ph44 Privacy Policy

This Privacy Policy ("Policy") describes how ph44 ("ph44," "we," "us," or "our") collects, uses, stores, and protects the personal data of users ("you," "your," or "Player") who access or use the ph44 online gaming platform available at ph44.xyz ("Platform").

ph44 is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

By registering an account, accessing the Platform, or otherwise providing your personal data to ph44, 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 this Policy, please discontinue use of the Platform immediately.

For the purposes of the Data Privacy Act of 2012, ph44 acts as the Personal Information Controller (PIC) in respect of the personal data collected through the Platform. As PIC, ph44 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

ph44 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact the DPO through the contact details provided in Section 14 of this Policy.

Where ph44 engages third-party service providers to process personal data on its behalf, such providers act as Personal Information Processors (PIPs) and are contractually bound to process data only in accordance with ph44's instructions and applicable data privacy laws.

ph44 collects the following categories of personal data from players and Platform users:

ph44 does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

ph44 collects personal data through the following means:

• Account Registration: When you create a ph44 account, you provide identity and contact data directly through the registration form.
• KYC Verification: When you submit identity documents for account verification, ph44 collects and processes the information contained in those documents.
• Financial Transactions: When you make a deposit or request a withdrawal, financial data is collected through our integrated payment processing partners, including GCash, PayMaya, and Philippine bank transfer services.
• Platform Usage: Technical and gaming data is collected automatically as you use the Platform, through server logs, cookies, and similar tracking technologies.
• Customer Support: When you contact ph44 support via live chat, email, or other channels, communications data is collected and retained for the purposes of resolving your inquiry and improving our services.
• Promotions and Surveys: If you participate in ph44 promotions, competitions, or voluntary surveys, additional data may be collected as part of those activities.

ph44 uses the personal data it collects for the following purposes:

• Account Management: To create, maintain, and administer your ph44 player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to ph44's gaming services, process your bets and wagers, credit winnings to your account, and facilitate deposits and withdrawals through your chosen payment method.
• Regulatory Compliance: To fulfill ph44's legal and regulatory obligations, including KYC verification, anti-money laundering (AML) checks under Republic Act No. 9160 (as amended), and reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC).
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal or prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming behavior and identify players who may be exhibiting signs of problem gambling, and to administer responsible gaming tools such as deposit limits, session limits, and self-exclusion.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Communications: To send you account-related notifications, security alerts, and, where you have provided consent, promotional communications about ph44 offers and services.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the ph44 Platform.

ph44 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

ph44 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving promotional communications from ph44.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and ph44 – specifically, the Terms & Conditions governing your use of the Platform. This includes processing necessary to create your account, deliver gaming services, and process financial transactions.
• Legal Obligation: Where processing is required for ph44 to comply with its legal and regulatory obligations under Philippine law, including AML obligations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate Interests: Where processing is necessary for ph44's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests as a data subject.

ph44 does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only where necessary and in accordance with this Policy:

• Payment Processors: Financial data is shared with licensed payment service providers (including GCash, PayMaya, and Philippine banking partners) solely for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Identity and document data may be shared with licensed KYC and identity verification service providers to fulfill ph44's regulatory obligations.
• Regulatory Authorities: ph44 is required by law to share certain data with PAGCOR, the AMLC, the Bureau of Internal Revenue (BIR), and other Philippine government agencies where required by applicable law or regulatory directive.
• Fraud Prevention Services: Technical and identity data may be shared with fraud prevention and security service providers to protect the Platform and its users from fraudulent activity.
• IT and Platform Service Providers: Technical data may be shared with cloud hosting, data analytics, and platform infrastructure providers who process data on ph44's behalf as Personal Information Processors under binding data processing agreements.
• Legal and Professional Advisors: In the context of legal proceedings, regulatory investigations, or professional advice, personal data may be disclosed to ph44's legal counsel, auditors, or other professional advisors under strict confidentiality obligations.

All third parties with whom ph44 shares personal data are required to maintain appropriate technical and organizational security measures and to process data only in accordance with ph44's instructions and applicable data privacy laws.

ph44 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security and fraud prevention functions. The following types of cookies may be used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting Platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymized information about how players use the Platform, such as which pages are visited most frequently and how long sessions last. This data helps ph44 improve the Platform's performance and user experience.
• Functional Cookies: These cookies remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience.
• Security Cookies: These cookies support ph44's fraud detection and account security systems by identifying unusual login patterns or suspicious activity.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph44 Platform. ph44 does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

ph44 retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active account and for a period of at least five (5) years following account closure, in accordance with PAGCOR licensing requirements and AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AML regulations and BIR record-keeping requirements.
• KYC and Identity Documents: Retained for the duration of your account and for at least five (5) years following account closure.
• Customer Support Records: Retained for a period of three (3) years from the date of the interaction, or longer where the interaction relates to an ongoing dispute or regulatory matter.
• Technical and Log Data: Retained for a period of up to twelve (12) months, unless longer retention is required for security investigations or regulatory purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with ph44's data disposal procedures. Where data is anonymized, it may be retained indefinitely for analytical purposes as it no longer constitutes personal data.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ph44. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

ph44 will respond to all data subject rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case ph44 will notify you of the extension and the reasons for it.

ph44 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the ph44 Platform is encrypted using 256-bit SSL/TLS technology. Sensitive data stored in ph44's systems is encrypted at rest.
• Access Controls: Access to personal data within ph44's systems is restricted to authorized personnel on a need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Security Audits: ph44 conducts regular security assessments and penetration testing to identify and address vulnerabilities in its systems.
• Incident Response: ph44 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, ph44 will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the Data Privacy Act.
• Staff Training: All ph44 personnel who handle personal data receive regular training on data privacy obligations and security best practices.

The ph44 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. ph44 does not knowingly collect personal data from persons under the age of 21.

If ph44 becomes aware that personal data has been collected from a person under 21 years of age, it will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that your child has provided personal data to ph44, please contact our support team immediately so that we can take appropriate action.

ph44 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. The date of the most recent revision is indicated at the top of this page.

Where material changes are made to this Policy, ph44 will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect. We encourage you to review this Policy periodically to stay informed about how ph44 protects your personal data.

Your continued use of the ph44 Platform following the effective date of any amendment to this 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 by contacting ph44 support.

If you have any questions, concerns, or requests relating to this Privacy Policy or ph44's handling of your personal data, please contact our Data Protection Officer or support team through the following channels:

• Support Center: ph44 Support Page
• Email: [email protected]

ph44 aims to respond to all privacy-related inquiries within thirty (30) days. If you are not satisfied with ph44's response to your inquiry or complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

For questions about your account, responsible gaming tools, or general support, please visit our Support Center or review our Terms & Conditions.