ph647 Privacy Policy

1. Introduction

ph647 ("ph647," "we," "us," or "our") is committed to protecting the privacy and personal data of all users who access and use the ph647 online gaming platform, including its website, mobile applications, and all associated services (collectively, the "Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

By registering an account, accessing the ph647 Platform, or otherwise interacting with our services, you acknowledge that you have read and understood this Privacy Policy and consent to the 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.

This Privacy Policy should be read together with our Terms & Conditions, which govern your overall use of the ph647 Platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

2. Data Controller

ph647 acts as the data controller for all personal data collected through the Platform. As data controller, ph647 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Data Privacy Act of 2012 and all applicable Philippine regulations.

ph647 has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection strategy and implementation. Contact details for our DPO are provided in Section 15 of this Privacy Policy.

3. Personal Data We Collect

ph647 collects the following categories of personal data from users of the Platform:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify the 21+ age requirement)
• Nationality and country of residence
• Email address and mobile phone number
• Residential address (barangay, city/municipality, province, ZIP code)
• Government-issued identification number (e.g., PhilSys ID, passport number, driver's license number)

3.2 Financial Data

• GCash or PayMaya/Maya account number or registered mobile number
• Bank account details (bank name, account number, account name) for bank transfer transactions
• Debit card details (card number, expiry date) where applicable
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used
• Source of funds documentation where required for KYC compliance

3.3 Gaming & Activity Data

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

3.4 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
• Cookie identifiers and similar tracking technology data (see Section 8)

3.5 Sensitive Personal Information

In limited circumstances, ph647 may collect sensitive personal information as defined under RA 10173, including government-issued identification numbers and financial account information. Such data is collected solely for the purposes of identity verification, KYC compliance, and anti-money laundering obligations, and is processed with heightened security measures.

4. How We Collect Your Data

ph647 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar technologies.
• Third-party sources: Data received from payment processors (GCash, PayMaya/Maya, banks), identity verification service providers, fraud prevention agencies, and PAGCOR or other regulatory authorities where required by law.

5. How We Use Your Personal Data

ph647 uses your personal data for the following purposes:

ph647 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have provided explicit consent.

6. Legal Basis for Processing

ph647 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including PAGCOR licensing requirements, anti-money laundering laws (AMLA), and tax obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

ph647 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya/Maya, and partner banks, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML compliance service providers engaged to verify your identity and screen against sanctions lists.
• Game content providers: Software providers whose games are available on the ph647 Platform, to the extent necessary to deliver gaming services and resolve disputes.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory instruction.
• IT and security service providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged by ph647 under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and accountants, where necessary for the conduct of ph647's business.

All third-party service providers engaged by ph647 are contractually required to process your personal data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable Philippine data protection law.

8. Cookies & Tracking Technologies

ph647 uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session security, and analyze Platform usage. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function, including session authentication and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Collect aggregated, anonymized data about how users interact with the Platform to help us improve performance and user experience.
• Marketing cookies: Used to deliver relevant promotional content to you based on your gaming preferences, subject to your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. ph647 does not use third-party advertising networks that track your activity across unrelated websites.

9. Data Retention

ph647 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter for compliance documentation purposes.
• Technical logs: Retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ph647's data disposal procedures.

10. Data Security

ph647 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the ph647 Platform.
• Encryption of sensitive data at rest, including financial account details and government identification numbers.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent security professionals.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph647 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay where required by law.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by ph647:

• Right to be Informed: The right to be notified of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right to Access: The right to request a copy of the personal data ph647 holds about you, along with information about how it is being processed.
• Right to Correction: The right to request correction of any inaccurate, incomplete, or outdated personal data we hold about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ph647'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 legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another 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 your data privacy rights have been violated.

To exercise any of the above rights, please contact ph647's Data Protection Officer using the contact details provided in Section 15. ph647 will respond to all verified data subject requests within thirty (30) days of receipt. We may request proof of identity before processing your request to protect against unauthorized access to your personal data.

12. Children's Privacy and Age Restriction

The ph647 Platform is strictly intended for individuals who are at least 21 years of age, in accordance with PAGCOR regulations and Philippine gaming law. ph647 does not knowingly collect personal data from individuals under the age of 21. If ph647 becomes aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to ph647, please contact our Data Protection Officer immediately using the details in Section 15 so that we can take appropriate action.

ph647 uses date-of-birth verification during registration and KYC document checks to enforce this age restriction. Any attempt to circumvent the age verification process constitutes a material breach of our Terms & Conditions.

13. International Data Transfers

ph647 primarily processes and stores personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to or accessed by service providers located outside the Philippines — for example, cloud infrastructure providers or game content suppliers operating internationally.

Where such transfers occur, ph647 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law. ph647 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards.

14. Changes to This Privacy Policy

ph647 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. Material changes to this Privacy Policy will be communicated to registered users via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how ph647 is protecting your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy.

15. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph647, please contact our Data Protection Officer:

ph647 takes all data privacy inquiries seriously. Our DPO will acknowledge receipt of your request within five (5) business days and provide a substantive response within thirty (30) days, or notify you if additional time is required for complex requests.