ph64 Privacy Policy

This Privacy Policy ("Policy") describes how ph64 ("ph64," "we," "us," or "our") collects, processes, stores, discloses, and protects the personal data of individuals who access or use the ph64 online gaming platform available at ph64.club, including all associated pages, features, and services (collectively, the "Platform").

This Policy applies to all registered players, account applicants, visitors to the ph64 website, and any other individuals whose personal data is processed by ph64 in connection with the delivery of its services. It covers personal data collected through all channels, including the ph64 website, mobile browser experience, customer support interactions, payment transactions, and identity verification processes.

By registering a ph64 account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you must discontinue your use of the Platform.

For the purposes of the Data Privacy Act of 2012 and this Policy, ph64 is the personal information controller responsible for the personal data collected through the Platform. ph64 determines the purposes and means of processing personal data in connection with the delivery of online gaming and sports betting services to Filipino players.

ph64 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data protection law and for handling data subject requests and inquiries. Contact information for the DPO is provided in Section 16 of this Policy.

Where ph64 engages third-party service providers to process personal data on its behalf, those providers act as personal information processors under written data processing agreements that require them to process data only as instructed by ph64 and to implement appropriate security measures.

ph64 collects the following categories of personal data, depending on the nature of your interaction with the Platform:

ph64 does not intentionally collect special categories of personal data (such as health data, religious beliefs, or political opinions) unless strictly required by law or with your explicit consent. Where responsible gaming interactions result in the recording of information relating to your health or wellbeing, such data is treated with the highest level of confidentiality.

ph64 collects personal data through the following channels and mechanisms:

• Direct collection from you: Data you actively provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, responding to surveys, or using responsible gaming tools.
• Automated technical collection: Data collected automatically when you access the Platform, including IP addresses, device identifiers, browser attributes, session activity logs, and page interaction data via cookies and similar tracking technologies (see Section 9).
• Third-party identity verification providers: Identity verification data returned by KYC/AML screening providers as part of ph64's regulatory compliance obligations.
• Payment service providers: Transaction confirmation data provided by GCash, Maya, Philippine banks, and other payment processors when you make deposits or request withdrawals.
• Game providers: Game session data, bet records, and RNG outcome logs provided by ph64's game studio partners in the normal course of game delivery.
• Fraud prevention services: Risk signals and device fingerprinting data provided by third-party fraud detection tools used to protect the Platform and its players.

ph64 processes personal data only for specific, legitimate purposes. The following table summarizes the primary processing activities, their purposes, and the applicable legal basis under the Data Privacy Act of 2012:

Where ph64 relies on legitimate interests as a legal basis for processing, ph64 has assessed that those interests are not overridden by the rights and interests of data subjects. Players may object to processing carried out on legitimate interests grounds by contacting the ph64 DPO as described in Section 16.

ph64 does not sell, rent, or trade your personal data to any third party. ph64 may share your personal data with the following categories of recipients, solely to the extent necessary for the stated purpose:

6.1 Payment Processors

ph64 shares necessary transaction data with GCash, Maya (PayMaya), Philippine bank partners, and other payment service providers to process your deposits and withdrawals. These providers operate under their own privacy policies and are bound by applicable Philippine financial regulations.

6.2 Identity Verification Providers

To fulfil its KYC and AML obligations, ph64 may transmit identity document images and personal details to accredited third-party identity verification services. These providers process data solely as instructed by ph64 under written data processing agreements.

6.3 Game Providers and Technology Partners

ph64's game studio partners — including providers of slot games, live casino software, sports betting feeds, and bingo room technology — receive gaming session data necessary for game delivery and real-time bet processing. These partners are contractually prohibited from using this data for any purpose other than providing services to ph64.

6.4 Regulatory Authorities

ph64 is required by law to disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine regulatory bodies upon receipt of a valid legal demand. ph64 will only comply with requests that are legally valid and proportionate.

6.5 Professional Advisors

ph64 may share limited personal data with lawyers, auditors, accountants, and other professional advisors where necessary in connection with the operation of its business, subject to confidentiality obligations.

Some of ph64's third-party service providers — including certain game studios, cloud infrastructure providers, and fraud detection services — are headquartered or operate servers outside the Philippines. Where personal data is transferred outside the Philippines, ph64 ensures that appropriate safeguards are in place to protect that data, consistent with the requirements of the Data Privacy Act of 2012 and NPC guidelines.

Such safeguards may include: standard contractual clauses approved by the NPC; reliance on a recipient country's adequacy determination; binding corporate rules; or other legally recognized transfer mechanisms. If you would like more information about the safeguards applicable to a specific international transfer, please contact the ph64 DPO at the address provided in Section 16.

ph64 retains personal data only for as long as necessary to fulfil the purposes described in this Policy or as required by applicable law, whichever is longer. The following general retention periods apply:

• Active account data: Retained for the duration of the account relationship and for a period of five (5) years following account closure, to comply with PAGCOR record-keeping requirements and AML obligations.
• Transaction and financial records: Retained for a minimum of ten (10) years in compliance with anti-money laundering regulations and applicable tax law.
• Identity verification documents: Retained for five (5) years post-account closure or as otherwise required by applicable KYC regulations.
• Customer support records: Retained for three (3) years from the date of the relevant support interaction.
• Marketing consents and opt-out records: Retained indefinitely to demonstrate compliance and honor opt-out preferences.
• Technical logs and access records: Retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ph64's data disposal procedures. Where data is anonymized, the anonymized data may be retained for statistical or analytical purposes without any personal identifying information.

ph64 uses cookies and similar tracking technologies (collectively, "Cookies") on the Platform for the purposes described below. Cookies are small data files stored on your device by your web browser when you visit the Platform.

9.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled without preventing normal use of the Platform.
• Functional Cookies: Used to remember your preferences such as language settings, display options, and responsible gaming limit configurations.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players interact with the Platform, enabling ph64 to improve performance, user experience, and content relevance.
• Security and Fraud Prevention Cookies: Used to detect and prevent unauthorized access, bot activity, and fraudulent transactions on the Platform.

9.2 Managing Cookies

You may manage non-essential Cookies through your browser settings or the ph64 cookie preference controls available on the Platform. Disabling strictly necessary Cookies will impair or prevent Platform functionality. Disabling analytics or functional Cookies will not prevent you from using the Platform but may reduce personalization features.

ph64 implements and maintains a comprehensive set of technical, organizational, and physical security measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph64 servers;
• AES-256 encryption for sensitive data stored at rest on ph64 systems;
• Bcrypt hashing of all account passwords — ph64 never stores passwords in recoverable plain text;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication requirements for all ph64 internal systems accessing production data;
• Real-time intrusion detection and automated security monitoring;
• Regular third-party security audits and penetration testing of the Platform infrastructure;
• Incident response procedures including mandatory breach notification to the National Privacy Commission within seventy-two (72) hours of detection, where required by law.

Notwithstanding the above, no method of data transmission or storage is one hundred percent secure. While ph64 uses commercially reasonable means to protect your personal data, ph64 cannot guarantee absolute security. You are encouraged to use a strong, unique password and to enable two-factor authentication on your ph64 account for enhanced personal protection.

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you hold the following rights with respect to your personal data held by ph64. These rights may be exercised free of charge by contacting the ph64 DPO as described in Section 16:

ph64 will respond to valid data subject requests within thirty (30) calendar days of receipt. ph64 may extend this period by an additional thirty (30) days where necessary due to the complexity of the request, and will notify you of any extension within the initial period. ph64 reserves the right to decline requests that are manifestly unfounded, excessive, or that would require disclosure of third-party personal data without appropriate authorization.

If you are not satisfied with ph64's response to your data subject request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

The ph64 Platform is strictly restricted to individuals who are twenty-one (21) years of age or older, as required by PAGCOR regulations applicable to online casino-style gaming in the Philippines. ph64 does not knowingly collect personal data from individuals under the age of 21.

If ph64 discovers or is informed that personal data has been collected from a person under 21 years of age, ph64 will promptly delete that data, suspend the associated account, and take appropriate remedial action. If you have reason to believe that a person under 21 has created a ph64 account, please notify ph64 immediately at [email protected].

ph64 may send you promotional communications — including bonus offers, game announcements, and VIP program updates — by SMS, email, or in-platform notification, subject to your communication preferences as recorded in your account settings.

ph64 will only send direct marketing communications where you have provided your explicit consent or, in limited circumstances, on the basis of legitimate interests where the communication relates directly to ph64 products you have already used. You may withdraw your consent to receive marketing communications at any time by updating your notification preferences in your ph64 account, or by contacting ph64 at [email protected].

Withdrawal of marketing consent will not affect the delivery of transactional communications that are necessary for the operation of your account, such as deposit confirmations, withdrawal notifications, KYC requests, and security alerts.

The ph64 Platform may contain references to third-party services — such as payment providers, game studios, and responsible gaming support organizations. Where the Platform links to or integrates with third-party services, those services operate under their own privacy policies, which are independent of this Policy. ph64 is not responsible for the privacy practices of third-party websites or services.

ph64 recommends that you review the privacy policies of any third-party services you interact with in connection with your use of the ph64 Platform, including the policies of GCash (Globe Fintech Innovations), Maya (Voyager Innovations), and your Philippine bank, where applicable.

ph64 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, NPC guidelines, PAGCOR requirements, or ph64's data processing practices. Where a material change is made, ph64 will provide advance notice to registered players via email or in-platform notification prior to the effective date of the amendment.

The effective date and last review date at the top of this Policy will be updated to reflect the date of the most recent revision. Your continued use of the ph64 Platform following the effective date of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the amended Policy, you must cease using the Platform and may request account closure under the terms of ph64's Terms & Conditions.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or need to report a potential data breach or privacy concern, please contact the ph64 Data Protection Officer using the contact information below. All addresses are provided as plain text — they are not clickable links.

ph64 will acknowledge privacy inquiries within three (3) business days and will endeavor to resolve them fully within thirty (30) calendar days. Requests relating to data subject rights will be handled in accordance with Section 11 of this Policy and the requirements of the Data Privacy Act of 2012.