ph626 Privacy Policy

1 Data Controller Identity

For the purposes of the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, the personal data controller responsible for your information is:

As the personal information controller, ph626 determines the purposes and means of processing your personal data in connection with your use of the ph626 Platform, including registration, gaming activity, financial transactions, customer support interactions, and marketing communications where applicable.

2 Personal Data We Collect

ph626 collects the following categories of personal data from players and users of the Platform:

ph626 does not collect sensitive personal information as defined under RA 10173 (such as racial or ethnic origin, religious beliefs, health data, sexual orientation, or criminal records) unless specifically required by PAGCOR regulations or anti-money laundering compliance obligations.

3 How We Collect Your Data

ph626 collects personal data through the following means:

3.1 Directly from You

You provide personal data directly to ph626 when you register a ph626 account, complete the KYC identity verification process, make deposits or withdraw funds, contact ph626 customer support, participate in promotions or surveys, set responsible gaming limits or self-exclusion preferences, and when you update your account profile information.

3.2 Automatically Through Platform Use

When you access and use the ph626 Platform, technical and behavioural data is collected automatically through server logs, cookies, pixel tags, and analytics technologies. This includes device information, IP addresses, session durations, game interactions, and navigation patterns. This data is essential for platform security, fraud detection, and service improvement.

3.3 From Third-Party Payment Processors

When you use GCash, Maya, BPI, BDO, GrabPay, or 7-Eleven payment services to transact with ph626, those payment providers share transaction confirmation data with ph626 as necessary to complete your deposit or withdrawal. ph626 does not store full payment account credentials and relies on tokenized or reference identifiers provided by payment processors.

3.4 From Identity Verification Partners

ph626 may engage third-party KYC verification service providers to assist in verifying the identity documents submitted by players during the account verification process. These providers process identity documents on behalf of ph626 and are bound by strict data processing agreements.

4 Purposes of Processing

ph626 processes your personal data for the following purposes:

• Account Administration: Creating and managing your ph626 account, verifying your identity and age, and maintaining accurate account records.
• Service Delivery: Providing access to games, processing bets and game outcomes, crediting winnings, administering bonuses, and delivering all features of the ph626 Platform.
• Financial Processing: Processing deposits and withdrawals through your nominated payment method, maintaining transaction records, and reconciling account balances.
• Regulatory Compliance: Fulfilling obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), RA 10173, and other applicable Philippine laws, including the filing of mandatory reports with the Anti-Money Laundering Council (AMLC) where triggered by legal thresholds.
• Fraud Prevention and Security: Detecting and preventing unauthorized access, fraudulent transactions, money laundering, collusion, and other prohibited conduct on the ph626 Platform.
• Responsible Gaming: Administering deposit limits, loss limits, session limits, self-exclusion requests, and cool-off periods, and identifying players who may exhibit problem gambling indicators.
• Customer Support: Responding to inquiries, resolving disputes, processing complaints, and maintaining records of support interactions.
• Marketing and Promotions: Sending promotional communications, bonus offers, and platform updates to players who have opted in to receive such communications. You may withdraw this consent at any time.
• Platform Improvement: Analysing usage patterns and technical data to improve platform performance, user experience, and game offerings.
• Legal Proceedings: Pursuing or defending legal claims, complying with court orders or regulatory directives, and preserving legally privileged information.

5 Legal Basis for Processing

ph626 processes your personal data on the following lawful bases as provided under RA 10173:

5.1 Contractual Necessity

The processing of your identity data, contact data, account data, financial data, and gaming activity data is necessary for the performance of the contract between you and ph626 — that is, the ph626 Terms and Conditions that you agreed to upon registration. Without this data, ph626 cannot provide the gaming services you have requested.

5.2 Legal Obligation

ph626 is required by Philippine law — including PAGCOR licensing conditions, AMLA, and RA 10173 itself — to collect and retain certain categories of personal data. This includes KYC identity verification data and transaction records, which are maintained to satisfy regulatory audit and reporting requirements.

5.3 Legitimate Interests

ph626 processes technical and behavioural data for the purposes of fraud prevention, platform security, and service improvement on the basis of legitimate interests — specifically, the legitimate interest of ph626 and its players in maintaining a secure and well-functioning gaming platform. ph626 balances these interests against your privacy rights and applies appropriate technical and organisational safeguards.

5.4 Consent

Where ph626 processes your personal data for marketing communications, optional analytics, or any other purpose beyond those described above, ph626 does so on the basis of your freely given, specific, and informed consent. You may withdraw your consent to marketing communications at any time by updating your communication preferences in your ph626 account settings or by contacting ph626 support.

6 Data Sharing & Disclosure

ph626 does not sell your personal data to third parties. ph626 shares your personal data only in the following circumstances and only to the extent necessary for the specified purpose:

6.1 Service Providers and Processors

ph626 engages third-party service providers who process personal data on ph626's behalf, including payment processing partners (GCash, Maya, BPI, BDO, GrabPay), KYC and identity verification providers, game content suppliers (e.g. software providers supplying RNG-certified games and live dealer platforms), cloud infrastructure providers hosting the ph626 Platform, and customer communication platforms used to deliver support responses. All such providers are contractually bound to process personal data only as instructed by ph626, to maintain appropriate security standards, and to comply with RA 10173.

6.2 Regulatory and Law Enforcement Bodies

ph626 discloses personal data to PAGCOR, the AMLC, the National Privacy Commission (NPC), and other competent Philippine authorities where required by law, including in connection with the filing of covered and suspicious transaction reports under AMLA, the response to lawful data access orders, and the investigation of regulated gaming violations.

6.3 Legal Proceedings

ph626 may disclose personal data where necessary to establish, exercise, or defend legal claims in any court, tribunal, or administrative proceeding in which ph626 is a party or is otherwise required to participate.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ph626's business, personal data held by ph626 may be transferred to the acquiring entity, subject to the continued application of privacy protections equivalent to those described in this Privacy Policy. ph626 will notify affected players of any material change in data controller identity arising from such a transfer.

7 Data Retention

ph626 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by applicable Philippine law:

Upon expiry of the applicable retention period, ph626 will securely delete or anonymise your personal data unless further retention is required by a lawful court order, regulatory directive, or ongoing legal proceeding.

8 Data Security Measures

ph626 implements technical and organisational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Key security measures include:

• Encryption: All data transmitted between your device and the ph626 Platform is encrypted using 256-bit Transport Layer Security (TLS). Stored passwords are hashed using industry-standard algorithms; ph626 does not store plaintext passwords.
• Access Controls: Access to personal data within ph626 systems is restricted to authorized personnel on a need-to-know basis. All internal access is logged and subject to regular review.
• Two-Factor Authentication: ph626 supports two-factor authentication (2FA) for player accounts to provide an additional layer of access security.
• Regular Security Audits: ph626's technical infrastructure is subject to regular penetration testing, vulnerability assessments, and security audits by qualified independent security professionals.
• Incident Response: ph626 maintains a documented data breach response procedure. In the event of a personal data breach affecting your rights and freedoms, ph626 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with RA 10173.

9 Cookies & Tracking Technologies

The ph626 Platform uses cookies and similar tracking technologies to ensure proper platform functionality, enhance user experience, maintain session state, and support analytics and security monitoring. The following categories of cookies are used:

Essential Analytics Functional Marketing

9.1 Essential Cookies

Essential cookies are strictly necessary for the ph626 Platform to operate. They maintain your login session, remember your language and currency preferences, ensure secure authenticated access to your account, and support the Platform's fraud detection and security systems. These cookies cannot be disabled without impairing Platform functionality.

9.2 Analytics Cookies

Analytics cookies allow ph626 to understand how players use the Platform by collecting aggregated, anonymized data about page visits, session durations, feature interactions, and navigation paths. This data is used to improve Platform performance and user experience. Analytics cookies are set by ph626's analytics providers and do not identify individual users.

9.3 Functional Cookies

Functional cookies remember your account settings and preferences — such as preferred game categories, display settings, and responsible gaming configuration — to provide a more personalized experience. These cookies are not essential to Platform operation but enhance convenience.

9.4 Marketing Cookies

Marketing cookies are used to track your interaction with ph626 promotions and, where you have provided consent, to tailor promotional content to your interests and gaming preferences. These cookies are only active where you have provided explicit consent for marketing data processing.

You can manage cookie preferences through your browser settings. Please note that disabling essential cookies will significantly impair your ability to use the ph626 Platform, including maintaining your login session and accessing your account balance.

10 Your Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by ph626:

To exercise any of the above rights, please submit a Data Subject Request to ph626's Data Protection Officer via the contact details in Section 13. ph626 will acknowledge your request within 48 hours and respond substantively within fifteen (15) business days, or within such period as may be extended where the complexity of the request warrants additional time.

11 Protection of Minors

The ph626 Platform is strictly restricted to persons who are at least 21 years of age, in accordance with PAGCOR regulations governing casino-style gaming in the Philippines. ph626 does not knowingly collect personal data from individuals under the age of 21.

ph626 implements age verification controls during the account registration process and requires players to submit government-issued identity documents confirming their date of birth as part of the KYC process. Any account found to belong to a person under 21 years of age will be immediately suspended, and all data associated with that account will be deleted in accordance with applicable law following the conclusion of any regulatory reporting obligations.

If you are a parent or guardian and believe that a minor has registered a ph626 account or submitted personal data to ph626, please contact ph626's Data Protection Officer immediately using the contact details in Section 13. ph626 will investigate and take appropriate action without delay.

12 Cross-Border Data Transfers

ph626 may transfer personal data to third-party service providers located outside the Philippines where this is necessary for the operation of the Platform — for example, in connection with cloud infrastructure services, game technology providers, or KYC verification platforms that maintain data processing facilities in other jurisdictions.

Any such cross-border transfer of personal data will only be undertaken where ph626 has satisfied itself that adequate data protection safeguards are in place in the recipient jurisdiction, including through the use of contractual clauses requiring the recipient to maintain data protection standards equivalent to those required by RA 10173, as required by the National Privacy Commission's rules on cross-border data transfers.

ph626 will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining approval from the National Privacy Commission.

13 Data Protection Officer

ph626 has designated a Data Protection Officer (DPO) as required under RA 10173 and the implementing rules of the National Privacy Commission. The DPO is responsible for overseeing ph626's compliance with data privacy obligations, handling data subject requests, and serving as the point of contact for the National Privacy Commission.

If you are not satisfied with ph626's response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines through the NPC's official complaint channels.

14 Amendments to This Privacy Policy

ph626 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, business practices, or technology. When material amendments are made, ph626 will notify registered players by email to the address associated with their ph626 account and/or by a prominent notice displayed on the Platform upon login.

Amendments take effect seven (7) days after notification to registered players, or immediately where required by applicable law or NPC guidance. Your continued use of the ph626 Platform following the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

15 Contact Information

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph626, please contact us through any of the following channels:

• Live Chat: Available 24/7 directly within the ph626 Platform — the fastest channel for urgent privacy matters.
• Email: [email protected] — include "Privacy Policy" or "Data Privacy Request" in your subject line for direct routing to the DPO.
• Response Timeframe: ph626 acknowledges all privacy-related enquiries within 48 hours and provides substantive responses within 15 business days.

ph626 customer support operates in both English and Filipino (Tagalog) to ensure that all players across the Philippines — from Luzon to Visayas to Mindanao — can communicate their privacy concerns clearly and receive assistance in a language they are comfortable with.