ph35 Privacy Policy

Section 1Introduction

ph35 ("ph35," "we," "us," or "our") operates the online gaming platform available at ph35.one. We are committed to protecting the privacy and security of the personal information you share with us when you use our platform.

This Privacy Policy ("Policy") describes how ph35 collects, uses, stores, shares, and protects your personal data. It applies to all users of the ph35 platform, including registered account holders, visitors to ph35.one, and anyone who contacts ph35's support team.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC). By using the ph35 platform, you acknowledge that you have read and understood this Policy.

Section 2Personal Data We Collect

ph35 collects the following categories of personal data from users:

ph35 does not collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. We do not collect biometric data, health information, or political opinions.

Section 3How We Collect Your Data

ph35 collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access ph35.one, including IP address, device identifiers, browser information, and session activity logs, via cookies and similar tracking technologies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud risk signals from payment processors; publicly available information used to verify your identity or detect suspicious activity.
• Payment Processors: Transaction confirmation data from GCash, Maya, and partner banks when you make deposits or request withdrawals.

Section 4How We Use Your Personal Data

ph35 uses your personal data for the following purposes:

• Account Management: Creating and maintaining your ph35 account, verifying your identity and age (21+), and managing your account settings and preferences.
• Platform Operation: Processing your bets and game participation, crediting winnings, processing deposits and withdrawals, and providing access to ph35's full range of gaming products.
• Regulatory Compliance: Fulfilling our obligations under Philippine law, including PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) reporting obligations, and the Data Privacy Act of 2012.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct on the ph35 platform.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior and applying responsible gaming tools where appropriate, in accordance with PAGCOR guidelines.
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest, and always with an easy opt-out mechanism.
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve the ph35 platform, optimize game offerings, and enhance the user experience for Filipino players.

ph35 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 given explicit consent.

Section 5Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, ph35 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you — i.e., to operate your ph35 account, process transactions, and deliver gaming services as described in our Terms & Conditions.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing necessary for ph35's legitimate business interests, including fraud prevention, platform security, and improving our services — provided these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and optional analytics. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Section 6Data Sharing & Disclosure

ph35 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the following limited circumstances:

• Service Providers: Trusted third-party vendors who assist ph35 in operating the platform, including KYC verification providers, payment processors (GCash, Maya, partner banks), IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only on ph35's instructions and in compliance with the Data Privacy Act.
• Regulatory Authorities: Philippine government agencies and regulatory bodies, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, where disclosure is required by law or court order.
• Fraud Prevention Networks: Industry fraud prevention and responsible gaming databases, where sharing is necessary to protect the integrity of the platform and the welfare of players.
• Business Transfers: In the event of a merger, acquisition, or sale of ph35's business assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections. You will be notified of any such transfer.

All third parties with whom ph35 shares personal data are required to maintain appropriate technical and organizational security measures and to process data only for the purposes specified by ph35.

Section 7Cookies & Tracking Technologies

ph35 uses cookies and similar tracking technologies on ph35.one to enhance your experience, maintain session security, and analyze platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the ph35 platform, including session management, login authentication, and security functions. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how users interact with ph35.one to help us understand usage patterns and improve the platform. This data is aggregated and does not identify individual users.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the ph35 platform.

You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use the ph35 platform. ph35 does not use third-party advertising cookies or cross-site tracking technologies for behavioral advertising purposes.

Section 8Data Security

ph35 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security framework includes:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including financial information and identity documents, is encrypted using industry-standard algorithms.
• Access Controls: Personal data is accessible only to ph35 personnel and authorized service providers who have a legitimate need to access it. Access is governed by role-based permissions and multi-factor authentication requirements.
• Infrastructure Security: ph35 servers are hosted in secure, access-controlled data centers with physical security measures, redundant systems, and regular security audits.
• Penetration Testing: ph35 conducts regular security assessments and penetration tests to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: ph35 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, ph35 will notify the National Privacy Commission and affected users within the timeframes required by Philippine law.

Section 9Data Retention

ph35 retains your personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, ph35 will securely delete or anonymize your personal data in accordance with our data disposal procedures. Anonymized, aggregated data may be retained indefinitely for statistical and analytical purposes.

Section 10Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph35:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — which this Policy fulfills.
• Right of Access: The right to request a copy of the personal data ph35 holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You can update most account information directly through your ph35 account dashboard.
• 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 ph35's legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller where technically feasible.
• 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 Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph35 has violated your data privacy rights.

To exercise any of these rights, please contact ph35's Data Protection Officer using the contact details in Section 14. ph35 will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. We may request proof of identity before processing your request.

Section 11Children's Privacy

The ph35 platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing casino-style online gaming. ph35 does not knowingly collect personal data from individuals under the age of 21.

If ph35 discovers or is notified that personal data has been collected from a person under 21, we will immediately close the associated account, delete the personal data, and — where applicable — report the matter to the relevant regulatory authority.

Section 12International Data Transfers

ph35 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international KYC verification services.

Where such transfers occur, ph35 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law.
• Transfers only to countries or organizations that the National Privacy Commission has recognized as providing adequate levels of data protection.
• Implementation of additional technical security measures where required by the nature of the data being transferred.

By using the ph35 platform, you acknowledge that your personal data may be transferred internationally in accordance with the safeguards described above.

Section 13Updates to This Privacy Policy

ph35 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. When material changes are made, ph35 will:

• Post the updated Policy on ph35.one/privacy-policy with a revised "Last Updated" date.
• Notify registered users by email at least seven (7) days before the changes take effect, where the changes materially affect your rights or how we process your data.
• Where required by law, seek your renewed consent before processing your data under the updated terms.

Your continued use of the ph35 platform after the effective date of any update constitutes your acknowledgment of the revised Policy. We encourage you to review this page periodically to stay informed of how ph35 protects your personal information.

Section 14Contact & Data Protection Officer

ph35 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact us through the following channels:

• Data Protection Officer: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the ph35 platform dashboard

ph35 aims to acknowledge all privacy-related inquiries within two (2) business days and to resolve them within fifteen (15) business days. For complex requests, we will keep you informed of progress and any extensions to the response timeline.

If you are not satisfied with ph35's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines through their official channels.