ph334 Privacy Policy

This Privacy Policy ("Policy") describes how ph334 ("ph334," "we," "us," or "our") collects, uses, stores, protects, shares, and otherwise processes personal information relating to individuals ("Data Subjects," "Players," "you," or "your") who access or use the ph334 website at ph334.org, its subdomains, associated mobile interfaces, and all related online gaming services (collectively, "the Platform" or "the Service").

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC"). ph334 is committed to the principles of transparency, legitimate purpose, and proportionality in all personal data processing activities.

By creating a ph334 account, accessing the Platform, or using any ph334 Service, you acknowledge that you have read and understood this Policy. This Policy should be read together with ph334's Terms and Conditions. In the event of any conflict between this Policy and the Terms and Conditions specifically regarding personal data processing, this Policy shall prevail.

For the purposes of the Data Privacy Act of 2012 and its IRR, ph334 is the Personal Information Controller (PIC) in respect of personal data collected from players and users of the ph334 Platform. As PIC, ph334 determines the purposes and means of processing personal data collected through the Platform.

ph334 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the DPA, handling data subject rights requests, and serving as the point of contact with the National Privacy Commission. Players may contact ph334's DPO using the contact details provided in Section 15 of this Policy.

Where ph334 engages third-party service providers to process personal data on ph334's behalf and under ph334's instructions, those providers act as Personal Information Processors (PIPs) and are bound by written data processing agreements that impose data protection obligations consistent with the DPA.

ph334 collects the following categories of personal data from players and Platform users:

ph334 does not collect sensitive personal information as defined under Section 3(l) of the DPA (such as health data, political opinions, or religious beliefs) unless such collection is strictly required by applicable law or regulatory mandate and you have been specifically informed of that collection.

ph334 collects personal data through the following means:

4.1 Direct Collection

Data you provide directly to ph334 when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in promotions, or respond to surveys or communications from ph334.

4.2 Automated Collection

Data collected automatically when you access or use the ph334 Platform, including through cookies, web beacons, pixel tags, server logs, and similar tracking technologies. This includes your IP address, device identifiers, browsing behaviour on the Platform, and session duration. See Section 9 for details on cookie use.

4.3 Third-Party Sources

ph334 may receive personal data about you from third parties in the following circumstances: (a) identity and fraud verification agencies used during KYC processing; (b) payment processors confirming transaction details; (c) PAGCOR or other Philippine regulatory bodies in connection with compliance activities; and (d) publicly available data sources where permitted by law.

ph334 processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

• Account Registration and Management: To create, maintain, and administer your ph334 account, verify your identity, and provide you with access to the Platform. Basis: Contractual necessity.
• KYC and Age Verification: To verify that you meet the 21+ age requirement and to comply with PAGCOR regulations and the Anti-Money Laundering Act (AMLA). Basis: Legal obligation.
• Payment Processing: To process deposits, withdrawals, and refunds through your registered payment method (GCash, PayMaya, BDO, BPI, Metrobank). Basis: Contractual necessity.
• Gaming Services: To operate and deliver the games and betting services available on the ph334 Platform, maintain game integrity, and record gaming history. Basis: Contractual necessity.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and other prohibited conduct on the Platform. Basis: Legitimate interest / Legal obligation.
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling, to enforce responsible gaming tools you have activated, and to comply with PAGCOR responsible gaming requirements. Basis: Legal obligation / Legitimate interest.
• Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance. Basis: Contractual necessity / Legitimate interest.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive marketing communications. Basis: Consent. You may withdraw consent at any time.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws, PAGCOR directives, court orders, and requests from competent regulatory authorities. Basis: Legal obligation.
• Platform Improvement: To analyse Platform usage patterns and improve the user experience, game selection, and service quality through aggregated and anonymised analytics. Basis: Legitimate interest.

ph334 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. ph334 shares personal data only in the following limited circumstances:

6.1 Service Providers (Personal Information Processors)

ph334 engages third-party companies to perform specific functions on our behalf under written data processing agreements. These include payment processors (GCash, PayMaya, BDO, BPI, Metrobank), KYC and identity verification providers, fraud detection services, IT infrastructure and cloud hosting providers, and customer support software platforms. These processors are permitted to use your personal data only for the specific purpose ph334 has contracted them for and under ph334's documented instructions.

6.2 Regulatory and Law Enforcement Bodies

ph334 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Philippine National Police (PNP), the National Bureau of Investigation (NBI), or any other competent Philippine government authority where required by law, regulation, court order, or lawful regulatory request.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of ph334's business or assets, player personal data may be transferred to the acquiring entity as part of the transaction. Players will be notified of any such transfer via the registered email address on file, and the acquiring entity will be required to comply with this Policy.

ph334 retains personal data for as long as is necessary to fulfil the purpose for which it was collected, subject to the following retention standards:

• Active Account Data: Retained for the duration of your active ph334 account relationship.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of account closure, in compliance with AMLA record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA and BIR requirements.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer Support Communications: Retained for a minimum of two (2) years from the date of last interaction.
• Marketing Consent Records: Retained for the period of active consent plus three (3) years after withdrawal of consent, as evidence of consent management.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with ph334's data disposal procedures. Anonymised and aggregated data that can no longer identify any individual may be retained indefinitely for statistical and analytical purposes.

ph334 implements technical, organisational, and physical security measures appropriate to the nature of the personal data processed and the risks involved, including:

• Encryption: All data transmitted between your device and ph334 servers is encrypted using Transport Layer Security (TLS). Sensitive data fields, including passwords, are hashed using industry-standard cryptographic algorithms. Personal and financial data stored in ph334 databases is encrypted at rest.
• Access Controls: Access to personal data is restricted to ph334 personnel and authorised processors who have a documented legitimate need. Access rights are role-based, reviewed regularly, and revoked upon departure or role change.
• Infrastructure Security: ph334's Platform infrastructure is hosted in secure data centre facilities with physical access controls, environmental protections, and continuous monitoring.
• Vulnerability Management: ph334 conducts regular security assessments and vulnerability scans of the Platform. Security patches and updates are applied promptly.
• Incident Response: ph334 maintains a documented personal data breach response procedure. In the event of a breach that is likely to result in a real risk to the rights and freedoms of affected data subjects, ph334 will notify the National Privacy Commission within 72 hours of discovery, and will notify affected players without undue delay in accordance with NPC Circular No. 16-03.

The ph334 Platform uses cookies and similar technologies (collectively, "Cookies") to operate platform functionality, maintain session security, and understand how players use the Platform. The following types of Cookies are used:

9.1 Strictly Necessary Cookies

Essential for the operation of the ph334 Platform — enabling login sessions, maintaining your authentication state, and protecting against cross-site request forgery. These Cookies cannot be disabled without impairing core Platform functionality.

9.2 Functional Cookies

Used to remember your preferences and settings on the Platform, such as language preference and notification settings. These Cookies enhance your experience but are not strictly required for Platform operation.

9.3 Analytics Cookies

Used to collect aggregated and anonymised information about how players navigate and use the ph334 Platform, which pages are visited most frequently, and where errors occur. This data helps ph334 improve the Platform. ph334 uses first-party analytics tools for this purpose.

ph334 does not use advertising or cross-site tracking Cookies. You can control and delete Cookies through your browser settings. Note that disabling strictly necessary Cookies will affect your ability to use the ph334 Platform.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph334. To exercise any of these rights, contact ph334's Data Protection Officer using the details in Section 15. ph334 will respond to all data subject rights requests within fifteen (15) working days of receipt of a complete and verified request.

• Right to Be Informed: The right to be informed of the personal data ph334 collects about you, the purposes of processing, and your rights — as set out in this Policy.
• Right to Access: The right to obtain a copy of the personal data ph334 holds about you, together with information about how it is being processed.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. For standard account details, you may update information directly through your ph334 account settings. For KYC data corrections, contact support.
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other legal basis applies), or where processing is unlawful. Note that certain data may be retained where required by law (see Section 7).
• Right to Object: The right to object to processing of your personal data for direct marketing purposes. You may also object to processing based on ph334's legitimate interests where your interests, rights, and freedoms override those interests.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to have that data transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe ph334's processing of your personal data violates the Data Privacy Act. ph334 encourages you to contact us first so we may address your concern directly.

The ph334 Platform is strictly intended for adults aged twenty-one (21) years and above. ph334 does not knowingly solicit or collect personal data from persons under the age of 21. Age verification is conducted during the account registration and KYC process.

If ph334 discovers or is notified that personal data has been collected from a person under the age of 21, ph334 will take immediate steps to: (a) suspend and close the relevant account; (b) securely delete the personal data collected from that account to the extent not required to be retained under applicable law; and (c) report the incident where required by PAGCOR regulations.

Some of ph334's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a recipient in a foreign country, ph334 ensures that appropriate safeguards are in place in accordance with Section 21 of the Data Privacy Act of 2012 and the NPC's guidelines on cross-border data transfers.

Safeguards employed by ph334 for cross-border transfers include: binding contractual clauses in data processing agreements with overseas processors that impose DPA-equivalent data protection obligations; and limiting overseas transfers to countries or entities whose data protection frameworks have been assessed as providing an adequate level of protection.

Where personal data is processed by overseas game providers or live dealer operators forming part of the ph334 game library, those providers are contractually required to process such data only for the purpose of delivering the specific game service and to maintain data security standards consistent with the DPA.

The ph334 Platform may integrate with or reference third-party services, including payment gateways (GCash, PayMaya), banking interfaces (BDO, BPI, Metrobank), and game providers. Each third-party service has its own privacy policy and data practices that are independent of this Policy.

ph334 is not responsible for the privacy practices of third-party services. When you interact directly with a third-party service — for example, when you use the GCash app to fund your ph334 account — your data interaction with that third-party is governed by their respective privacy policy, not this Policy.

ph334 does not include social media tracking pixels, third-party advertising networks, or cross-site tracking tools on the ph334 Platform. Any analytics tools used are configured to collect data in an aggregated and anonymised form that does not identify individual players.

ph334 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC issuances, or operational requirements. Material changes to this Policy will be communicated to registered players via email to the address on file, and a prominent notice will be displayed on the ph334 Platform, at least seven (7) days before the amended Policy takes effect.

The "Last Updated" date at the top of this Policy will be revised whenever the Policy is amended. Your continued use of the ph334 Platform after the effective date of any amended Policy constitutes your acknowledgement of the changes. If you do not agree to the amended Policy, you may close your ph334 account in accordance with the procedure described in ph334's Terms and Conditions.

The most current version of this Privacy Policy is always accessible at ph334.org/privacy-policy.

For any questions, concerns, or requests related to this Privacy Policy or to ph334's personal data processing practices — including data subject rights requests — please contact ph334's Data Protection Officer:

If you are not satisfied with ph334's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

ph334 encourages you to contact us first before raising a matter with the NPC. Most data privacy concerns can be resolved quickly and directly through ph334 support, and we are committed to addressing every concern seriously and promptly.