ph635 Privacy Policy

1.1 ph635 operates as a PAGCOR-licensed online casino and sports betting platform serving Filipino players across the Philippines, from Metro Manila and Makati to Cebu, Davao, and Quezon City. In the ordinary course of providing these services, ph635 collects and processes personal information from its members and prospective members.

1.2 ph635 recognizes that the privacy of your personal information is fundamental. This Policy has been prepared to ensure full transparency about how your data is handled and to affirm ph635's compliance with the DPA and the requirements of the National Privacy Commission ("NPC") of the Philippines.

1.3 This Policy applies to all personal data collected by ph635 through the Platform, including data collected during account registration, identity verification, payment transactions, customer support interactions, and use of ph635's gaming and betting services.

2.1 ph635 is the personal information controller ("PIC") for all personal data collected through the Platform, as defined under Section 3(h) of the DPA. ph635 determines the purposes and means of processing your personal data.

2.2 ph635 has appointed a Data Protection Officer ("DPO") as required under the DPA. The DPO is responsible for ensuring ph635's ongoing compliance with the DPA and for handling data subject requests. Contact details for the DPO are set out in Section 15 of this Policy.

3.1 ph635 collects the following categories of personal data in connection with the use of the Platform:

3.2 ph635 does not intentionally collect sensitive personal information as defined under Section 3(l) of the DPA — such as health, racial, or political data — unless specifically required for responsible gaming case management or as mandated by PAGCOR or law enforcement. Where such data is collected, it is processed with heightened security measures and explicit consent.

4.1 ph635 uses your personal data for the following purposes:

• Account Administration: To create, maintain, and manage your ph635 member account, including authenticating your identity at login and processing account settings changes.
• Identity Verification (KYC): To fulfill PAGCOR's mandatory know-your-customer requirements before permitting real-money transactions on the Platform.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and card providers, and to verify that payment accounts are in your verified name.
• Service Delivery: To provide you with access to all ph635 gaming and betting services, including casino games, sports betting, bingo, slots, and sabong.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the DPA, and other applicable Philippine laws and regulations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and abuse of the Platform.
• Responsible Gaming: To monitor for indicators of problem gambling behavior, to apply and enforce player-set limits and self-exclusion requests, and to facilitate responsible gaming interventions in accordance with PAGCOR guidelines.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support team.
• Platform Improvement: To analyze usage data in aggregate to improve the Platform's performance, user interface, game library, and security posture.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent. You may opt out of marketing communications at any time from your account settings or by contacting support.

5.1 Under the DPA, ph635 relies on the following legal bases for processing your personal data:

• Consent (Section 12[a] DPA): Where you have expressly agreed to the processing of your personal data, including for marketing communications, when you register your account and accept this Policy.
• Contract (Section 12[b] DPA): Where processing is necessary for the performance of the member agreement between you and ph635, including account management, payment processing, and service delivery.
• Legal Obligation (Section 12[c] DPA): Where processing is required to comply with PAGCOR regulations, the AMLA, the DPA itself, and other applicable Philippine laws.
• Legitimate Interests (Section 12[f] DPA): Where processing is necessary for ph635's legitimate interests — including fraud prevention, platform security, and responsible gaming monitoring — provided these interests are not overridden by your fundamental rights and freedoms.

6.1 Third-Party Service Providers. ph635 may share your personal data with carefully selected third-party service providers who process data on ph635's behalf as personal information processors ("PIPs") under the DPA. These include payment processors (GCash, PayMaya, and bank partners), identity verification providers, cloud hosting and infrastructure providers, and analytics service providers. All PIPs are bound by written data processing agreements that restrict their use of your data to the specific services they provide to ph635 and prohibit unauthorized disclosure.

6.2 Regulatory Authorities. ph635 is required by law to disclose member data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities when formally required to do so. ph635 will not notify you of such disclosures where doing so would be unlawful or would compromise an ongoing investigation.

6.3 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of ph635's business or assets, member personal data may be transferred to the acquiring entity, subject to that entity assuming the obligations of this Policy. ph635 will notify affected members of any such transfer that materially affects their data rights.

7.1 ph635 retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to applicable legal retention obligations. The following retention periods apply as a general guide:

• Active account data: Retained for the duration of the membership and for five (5) years following account closure, in compliance with PAGCOR record-keeping and AMLA requirements.
• Transaction and betting records: Retained for five (5) years following the date of the transaction, in accordance with AMLA obligations.
• KYC documents: Retained for five (5) years following account closure or the date of the last transaction, whichever is later.
• Support and communications records: Retained for three (3) years from the date of the interaction.
• Marketing consent records: Retained for three (3) years from the date consent was last confirmed or withdrawn.
• Technical and usage logs: Retained for twelve (12) months from the date of generation.

7.2 Upon expiry of the applicable retention period, personal data is securely deleted from ph635's systems or rendered permanently anonymous such that it can no longer be attributed to an identifiable individual.

8.1 ph635 implements organizational and technical security measures appropriate to the risk presented by its processing activities. These measures include:

• 256-bit TLS encryption for all data transmitted between your device and the Platform
• AES-256 encryption for personal and financial data at rest on ph635 servers
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Comprehensive audit logging of all access to personal data by ph635 personnel
• Regular penetration testing and vulnerability assessments by independent security firms
• Multi-factor authentication requirements for ph635 internal systems that handle member data
• Segregation of member funds from operational accounts to protect financial data integrity
• Annual security awareness training for all ph635 staff with access to personal data

8.2 While ph635 takes all reasonable steps to protect your data, no transmission or storage system is guaranteed to be completely secure. You are responsible for maintaining the security of your own account credentials and for notifying ph635 promptly if you suspect unauthorized access to your account.

9.1 ph635 uses cookies and similar technologies to operate the Platform effectively and to improve your experience. The following cookie categories are used:

• Strictly Necessary Cookies: Session cookies required to keep you logged in and maintain your session state while you navigate the Platform. These cannot be disabled as the Platform will not function without them.
• Functional Cookies: Cookies that remember your preferences, such as your preferred language settings and display configuration. These improve convenience but are not essential.
• Analytics Cookies: Anonymized and aggregated cookies used to understand how members use the Platform — which pages are most visited, where navigation difficulties occur, and how features are used. This data informs Platform improvements. Analytics data is never linked to your individual identity.

9.2 ph635 does not use advertising or tracking cookies to serve targeted third-party advertisements. ph635 does not use fingerprinting technologies or cross-site tracking of any kind.

9.3 You may manage and delete cookies through your browser settings. Note that disabling functional cookies may affect certain non-essential Platform features. Disabling strictly necessary cookies will prevent access to the Platform as a logged-in member.

10.1 Under Republic Act No. 10173, you have the following rights in relation to your personal data held by ph635:

10.2 To exercise any of the rights above, submit a written request to ph635's Data Protection Officer at the contact details in Section 15. ph635 will respond within fifteen (15) business days of receiving a valid, verifiable request. ph635 may request additional information to verify your identity before processing a data subject request.

10.3 ph635 will not charge a fee for processing data subject requests unless the request is manifestly unfounded, excessive, or repetitive, in which case a reasonable administrative fee may be applied.

11.1 The ph635 Platform is strictly for adults aged 21 and above as mandated by PAGCOR. ph635 does not knowingly collect personal data from persons under the age of 21.

11.2 Account holders who share devices with minors are solely responsible for preventing those minors from accessing their ph635 account. ph635 recommends activating device-level passcodes and browser-level password management to prevent unauthorized access by minors.

12.1 Some of ph635's third-party service providers — including cloud infrastructure and analytics providers — may process or store data on servers located outside the Philippines. Where such transfers occur, ph635 ensures that adequate safeguards are in place to protect your personal data, including contractual clauses that require overseas processors to maintain data protection standards equivalent to those required under the DPA.

12.2 ph635 will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, notifying the NPC.

13.1 In the event of a personal data breach that is likely to result in a real risk of serious harm to affected data subjects, ph635 will notify the NPC within seventy-two (72) hours of becoming aware of the breach, in accordance with the NPC's breach notification guidelines.

13.2 Affected members will be notified of a breach without undue delay where the breach is likely to result in high risk to their personal rights and freedoms. The notification will include a description of the nature of the breach, the categories and volume of data affected, the likely consequences, and the measures taken or proposed to address the breach.

13.3 ph635 maintains a documented data breach response plan and conducts annual breach response drills to ensure that the response team is prepared to act swiftly and effectively in the event of an incident.

14.1 ph635 may update this Privacy Policy periodically to reflect changes in its data processing practices, regulatory requirements, or platform features. The updated Policy will be published on this page with a revised effective date.

14.2 Where amendments are material — meaning they significantly affect how your personal data is processed or your rights as a data subject — ph635 will provide advance notice of at least fourteen (14) days by email to your registered address before the changes take effect.

14.3 Your continued use of the ph635 Platform following the effective date of an updated Policy constitutes acceptance of the revised terms. If you do not agree to the updated Policy, you may close your account by contacting ph635 support before the effective date.

15.1 For any questions, concerns, or requests relating to this Privacy Policy or to ph635's processing of your personal data, please contact the ph635 Data Protection Officer:

15.2 If you are not satisfied with ph635's response to your data subject request or believe ph635 has violated your rights under the DPA, you may file a complaint with the National Privacy Commission of the Philippines.