ph32 Privacy Policy

1. Introduction

ph32 is committed to protecting the privacy and personal data of every player who uses our Platform. We understand that trust is the foundation of any good relationship — and that trust starts with being completely transparent about how we handle your information.

This Policy describes the types of personal data we collect from you when you register, deposit, play, or interact with ph32 in any way. It explains the purposes for which we process that data, the legal grounds on which we rely, the parties with whom we may share it, and the rights you have as a data subject under applicable Philippine law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

ph32 acts as the data controller for all personal data collected through the Platform. We are responsible for ensuring that your data is processed lawfully, fairly, and transparently, and that it is kept secure at all times.

2. Personal Data We Collect

ph32 collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include the following:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify the 21+ age requirement);
• Residential address, including city, province, and postal code;
• Email address and mobile phone number;
• Government-issued identification number (e.g., Philippine national ID, passport, driver's license).

2.2 Financial Data

• GCash or PayMaya mobile wallet number;
• Bank account details (BPI, BDO, Metrobank, or other supported banks) where provided for withdrawal purposes;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references;
• Account balance information.

2.3 Gaming & Activity Data

• Game history, including games played, stakes placed, outcomes, and session durations;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status);
• Customer support interaction records, including chat transcripts and email correspondence.

2.4 Technical & Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type and version;
• Unique device identifiers;
• Login timestamps and session activity logs.

3. How We Collect Your Data

ph32 collects personal data through the following means:

• Directly from you — when you register an account, complete identity verification, make a deposit or withdrawal, contact customer support, or participate in a promotion;
• Automatically — through cookies, web beacons, and similar tracking technologies when you access and use the Platform (see Section 9 for details);
• From third parties — including identity verification service providers, payment processors (such as GCash and PayMaya), fraud prevention services, and regulatory authorities where required by law.

4. How We Use Your Personal Data

ph32 uses your personal data only for the purposes described in this Policy. We do not sell your personal data to third parties for their own marketing purposes. The primary purposes for which we process your data are set out in the table below:

5. Legal Basis for Processing

ph32 processes your personal data on the following legal grounds under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations:

• Contractual necessity — processing is necessary to perform our contract with you, including account registration, payment processing, and the provision of gaming services;
• Legal obligation — processing is required to comply with applicable laws and regulations, including PAGCOR licensing requirements, anti-money laundering obligations, and tax reporting requirements;
• Legitimate interests — processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests;
• Consent — where we rely on your consent (for example, for optional marketing communications), you have the right to withdraw that consent at any time by contacting our support team or updating your account preferences.

6. Sharing Your Personal Data

ph32 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. 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:

6.1 Service Providers

We engage trusted third-party service providers to assist us in operating the Platform. These include identity verification and KYC providers, payment processors (including GCash, PayMaya, BPI, BDO, and Metrobank), cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and cybersecurity services. All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

ph32 may be required to disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government authorities where required by applicable law, regulation, court order, or regulatory directive. Such disclosures will be made only to the extent strictly necessary to comply with the relevant legal obligation.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ph32's business, your personal data may be transferred to the relevant successor entity as part of that transaction. You will be notified of any such transfer and any material changes to this Policy that result from it.

7. Data Retention

ph32 retains your 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 and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and anti-money laundering regulations;
• Financial transaction records — retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act (RA 9160, as amended);
• Gaming activity data — retained for a minimum of three (3) years from the date of the activity;
• Customer support records — retained for a minimum of two (2) years from the date of the interaction;
• Marketing consent records — retained until consent is withdrawn and for one (1) year thereafter as evidence of consent.

When personal data is no longer required for any lawful purpose, ph32 will securely delete or anonymise it in accordance with our internal data retention and disposal procedures.

8. Data Security

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:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph32 Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent necessary for their role;
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent third-party security specialists;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Comprehensive staff training on data protection and information security obligations.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph32 will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

9. Cookies & Tracking Technologies

ph32 uses cookies and similar tracking technologies to operate and improve the Platform, to remember your preferences, and to analyse how the Platform is used. A cookie is a small text file placed on your device when you visit the Platform.

9.1 Types of Cookies We Use

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies may affect the functionality of the Platform and prevent you from accessing certain features, including your account. Disabling functional cookies may mean that your preferences are not saved between sessions.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by ph32. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

• Right to be Informed — you have the right to be informed about how your personal data is collected and processed, which is the primary purpose of this Policy;
• Right of Access — you have the right to request a copy of the personal data we hold about you and information about how it is processed;
• Right to Rectification — you have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure — you have 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 our legal retention obligations;
• Right to Object — you have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis, and to opt out of direct marketing communications at any time;
• Right to Data Portability — you have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible;
• Right to Lodge a Complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

ph32 will respond to all data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

11. Minors & Age Policy

ph32 employs age verification procedures during the registration process and may request additional documentation to confirm a player's age at any time. If you are a parent or guardian and believe that a minor has registered on the ph32 Platform, please contact our support team immediately so that we can take appropriate action.

12. AML & Regulatory Compliance

ph32 is subject to the Anti-Money Laundering Act of 2001 (RA 9160, as amended by RA 10365 and RA 11521) and the regulations of the Anti-Money Laundering Council (AMLC). In compliance with these obligations, ph32 is required to:

• Collect and verify the identity of all players through a Know Your Customer (KYC) process before processing withdrawals;
• Monitor transactions for suspicious activity and report covered and suspicious transactions to the AMLC as required by law;
• Retain transaction records for a minimum of five (5) years;
• Cooperate fully with AMLC investigations and requests for information.

The processing of your personal data for AML compliance purposes is a legal obligation. You cannot opt out of this processing. Failure to provide the information required for KYC verification may result in restrictions on your ability to withdraw funds from your ph32 account.

13. Changes to This Privacy Policy

ph32 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players by email and by posting a prominent notice on the Platform. The updated Policy will display a revised "Last Updated" date at the top of this page.

We encourage you to review this Policy periodically to stay informed about how ph32 protects your personal data. Your continued use of the Platform following the publication of an updated Policy constitutes your acknowledgement of the changes.

14. Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way ph32 handles your personal data, please contact our Data Protection Officer. We take all privacy enquiries seriously and will respond promptly.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for administering and enforcing the Data Privacy Act of 2012.

ph32 is committed to working constructively with the NPC and with individual data subjects to resolve any privacy concerns in a fair and timely manner.