Privacy Policy

1 Introduction

ph986 (hereinafter "ph986," "we," "us," or "our") respects the privacy of all individuals who use our online gaming platform. This Privacy Policy is designed to inform you about the personal data we collect, how we process it, the purposes for which we use it, and the rights you have regarding your personal information under the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its implementing rules and regulations.

This Privacy Policy should be read in conjunction with our Terms and Conditions, which govern your use of the ph986 Platform. Where this Privacy Policy conflicts with other ph986 documentation, this Privacy Policy shall prevail in matters relating to data protection and privacy.

ph986 processes personal data only in accordance with applicable Philippine data protection laws, including the DPA, and in compliance with the principles of transparency, legitimate purpose, and proportionality. We employ technical, organizational, and physical security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction.

2 Data Controller

For the purposes of this Privacy Policy and applicable Philippine data protection law, ph986 is the data controller responsible for the collection, processing, storage, and protection of your personal data. As data controller, ph986 determines the purposes and means of processing personal information collected through the ph986 Platform.

ph986 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and addressing data subject rights requests. You may contact our Data Protection Officer at the contact details provided in Section 15 of this Privacy Policy.

3 Information We Collect

ph986 collects various categories of personal information to operate the Platform, provide gaming services, verify identity, prevent fraud, and comply with legal and regulatory obligations. The personal data we collect includes:

3.1 Information You Provide Directly

When you register for a ph986 account or use our services, you may provide the following information:

• Account Registration Information: Full legal name, date of birth, gender, residential address, email address, mobile phone number, and username/password credentials.
• Identity Verification Documents: Government-issued identification such as Philippine passport, driver's licence, SSS ID, UMID card, postal ID, or voter's ID, provided as part of Know Your Customer (KYC) compliance procedures.
• Financial Information: Payment method details including GCash account information, PayMaya account information, bank account numbers (BPI, BDO, Metrobank), cryptocurrency wallet addresses, and transaction history.
• Communication Data: Information contained in messages you send to ph986 customer support, including chat transcripts, emails, and complaint submissions.
• Survey and Feedback Data: Responses to voluntary surveys, promotional campaigns, or feedback forms you choose to complete.

3.2 Information Collected Automatically

When you access and use the ph986 Platform, certain technical and usage data is collected automatically:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (such as IMEI, MAC address, or advertising ID).
• Log Data: IP address, access times, pages viewed, time spent on pages, referral URLs, clickstream data, and error logs.
• Gaming Activity: Games played, bet amounts, winnings and losses, game session duration, bonus usage, and responsible gaming tool activation (such as deposit limits and self-exclusion requests).
• Location Data: Approximate geographic location derived from your IP address, and, where you have granted permission, precise geolocation data from your mobile device.
• Cookies and Tracking Technologies: Data collected via cookies, web beacons, and similar technologies as described in Section 10 of this Privacy Policy.

3.3 Information from Third Parties

ph986 may receive personal data about you from third-party sources, including:

• Payment Processors: Transaction verification data from GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency payment providers.
• Fraud Prevention Services: Information from third-party fraud detection and prevention services used to verify identity, detect suspicious activity, and prevent account abuse.
• Regulatory Databases: Information from publicly available regulatory databases, sanctions lists, and politically exposed persons (PEP) screening services.
• Marketing Partners: Limited referral or promotional data where you have been referred to ph986 through an affiliate partner or marketing campaign.

4 How We Use Your Data

ph986 processes your personal data for the following purposes, all of which are necessary for the operation of the Platform, compliance with legal obligations, or based on your explicit consent:

4.1 Account Management and Service Provision

• Create and manage your ph986 player account;
• Authenticate your identity when you log in to the Platform;
• Process deposits, withdrawals, and other financial transactions;
• Enable gameplay and maintain game integrity;
• Deliver customer support and respond to your inquiries;
• Communicate important account updates, transaction confirmations, and service notifications.

4.2 Identity Verification and Regulatory Compliance

• Conduct Know Your Customer (KYC) identity verification in accordance with PAGCOR requirements;
• Screen against anti-money laundering (AML) watchlists, sanctions lists, and PEP databases as required by the Anti-Money Laundering Act (AMLA) of the Philippines;
• Verify that you meet the minimum age requirement of 21 years for real-money gaming;
• Fulfill reporting obligations to the Anti-Money Laundering Council (AMLC) and other competent Philippine regulatory authorities;
• Retain records as required by applicable Philippine law and gaming regulations.

4.3 Fraud Prevention and Security

• Detect, investigate, and prevent fraudulent transactions, account abuse, and other prohibited activities;
• Monitor for suspicious activity patterns and enforce responsible gaming tools such as deposit limits and self-exclusion;
• Protect the security and integrity of the ph986 Platform and its users;
• Investigate and resolve disputes and complaints.

4.4 Marketing and Personalization

Where you have provided your consent, ph986 may use your personal data to:

• Send promotional offers, bonus notifications, and marketing communications via email or SMS;
• Personalize your gaming experience, including recommending games and promotions based on your activity history;
• Conduct market research and player satisfaction surveys.

You may withdraw your consent to marketing communications at any time by updating your notification preferences in your ph986 account settings or by contacting our support team.

4.5 Platform Improvement

• Analyze aggregated usage data to improve Platform performance, features, and user experience;
• Conduct internal analytics and reporting on game performance and player engagement;
• Test new Platform features, products, and functionality.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, ph986 relies on the following legal grounds to process your personal data:

6 Data Sharing & Disclosure

ph986 does not sell your personal data to third parties. We may share your personal information only in the following circumstances and only to the extent strictly necessary:

6.1 Service Providers

ph986 engages trusted third-party service providers who process personal data on our behalf, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank, cryptocurrency platforms), identity verification and KYC service providers, fraud detection and prevention platforms, cloud hosting and infrastructure providers, and customer support software providers. All third-party processors are bound by data processing agreements that require them to handle your data in accordance with the DPA and ph986's data protection standards.

6.2 Regulatory and Law Enforcement Disclosure

ph986 may disclose your personal data to competent Philippine government authorities, regulatory bodies, and law enforcement agencies where required by law, including:

• The Philippine Amusement and Gaming Corporation (PAGCOR) in connection with regulatory audits or compliance inquiries;
• The Anti-Money Laundering Council (AMLC) as required under the Anti-Money Laundering Act;
• The National Privacy Commission (NPC) in connection with data protection investigations;
• Philippine courts, tribunals, or law enforcement agencies pursuant to a valid court order, subpoena, or other lawful process.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or substantially all of ph986's assets, your personal data may be transferred to the successor entity. ph986 will notify affected players prior to any such transfer and will ensure that adequate data protection measures are maintained by the successor entity.

6.4 Consent-Based Sharing

Where you have provided explicit consent, ph986 may share your data with specifically identified marketing partners or promotional affiliates for purposes clearly explained at the time of consent. You may withdraw such consent at any time by contacting ph986 support.

7 Data Security

ph986 implements robust technical, organizational, and physical security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security program includes:

• Encryption: All data transmitted between your device and ph986's servers is protected with Transport Layer Security (TLS) 1.2 or higher. Sensitive data stored in ph986's databases, including financial information and identity documents, is encrypted at rest using AES-256 encryption;
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. ph986 staff access to player data is role-based, logged, and subject to regular review;
• Two-Factor Authentication: ph986 offers and encourages two-factor authentication (2FA) for all player accounts to reduce the risk of unauthorized access;
• Fraud Monitoring: Real-time fraud detection systems monitor account activity for suspicious patterns, unauthorized logins, and anomalous transaction behavior;
• Penetration Testing: ph986's Platform undergoes regular security assessments, vulnerability scanning, and penetration testing conducted by qualified third-party security professionals;
• Staff Training: All ph986 employees and contractors who handle personal data receive regular data protection and information security training.

8 Data Retention

ph986 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods applied by ph986 include:

• Account Information: Retained for the duration of your active account, plus five (5) years following account closure, in accordance with PAGCOR record-keeping requirements;
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of collection, as required by PAGCOR and AMLA regulations;
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the transaction date in compliance with AMLA and Philippine tax regulations;
• Customer Support Records: Support interactions and complaint records are retained for three (3) years from the date of resolution;
• Marketing Data: Data processed solely for marketing purposes is retained until you withdraw consent or for a maximum of two (2) years from last interaction, whichever occurs first;
• Technical Log Data: Server logs and technical usage data are retained for twelve (12) months unless required to be retained longer for an active security investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with an identifiable individual.

9 Your Privacy Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights regarding the personal data ph986 holds about you:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed, as provided in this Privacy Policy;
• Right to Access: The right to request a copy of the personal data ph986 holds about you and information about how that data is processed;
• Right to Correction: The right to request correction of inaccurate, incomplete, or outdated personal data held by ph986;
• 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 ph986's legal and regulatory retention obligations;
• Right to Object: The right to object to the processing of your personal data where that processing is based on ph986's legitimate interests or for direct marketing purposes;
• Right to Data Portability: The right to receive a copy of the personal data you have provided to ph986 in a structured, commonly used, machine-readable format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph986 has violated your privacy rights under the Data Privacy Act.

To exercise any of the above rights, please contact ph986's Data Protection Officer using the contact details in Section 15 of this Privacy Policy. ph986 will respond to all verified data subject rights requests within fifteen (15) calendar days of receipt, or within a reasonable extended timeframe where the complexity of the request requires it, with notification provided to you of the extension.

Please note that certain rights are subject to limitations where ph986 has compelling legal grounds for processing, including where retention is required by PAGCOR or AMLA regulations or where erasure would adversely affect ongoing fraud investigations or legal proceedings.

10 Cookies & Tracking Technologies

ph986 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and support security functions. The categories of cookies we use are:

10.1 Strictly Necessary Cookies

These cookies are essential for the operation of the ph986 Platform and cannot be disabled. They include session management cookies that keep you logged in during a gaming session, security cookies that detect and prevent fraudulent activity, and cookies that remember your responsible gaming preferences such as active deposit limits.

10.2 Functional Cookies

Functional cookies enable the Platform to remember your preferences and provide enhanced, personalized features. Examples include language preference cookies, game display preferences, and cookies that remember which payment method you last used. Disabling these cookies may affect certain Platform features.

10.3 Analytics Cookies

With your consent, ph986 uses analytics cookies to collect aggregated and anonymized information about how users interact with the Platform. This data helps ph986 understand which features are most used, where players encounter difficulties, and how to improve the overall gaming experience. Analytics data is not used to identify individual players.

10.4 Marketing Cookies

Where you have consented, marketing cookies may be used to deliver ph986 promotional content relevant to your interests and to measure the effectiveness of ph986's marketing campaigns. You may withdraw consent to marketing cookies at any time through your browser settings or by contacting ph986 support.

You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may prevent you from using certain essential features of the ph986 Platform, including logging in to your account.

11 Third-Party Services

The ph986 Platform integrates with third-party services including game providers, payment processors, and customer support tools. While ph986 carefully selects and vets all third-party partners, ph986 is not responsible for the privacy practices of third-party services accessed through or in connection with the Platform.

Third-party game providers integrated into ph986 may collect certain technical data directly from your device for the purpose of delivering and securing their games. This data collection is governed by the respective game provider's privacy policy, details of which are available upon request from ph986 support.

Payment processors such as GCash and PayMaya are independent data controllers for transactions processed through their respective platforms and have their own privacy policies governing their handling of your financial data. ph986 recommends that you review the privacy policies of all payment services you use in connection with your ph986 account.

12 International Data Transfers

In the course of operating the ph986 Platform, your personal data may be transferred to, stored in, or processed in jurisdictions outside the Republic of the Philippines. This may occur where ph986 engages cloud infrastructure providers, game suppliers, or fraud prevention services that operate internationally.

Where personal data is transferred outside the Philippines, ph986 takes all reasonable steps to ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that provided by the Data Privacy Act of 2012. Such safeguards may include contractual data protection clauses, adequacy assessments of the recipient jurisdiction, or certification schemes recognized under Philippine data protection law.

By using the ph986 Platform and providing your personal data, you acknowledge that your data may be processed in jurisdictions outside the Philippines, subject to the protections described in this section.

13 Children's Privacy

ph986's real-money gaming services are strictly intended for individuals who are twenty-one (21) years of age or older in accordance with Philippine gaming law. ph986 does not knowingly collect, process, or retain personal data from individuals below the minimum gaming age.

If ph986 discovers or has reasonable grounds to believe that personal data has been collected from a minor, ph986 will immediately suspend the associated account, delete all collected personal data, and return any deposited funds in accordance with our account closure procedures.

If you believe that a minor has registered for or is using a ph986 account, please notify our support team immediately at the contact details provided in Section 15. ph986 takes the protection of minors from online gambling harms extremely seriously and will act promptly upon receiving any such report.

14 Changes to This Privacy Policy

ph986 reserves the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. The revised Privacy Policy will be posted on the ph986 Platform with the updated effective date clearly indicated.

Where changes to this Privacy Policy are material — meaning they significantly affect how we process your personal data or your rights as a data subject — ph986 will notify you by email to the address registered on your account or via a prominent in-platform notification at least seven (7) days before the changes take effect, except where earlier implementation is required by applicable law or regulation.

Your continued use of the ph986 Platform following the effective date of a revised Privacy Policy constitutes your acknowledgment of and agreement to the revised terms. If you do not agree with the changes, you must discontinue use of the Platform and may request account closure in accordance with our Terms and Conditions.

15 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or ph986's handling of your personal data, please contact our Data Protection Officer:

Data Protection Officer — ph986

Email: [email protected]

Support Hours: 24 hours a day, 7 days a week

When submitting a data subject rights request or privacy-related complaint, please include your full name, registered email address, a clear description of your request or concern, and any relevant account or transaction reference numbers to help us process your request efficiently.

ph986 aims to acknowledge all privacy-related inquiries within two (2) business days and to provide a substantive response within fifteen (15) calendar days. For complex requests, we may extend this period by an additional fifteen (15) days with prior notification to you.