ph789 Privacy Policy

This Privacy Policy ("Policy") describes how ph789 ("ph789", "we", "us", or "our") collects, uses, stores, discloses, and otherwise processes the personal data of individuals ("you" or "Data Subject") who access or use the ph789 online gaming platform and related services available at ph789.bio (the "Platform").

ph789 is committed to protecting the privacy and security of your personal data. This Policy has been prepared in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering an account with ph789, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Policy and consent to the collection, processing, and use of your personal data as described herein. This Policy is incorporated by reference into the ph789 Terms and Conditions and forms part of the binding agreement between you and ph789.

For the purposes of the Data Privacy Act of the Philippines and this Policy, ph789 acts as the Personal Information Controller ("PIC") with respect to personal data collected from players and users of the ph789 Platform. As the PIC, ph789 determines the purposes and means by which your personal data is processed.

ph789 operates as an online gaming platform regulated by the Philippine Amusement and Gaming Corporation ("PAGCOR"). All data processing activities are conducted within the scope of and in compliance with ph789's PAGCOR operating authorization.

ph789 has designated a Data Protection Officer ("DPO") responsible for overseeing this Policy and compliance with applicable data protection law. Contact details for the ph789 DPO are provided in Section 15 of this Policy.

ph789 collects the following categories of personal data, depending on the services you use and the interactions you have with the Platform:

ph789 collects your personal data through the following methods:

• Directly from you — when you register an account on ph789, complete KYC verification, make deposits or withdrawal requests, contact customer support, or respond to surveys and promotions.
• Automatically through Platform use — gameplay data, session logs, IP addresses, device identifiers, and cookie data are collected automatically as you use the ph789 Platform.
• From payment processors — when you transact via GCash, Maya, BPI, BDO, Metrobank, or other supported payment channels, our payment processing partners share transaction confirmation data with ph789.
• From identity verification providers — ph789 may use third-party KYC technology providers to assist with document verification. These providers may process your identity documents and return verification results to ph789.
• From regulatory and fraud prevention systems — ph789 may receive information about players from PAGCOR-linked databases (including self-exclusion registries), or from fraud detection services used to protect the Platform and its users.

Under the Data Privacy Act of the Philippines, ph789 processes your personal data on one or more of the following lawful bases:

1. Consent — you have given ph789 your explicit consent to process specific categories of your personal data, such as for marketing communications (where you have opted in).
2. Contractual Necessity — processing is necessary for the performance of the contract between you and ph789 (i.e., the Terms and Conditions), including account management, payment processing, and provision of gaming services.
3. Legal Obligation — processing is necessary for ph789 to comply with legal obligations, including PAGCOR licensing requirements, RA 9160 (Anti-Money Laundering Act), RA 10173 (Data Privacy Act), and other applicable Philippine regulations.
4. Legitimate Interests — processing is necessary for the legitimate interests of ph789, such as fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided those interests are not overridden by your data protection rights.
5. Vital Interests — in exceptional circumstances, processing may be necessary to protect the vital interests of a data subject or another person.

Where ph789 relies on consent as the legal basis for processing, you have the right to withdraw that consent at any time by contacting ph789 support or updating your account preferences. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

ph789 uses your personal data for the following specific and legitimate purposes:

ph789 does not sell, rent, or trade your personal data to any third party for their independent commercial or marketing purposes. Your data is shared with third parties only in the following specific and controlled circumstances:

• Payment Processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, InstaPay, PesoNet, and other payment infrastructure providers receive the minimum financial data necessary to process your transactions. These entities are subject to their own privacy policies and Bangko Sentral ng Pilipinas (BSP) regulatory requirements.
• Game Providers: Third-party game studios and live casino operators (such as Evolution Gaming and Pragmatic Play) may receive anonymized session identifiers and bet data necessary to facilitate gameplay. These providers do not receive your identity or contact data.
• KYC and Verification Providers: Identity verification technology providers engaged by ph789 may process your government ID and selfie data solely for the purpose of verifying your identity. These providers operate as Personal Information Processors under data processing agreements with ph789.
• Regulatory Authorities: ph789 is legally obligated to share relevant player data with PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine regulatory or law enforcement bodies when required by law, court order, or valid regulatory directive.
• Fraud and Security Providers: ph789 may share limited technical and transaction data with fraud detection service providers to protect the Platform and its players from fraudulent activity.
• Professional Advisors: ph789's legal counsel, auditors, and compliance consultants may access relevant personal data where necessary for the performance of their professional services, under strict confidentiality obligations.

All third parties with whom ph789 shares personal data are required by ph789 to maintain appropriate data protection standards and to process personal data only in accordance with ph789's instructions and applicable Philippine data protection law.

Some of ph789's third-party service providers — including certain game studios and technology infrastructure providers — may be located outside the Philippines and may process your personal data in foreign jurisdictions. Where such international transfers occur, ph789 ensures that appropriate safeguards are in place to protect your data at a standard at least equivalent to that required by the Data Privacy Act of the Philippines.

These safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission or equivalent data protection authority;
• Data processing agreements that impose DPA-equivalent obligations on the receiving party;
• Transfers to jurisdictions recognized by the NPC as providing adequate data protection standards.

Where the Philippines is the primary jurisdiction in which your data is processed — which is the case for the majority of ph789's data processing activities — your data remains subject to the protections of RA 10173 at all times.

ph789 retains your personal data only for as long as is necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by applicable Philippine law.

Upon expiry of the applicable retention period, ph789 will securely delete or anonymize your personal data in a manner that prevents its reconstruction or recovery.

The ph789 Platform uses cookies and similar tracking technologies to enable core Platform functionality, improve user experience, and support Platform security and analytics.

The following categories of cookies are used on ph789:

• Strictly Necessary Cookies: These are essential for the Platform to function. They enable session management, login authentication, and security features. These cookies cannot be disabled without significantly impairing your ability to use ph789.
• Functional Cookies: These remember your preferences, such as language settings, game display options, and whether you have previously acknowledged notifications. Disabling these may reduce Platform personalization.
• Analytics Cookies: These help ph789 understand how players use the Platform, which games are most popular, and where usability improvements may be needed. Analytics data is aggregated and anonymized where possible. ph789 uses first-party analytics tools for this purpose.
• Security Cookies: These support fraud detection, session integrity verification, and bot identification to protect both the Platform and its players.

ph789 does not use advertising tracking cookies or third-party cookies for cross-site behavioral advertising. Your browsing behavior on ph789 is not shared with external advertising networks.

ph789 implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption in transit: All communications between your device and ph789 servers are encrypted using 256-bit SSL/TLS encryption.
• Encryption at rest: Sensitive personal data — including financial records and KYC documents — is stored in encrypted form on ph789's secure servers.
• Password security: Account passwords are stored in hashed format using industry-standard algorithms. ph789 never stores passwords in plain text.
• Two-factor authentication (2FA): Players may enable 2FA on their accounts, requiring OTP verification via their registered Philippine mobile number in addition to their password.
• Access controls: Access to personal data within ph789's systems is restricted on a strict need-to-know basis. All staff with data access undergo data privacy training and are bound by confidentiality obligations.
• Regular security testing: ph789 conducts periodic security assessments, including vulnerability scanning and penetration testing, to identify and remediate security weaknesses.
• Incident response: ph789 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, ph789 will notify the NPC and affected players within the timelines prescribed by the DPA IRR.

Under the Data Privacy Act of the Philippines (RA 10173), you have the following rights with respect to your personal data held by ph789. These rights may be exercised by contacting ph789's Data Protection Officer using the contact details in Section 15:

ph789 will respond to all valid data subject requests within fifteen (15) business days of receipt, as required by NPC regulations. Requests may be submitted via email to the ph789 DPO (see Section 15). ph789 may ask you to verify your identity before processing a data subject request to protect against unauthorized requests.

ph789 is an online gaming platform strictly intended for persons aged 21 years and above, in compliance with PAGCOR licensing requirements. ph789 does not knowingly collect personal data from individuals under the age of 21.

All registration applicants are required to confirm their age during the registration process and to provide government-issued proof of age as part of KYC verification. Where ph789 discovers or has reasonable grounds to believe that personal data has been collected from a person under 21, ph789 will:

• Immediately suspend the account;
• Void all gaming activity and transactions conducted through the account;
• Securely delete the minor's personal data to the extent permitted by law; and
• Report the matter to PAGCOR and relevant authorities if required.

If you are a parent or guardian and believe that your child (under 21) has registered on ph789, please contact ph789 support immediately at the contact details provided in Section 15. ph789 will investigate and take appropriate action promptly.

ph789 reserves the right to update, revise, or replace this Privacy Policy at any time to reflect changes in legal requirements, regulatory guidance, business practices, or Platform features. The effective date of the most current version is always displayed at the top of this page.

When material changes are made to this Policy, ph789 will endeavor to notify registered players through reasonable means, such as a notice displayed upon login or a notification sent to your registered mobile number or email address, prior to the changes taking effect. For minor or non-material updates, the revised Policy will be published on this page without separate notice.

Your continued use of the ph789 Platform following any update to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must stop using the Platform and may request account closure and data deletion in accordance with Section 12.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph789, please contact us through the following channels:

ph789 will acknowledge all data privacy inquiries within one (1) business day and provide a substantive response or resolution within fifteen (15) business days as required by the DPA IRR. For complex requests or those requiring additional verification, ph789 may request up to an additional fifteen (15) business days, with notification provided to the data subject within the initial fifteen-day period.

ph789's DPO is registered with the National Privacy Commission of the Philippines as required by NPC Circular 16-03. Registration details are available upon request.