Privacy Policy — ph165

ph165 ("we", "us", "the Platform") is committed to protecting the privacy of all individuals who access or use the ph165 online gaming platform. This Privacy Policy explains what personal data ph165 collects, how it is used, with whom it is shared, how long it is retained, and what rights you hold as a data subject under Philippine law.

By registering a ph165 account, completing the ph165 Login process, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, please discontinue use of the Platform and contact ph165 support to arrange account closure.

This Privacy Policy applies to all personal data collected by ph165 through:

• The ph165 website and all pages accessible at the ph165 domain, including the ph165 Login page and all game category pages.
• The ph165 progressive web application (PWA) when added to a mobile device home screen.
• Any communication channel operated by ph165, including live chat support, email correspondence to [email protected], and any future communication tools introduced on the Platform.
• Interactions with ph165 payment processing partners and identity verification service providers where ph165 initiates the data request.

This Policy does not apply to third-party websites, applications, or services that may be linked from ph165 content. ph165 is not responsible for the privacy practices of any third-party service, and players should review the privacy policies of any third party independently.

For the purposes of the Philippine Data Privacy Act and applicable data protection law, ph165 is the personal information controller in respect of all personal data collected through the Platform. ph165 determines the purposes and means of processing your personal data, and is responsible for ensuring that such processing is lawful, fair, and transparent.

ph165 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act. Contact details for the ph165 DPO are available upon request by contacting ph165 support through the channels listed in Section 15 of this Policy.

ph165 collects the following categories of personal data, depending on your interaction with the Platform:

ph165 does not intentionally collect sensitive personal information as defined under the Data Privacy Act (such as health data, religious beliefs, or political affiliation) unless strictly required for regulatory compliance purposes, in which case explicit consent will be obtained.

ph165 collects personal data through the following methods:

• Direct submission: Information you provide when registering an account, completing the ph165 Login, updating your profile, submitting identity verification documents, or contacting customer support.
• Automated collection: Technical data collected automatically when you access the Platform, including IP address, device identifiers, session cookies, and browser information.
• Transaction records: Financial data generated when you make deposits or withdrawals via GCash, Maya, InstaPay, BPI, BDO, or other supported payment channels.
• Third-party sources: Identity and address verification data received from KYC service providers engaged by ph165. Financial crime screening data from sanctions list databases applicable to the Philippines.
• Platform activity: Gaming records, bet histories, session logs, and responsible gaming tool usage generated by your activity within the ph165 Platform.

ph165 processes your personal data for the following purposes:

• Account creation and management: To register and maintain your ph165 Account, authenticate your ph165 Login, and provide access to all Platform services.
• Identity verification (KYC): To verify your identity and age (21+) as required by applicable Philippine gaming and anti-money laundering regulations.
• Payment processing: To process deposits and withdrawals via GCash, Maya, bank transfers, and other supported Philippine payment channels.
• Game provision and bet settlement: To operate games, record wager activity, calculate results, and settle winnings accurately.
• Regulatory compliance: To fulfill obligations under Philippine anti-money laundering laws (AMLA), applicable gaming regulations, and any lawful requirement from Philippine government authorities.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account abuse, money laundering, and unauthorized access to the Platform.
• Responsible gaming: To monitor gaming patterns, administer deposit limits and self-exclusion requests, and comply with PAGCOR's responsible gaming framework.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Service improvement: To analyze Platform usage, identify technical issues, and improve the ph165 player experience.
• Marketing communications: To send you promotional offers, bonuses, and updates about ph165 — only where you have provided consent and only via channels you have opted into.

ph165 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules:

• Contractual necessity: Processing required to perform the contract between you and ph165 — including account operation, game provision, and payment processing.
• Compliance with a legal obligation: Processing required to fulfill ph165's obligations under Philippine law, including AMLA, applicable PAGCOR regulations, tax laws, and NPC requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights and interests as a data subject.
• Consent: Processing for direct marketing communications, optional analytics, and any processing not covered by the above bases — only where you have provided freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time by contacting ph165 support.

ph165 does not sell, rent, or trade your personal data. ph165 shares personal data only with the following categories of recipients, strictly to the extent necessary for the purposes described in Section 5:

• Payment processors: GCash (Mynt / Globe Fintech Innovations), Maya (Voyager Innovations), InstaPay network participants, Philippine banks (BPI, BDO, Metrobank, UnionBank), and other payment service providers necessary to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and document verification service providers engaged by ph165 to verify your identity and age as required by applicable regulations.
• Game providers: Certified gaming software providers including Evolution Gaming, Pragmatic Play, PG Soft, JILI, and others, who require session data to operate their games within the ph165 Platform.
• Regulatory and law enforcement authorities: The Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where required by law or regulatory mandate.
• IT and infrastructure providers: Cloud hosting, content delivery, and cybersecurity service providers engaged by ph165 under contractual data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, under binding confidentiality obligations.

Some of ph165's third-party service providers operate internationally, which may result in your personal data being transferred to and processed in countries outside the Philippines. Where such international transfers occur, ph165 ensures that appropriate safeguards are in place — including contractual data transfer agreements that impose obligations equivalent to those required under the Philippine Data Privacy Act.

ph165 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate supplemental safeguards as required by the NPC's applicable issuances.

ph165 retains personal data for as long as necessary to fulfill the purpose for which it was collected, including for the duration of your Account and for a reasonable period thereafter. Specific retention periods are as follows:

• Account data and gaming records: For the duration of your active ph165 Account plus a minimum of five (5) years after Account closure, in compliance with AMLA record-keeping requirements applicable in the Philippines.
• Financial transaction records: A minimum of five (5) years from the date of the transaction, or longer if required by Philippine tax or anti-money laundering law.
• KYC and identity verification documents: For the period required under applicable Philippine regulatory obligations, typically five (5) years after Account closure.
• Customer support communications: Up to three (3) years from the date of the interaction, unless a longer period is required for dispute resolution or regulatory purposes.
• Marketing consent records: For the period of your consent plus two (2) years, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Where data cannot be immediately deleted due to technical constraints, it is isolated from further processing until deletion can be completed.

ph165 implements appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph165 servers.
• AES-256 encryption for personal and financial data stored in ph165 databases.
• Multi-factor authentication for all ph165 administrative system access.
• Role-based access controls ensuring that employees access personal data only to the extent required for their specific role.
• Regular third-party security audits and penetration testing of the ph165 platform infrastructure.
• Intrusion detection systems and 24/7 security monitoring of the ph165 technical environment.
• Documented incident response procedures with defined notification timelines for material data breaches.

While ph165 applies industry-standard security practices, no data transmission or storage system can guarantee absolute security. Players are reminded of their own responsibility to maintain the security of their ph165 Login credentials, as described in the ph165 Terms & Conditions.

ph165 uses cookies and similar tracking technologies to operate the Platform, maintain your session after ph165 Login, and analyze Platform usage. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in after completing the ph165 Login process. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming limits you have configured in your Account.
• Analytics Cookies: Used by ph165 to understand how players navigate the Platform, which game categories are most visited, and where technical improvements should be prioritized. Analytics data is aggregated and does not identify individual players.
• Security Cookies: Used to detect and prevent fraudulent activity, credential-stuffing attacks, and suspicious login patterns associated with your Account.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform, including completing the ph165 Login process. ph165 does not use third-party advertising cookies or tracking pixels for cross-site behavioral advertising.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph165:

• Right to Access: Request a copy of the personal data ph165 holds about you, along with information about how it is processed.
• Right to Rectification: Request correction of inaccurate or incomplete personal data associated with your ph165 Account.
• Right to Erasure: Request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ph165's retention obligations under Philippine law.
• Right to Object: Object to ph165 processing your personal data on the basis of legitimate interests, including for direct marketing purposes. You may opt out of marketing communications at any time.
• Right to Data Portability: Request a structured, machine-readable copy of personal data you have provided to ph165, where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.
• Right to Lodge a Complaint: File a complaint with the National Privacy Commission of the Philippines if you believe ph165 has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, contact ph165 via the support channels listed in Section 15. ph165 will respond to valid data subject requests within fifteen (15) working days of receipt, in compliance with NPC guidelines.

The ph165 platform is strictly for individuals aged 21 years and above in accordance with applicable Philippine gaming regulations. ph165 does not knowingly collect personal data from individuals under the age of 21. If ph165 becomes aware that it has collected personal data from a person under 21, that data will be immediately deleted and the associated Account will be permanently closed.

If you are a parent or guardian and believe that a person under 21 has created a ph165 Account, please contact ph165 support immediately through the channels in Section 15. ph165 takes age verification seriously and cooperates fully with PAGCOR's minors protection requirements.

ph165 reviews this Privacy Policy periodically and may update it to reflect changes in applicable law, regulatory requirements, or ph165's data processing practices. The effective date at the top of this page indicates when the current version was last updated.

Where updates are material — affecting your rights as a data subject or significantly changing how ph165 processes your data — ph165 will notify registered players via email to the address on record, or via a prominent notice on the Platform, at least fourteen (14) days before the changes take effect. Continued use of ph165 following the effective date of revised Policy constitutes acceptance of the updated terms.

For all data protection and privacy-related inquiries — including requests to exercise your data subject rights, questions about this Privacy Policy, or concerns about ph165's data processing practices — please contact ph165 via:

• Email (plain text — not a link): [email protected] — please include "Privacy Inquiry" in the subject line.
• Live Chat: Available 24/7 within the ph165 Platform after completing the ph165 Login process. Ask to be connected to the Data Protection team.

If your concern is not resolved to your satisfaction after contacting ph165, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). Information about NPC complaint procedures is available through official Philippine government channels.

For responsible gaming concerns, support tools, and self-exclusion requests, please visit the ph165 Responsible Gaming page, or raise the matter directly with ph165 customer support.