ph32 Privacy Policy

1. Introduction

ph32 ("ph32," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who access the ph32 Platform. This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as well as other applicable Philippine data protection laws and regulations.

This Policy describes the types of personal information we collect from you when you register an account, make a deposit, place a wager, contact our support team, or otherwise interact with the ph32 Platform. It also explains how we use that information, with whom we may share it, how long we retain it, and what rights you have in relation to your personal data.

ph32 acts as the data controller in respect of all personal data collected through the Platform. If you have any questions about this Policy or about how ph32 handles your personal data, please refer to the contact details set out in Section 13 of this Policy.

2. Personal Data We Collect

ph32 collects the following categories of personal data from players and Platform visitors:

2.1 Identity & Contact Data

• Full legal name as it appears on a government-issued identification document
• Date of birth
• Residential address, including barangay, city or municipality, province, and postal code
• Email address
• Mobile phone number
• Nationality and country of residence

2.2 Identity Verification Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's licence, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Proof of payment method ownership (e.g., screenshots of GCash or PayMaya account details)
• Selfie photographs submitted for identity verification purposes

2.3 Financial Data

• Payment method details (GCash mobile number, PayMaya account details, bank account details, debit card details)
• Transaction history, including deposits, withdrawals, and wager amounts
• Account balance information

2.4 Gaming & Behavioural Data

• Game history, including games played, wagers placed, and outcomes
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool settings and usage (deposit limits, session timers, self-exclusion status)

2.5 Technical & Usage Data

• IP address and approximate geolocation derived from IP address
• Device type, operating system, and browser type and version
• Pages visited on the ph32 Platform and time spent on each page
• Referring website or source
• Cookie identifiers and similar tracking data (see Section 9)

2.6 Communications Data

• Records of communications between you and the ph32 customer support team, including live chat transcripts and email correspondence
• Feedback, complaints, and dispute records

3. How We Collect Your Data

ph32 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, 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 third-party KYC service providers; fraud prevention data from anti-fraud service providers; payment data from payment processors such as GCash, PayMaya, and Philippine banking partners.

4. Purposes of Processing

ph32 processes your personal data for the following purposes:

5. Legal Basis for Processing

ph32 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform the contract between you and ph32, including account management, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations, gaming regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for ph32's legitimate business interests, including fraud prevention, security monitoring, Platform analytics, and responsible gaming monitoring, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Personal Data

ph32 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention and AML service providers: Third-party providers engaged to assist ph32 in detecting and preventing fraud, money laundering, and other financial crimes.
• Gaming software and platform providers: Technology partners who provide the gaming software and infrastructure underlying the ph32 Platform.
• Regulatory and law enforcement authorities: Philippine gaming regulators, the Anti-Money Laundering Council (AMLC), and other competent authorities, where disclosure is required by law or regulation.
• Professional advisers: Legal, accounting, and auditing firms engaged by ph32, subject to professional confidentiality obligations.

7. Data Retention

ph32 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. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming and behavioural data: Retained for the duration of your account and for two (2) years following account closure.
• Communications data: Retained for two (2) years from the date of the communication.
• Technical and usage data: Retained for up to thirteen (13) months from collection.
• Self-exclusion records: Retained indefinitely to prevent re-registration during an exclusion period and to maintain a record of the exclusion.

Upon expiry of the applicable retention period, ph32 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8. Security Measures

ph32 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the ph32 Platform
• Encryption of sensitive data at rest, including financial and identity data
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Multi-factor authentication for all internal systems containing personal data
• Regular security audits, vulnerability assessments, and penetration testing
• Incident response procedures for detecting, reporting, and responding to personal data breaches
• Staff training on data protection and information security obligations

9. Cookies & Tracking Technologies

ph32 uses cookies and similar tracking technologies to enhance your experience on the Platform, to maintain your session, and to collect analytics data. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management and security. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Used to collect aggregated, anonymised data about how visitors use the Platform, enabling ph32 to improve its services.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content. You may opt out of marketing cookies at any time via your account settings.

You may control cookie settings through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph32 Platform.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by ph32:

• Right to be informed: The right to be informed of how your personal data is being processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data ph32 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to ph32's legal retention obligations.
• Right to object: The right to object to the processing of your personal data on grounds of legitimate interests or for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact the ph32 Data Protection Officer using the contact details in Section 13. ph32 will respond to all data subject requests within thirty (30) days of receipt, in accordance with applicable law.

11. Minors & Age Restriction

The ph32 Platform is strictly intended for persons aged 21 years and above. ph32 does not knowingly collect personal data from individuals under the age of 21. If ph32 becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to ph32, please contact us immediately using the details in Section 13 so that we can take appropriate action.

12. Changes to This Privacy Policy

ph32 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. The date of the most recent revision is indicated at the top of this document.

Where changes are material, ph32 will notify registered players by email or via an on-Platform notification prior to the changes taking effect. Your continued use of the ph32 Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or to ph32's handling of your personal data, please contact the ph32 Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the ph32 Platform
• Response Time: Within 30 days for data subject requests; within 24 hours for general enquiries

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you are not satisfied with ph32's response to your data protection concern.