletes or anonymises personal data so that it can no longer be associated with an identifiable individual.

8. Data Security

ph64 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Security measures in place at ph64 include:

• 256-bit TLS/SSL encryption for all data transmitted between your device and ph64's servers.
• Encryption of sensitive data fields (financial data, identity data) at rest using AES-256.
• Role-based access controls limiting ph64 staff access to personal data on a need-to-know basis.
• Regular security audits and penetration testing of ph64's platform infrastructure.
• Multi-factor authentication for access to ph64's internal systems.

In the event of a personal data breach that poses a risk to your rights, ph64 will notify the Philippine National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by RA 10173.

9. Your Rights Under the Data Privacy Act

As a data subject under Republic Act 10173, you have the following rights with respect to your personal data held by ph64:

• Right to be informed: The right to know how your personal data is being collected and processed — which is the purpose of this Privacy Policy.
• Right to access: The right to request a copy of the personal data ph64 holds about you.
• Right to rectification: The right to correct inaccurate or incomplete personal data in your ph64 account.
• Right to erasure: The right to request deletion of your personal data where ph64 no longer has a legal basis to retain it. Note that regulatory retention obligations may limit this right in practice.
• Right to data portability: The right to receive a machine-readable copy of personal data you have provided to ph64.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact ph64's Data Protection Officer at [email protected]. ph64 will respond within 15 business days. You also have the right to lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph if you believe ph64 has violated your data privacy rights.

10. Children's Privacy

ph64 does not knowingly collect personal data from individuals under the age of 21. The ph64 Platform is strictly for adults aged 21 and above. 21+

If ph64 determines that a registered account belongs to a person under 21, that account will be suspended immediately, all associated data will be handled in accordance with applicable Philippine law, and any balance held will be dealt with per PAGCOR's underage player protocols. If you believe a minor has created a ph64 account, please contact ph64 support immediately.

11. Cross-Border Data Transfers

Some of ph64's third-party service providers — including certain cloud infrastructure, game platform operators, and analytics providers — may process data outside the Philippines. Where such transfers occur, ph64 ensures that:

• The receiving country or organisation provides an adequate level of data protection comparable to RA 10173 standards.
• Appropriate contractual safeguards (such as standard contractual clauses) are in place with the receiving entity.
• The transfer is disclosed to the National Privacy Commission where required.

By using ph64, you acknowledge that your data may be processed in countries outside the Philippines, subject to the safeguards described above.

12. Policy Updates

ph64 may update this Privacy Policy from time to time to reflect changes in Philippine law, PAGCOR regulations, or ph64's data processing practices. Material changes will be communicated to registered players via email to the address on file and via a prominent notice on ph64.vip.

The updated policy will indicate the effective date at the top of this page. Continued use of ph64 after the effective date of a revised Privacy Policy constitutes acceptance of the updated terms.

13. Contact & Data Protection Officer

For any privacy-related question, data subject rights request, or complaint related to ph64's handling of your personal data, you may contact ph64 through the following channels:

ph64 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012. All privacy-related correspondence is directed to the DPO for handling. ph64 will acknowledge receipt of your inquiry within two (2) business days and provide a substantive response within fifteen (15) business days.