ph92 Privacy Policy

ph92 ("we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the ph92 online gaming platform at https://ph92.net (the "Platform"). This Privacy Policy describes how ph92 collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Republic of the Philippines, and its Implementing Rules and Regulations, as well as the guidelines issued by the National Privacy Commission (NPC).

By registering a ph92 account, accessing the Platform, or otherwise providing your personal data to ph92, 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 Privacy Policy, you must discontinue use of the Platform immediately.

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, ph92 acts as the Personal Information Controller in respect of the personal data collected from players and visitors to the Platform. ph92 determines the purposes and means of processing your personal data.

ph92 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data privacy laws and this Privacy Policy. If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact the ph92 DPO using the contact details provided in Section 15 of this Privacy Policy.

Where ph92 engages third-party service providers to process personal data on its behalf, such providers act as Personal Information Processors and are contractually bound to process personal data only in accordance with ph92's instructions and applicable data privacy laws.

ph92 collects the following categories of personal data from players and Platform visitors, to the extent necessary for the purposes described in this Privacy Policy:

ph92 collects personal data through the following means:

• Direct interactions: Data you provide when registering a ph92 account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. Please refer to Section 10 for more information on our use of cookies.
• Third-party sources: Identity and financial verification data received from third-party KYC and anti-money laundering service providers, payment processors (including GCash, PayMaya, BPI, BDO, and Metrobank), and fraud prevention agencies, where permitted by applicable law.
• Publicly available sources: Information available from public registries or databases where relevant to our legal compliance obligations.

ph92 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an underage individual, we will take immediate steps to delete such data and close the associated account.

ph92 uses the personal data we collect for the following purposes:

• Account management: To register and maintain your ph92 account, verify your identity, and manage your account preferences and settings.
• Service delivery: To provide access to the Platform's gaming services, process deposits and withdrawals, and deliver customer support.
• Legal and regulatory compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, know-your-customer (KYC) requirements, and reporting obligations to relevant regulatory authorities including PAGCOR.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming activity for indicators of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Communications: To send you transactional communications relating to your account, including deposit confirmations, withdrawal notifications, and security alerts.
• Marketing (with consent): To send you promotional offers, bonus notifications, and news about ph92 products and services, where you have provided your consent to receive such communications. You may withdraw your marketing consent at any time through your account settings.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the ph92 Platform.

ph92 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary for the performance of the contract between you and ph92 (i.e., the Terms & Conditions), including account registration, service delivery, and payment processing.
• Legal obligation: Processing is required for ph92 to comply with applicable Philippine laws and regulations, including AML, KYC, and gaming regulatory requirements.
• Legitimate interests: Processing is necessary for ph92's legitimate interests, including fraud prevention, Platform security, and service improvement, provided such interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as direct marketing communications and non-essential cookies, ph92 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ph92 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. ph92 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, BPI, BDO, Metrobank, and other approved payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify player identities and screen for sanctions, politically exposed persons (PEPs), and adverse media.
• Technology service providers: Cloud hosting providers, Platform infrastructure providers, and software vendors who process data on ph92's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law, court order, or regulatory directive.
• Fraud prevention agencies: Third-party fraud detection and prevention services used to protect the Platform and its players from fraudulent activity.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by ph92, subject to professional confidentiality obligations.

Any third party with whom ph92 shares personal data is contractually required to implement appropriate technical and organizational security measures and to process personal data only for the specified purpose and in accordance with ph92's instructions.

ph92 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account data: Retained for the duration of your active ph92 account, and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under Philippine law.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (as amended) and PAGCOR regulations.
• Identity verification documents: Retained for the duration of the account and for a minimum of five (5) years following account closure.
• Customer support communications: Retained for a period of three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing consent records: Retained for as long as you maintain a ph92 account or until you withdraw your marketing consent, whichever is earlier.
• Technical and usage data: Retained for a period of twelve (12) months from the date of collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, ph92 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

ph92 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph92 Platform.
• Encryption at rest for sensitive personal data stored on ph92's servers, including financial data and identity verification documents.
• Access controls limiting access to personal data to authorized ph92 personnel and service providers on a strict need-to-know basis.
• Multi-factor authentication for internal systems accessing personal data.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform and supporting infrastructure.
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

While ph92 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. ph92 cannot guarantee the absolute security of data transmitted over the internet. You are responsible for maintaining the security of your ph92 account credentials and for notifying ph92 immediately if you suspect any unauthorized access to your account.

ph92 uses cookies and similar tracking technologies (including web beacons and pixel tags) on the Platform to enhance your user experience, analyze Platform performance, and support our security and fraud prevention measures. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management, authentication, and security functions. These cookies cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies: Used to collect aggregated, anonymized information about how players use the Platform, including pages visited and features used, to help ph92 improve Platform performance and user experience.
• Functional cookies: Used to remember your preferences and settings, such as language preferences and display options, to provide a more personalized experience.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats on the Platform.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the ph92 Platform. For detailed instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph92:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data ph92 holds about you, together with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data ph92 holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph92's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on ph92's legitimate interests.
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that ph92 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact the ph92 Data Protection Officer using the contact details in Section 15. ph92 will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. ph92 may request proof of identity before processing any data subject request.

The ph92 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. ph92 does not knowingly collect, process, or store personal data from individuals under the age of 21.

If ph92 becomes aware that personal data has been collected from an individual under the age of 21, ph92 will take immediate steps to delete such data, close the associated account, and return any funds deposited, subject to applicable verification procedures.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to ph92, please contact us immediately using the details in Section 15 so that we can take appropriate action.

The ph92 Platform may contain references to third-party services, such as payment providers and gaming software suppliers. This Privacy Policy applies solely to personal data collected and processed by ph92 through the Platform. ph92 is not responsible for the privacy practices of any third-party services or platforms.

ph92 encourages you to review the privacy policies of any third-party services you interact with in connection with your use of the Platform, including your chosen payment provider (e.g., GCash, PayMaya, BPI, BDO, or Metrobank), as their data handling practices may differ from those of ph92.

ph92 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. When material changes are made, ph92 will update the "Last Updated" date at the top of this page.

For significant changes that materially affect how ph92 processes your personal data, ph92 will provide notice to registered players via email or an in-Platform notification prior to the changes taking effect, where reasonably practicable.

Your continued use of the ph92 Platform following the publication of any updated Privacy Policy constitutes your acknowledgment of the changes. ph92 recommends that you review this Privacy Policy periodically to stay informed of how your personal data is being protected.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph92, please contact our Data Protection Officer using the following details:

• Data Protection Officer, ph92
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available within the ph92 Platform after logging in to your account.

ph92 aims to respond to all privacy-related enquiries and data subject requests within fifteen (15) business days of receipt. For complex requests, ph92 may extend this period by a further fifteen (15) business days, in which case you will be notified of the extension and the reasons for it.

If you are not satisfied with ph92's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data protection matters in the Philippines.