ph35b Privacy Policy

1. Introduction

ph35b ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every player who uses the ph35b online gaming platform at ph35b.app. This Privacy Policy describes our practices regarding the collection, use, storage, sharing, and protection of personal data in connection with the ph35b service.

This policy is written in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). ph35b also observes the relevant data protection guidelines issued by PAGCOR in connection with online gaming operations.

Please read this Privacy Policy carefully. If you have questions about how ph35b handles your personal data, contact our Data Protection Officer using the details provided in Section 14 of this policy.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, ph35b is the personal information controller in respect of the personal data collected through the ph35b platform. This means ph35b determines the purposes and means of processing your personal data.

ph35b has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection law. You may contact the ph35b DPO at any time using the contact details set out in Section 14.

3. Data We Collect

ph35b collects the following categories of personal data from players and platform users:

ph35b collects only the personal data that is necessary for the purposes described in this policy. We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required by law or responsible gaming obligations.

4. How We Collect Data

ph35b collects personal data through the following means:

• Direct collection: Information you provide when registering a ph35b account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the ph35b platform, including IP address, device identifiers, browser information, and session activity logs.
• Cookies and tracking technologies: ph35b uses cookies and similar technologies to collect data about your browsing behaviour on the ph35b platform. See Section 8 for full details.
• Third-party sources: Identity and address verification data received from KYC service providers, fraud prevention agencies, and payment processors in connection with account verification and transaction processing.
• Payment providers: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners when you make deposits or request withdrawals.

Where ph35b receives personal data about you from a third party, we will handle that data in accordance with this Privacy Policy and notify you of the source where required by applicable law.

5. How We Use Your Data

ph35b uses your personal data for the following purposes:

• Account management: Creating and maintaining your ph35b player account, verifying your identity and age, and managing your account settings and preferences.
• Service delivery: Providing access to ph35b games, processing bets, calculating and paying out winnings, and delivering the full range of ph35b platform features.
• Financial transactions: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods, and maintaining accurate financial records.
• Legal and regulatory compliance: Fulfilling ph35b's obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, account takeover, and other security threats to the ph35b platform.
• Responsible gaming: Monitoring gaming behaviour to identify signs of problem gambling, enforcing deposit limits and self-exclusion requests, and complying with PAGCOR responsible gaming requirements.
• Customer support: Responding to your enquiries, resolving disputes, and providing technical assistance through the ph35b support team.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: Analysing aggregated usage data to improve the ph35b platform, optimise game performance, and develop new features.

ph35b will not use your personal data for any purpose that is incompatible with the purposes described above without first obtaining your consent or establishing another lawful basis for processing.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, ph35b processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the ph35b player agreement with you, including account registration, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulations, AMLA obligations, and NPC requirements.
• Legitimate interests: Processing necessary for ph35b's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications and certain cookie-based tracking. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

ph35b does not sell your personal data. We may share your personal data with the following categories of recipients only where necessary and in accordance with this Privacy Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, PESONet, and other payment partners, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to verify your identity, age, and address as required by PAGCOR and AMLA regulations.
• Fraud prevention and AML services: Specialist providers engaged to detect and prevent fraudulent activity and money laundering on the ph35b platform.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on ph35b's behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law or regulatory obligation.
• Law enforcement: Philippine law enforcement agencies where ph35b is legally required to disclose personal data in connection with a criminal investigation or court order.

All third-party service providers engaged by ph35b are required to process personal data only in accordance with ph35b's instructions and to implement appropriate technical and organisational security measures. ph35b does not transfer personal data outside the Philippines except where required by law or where adequate data protection safeguards are in place.

8. Cookies & Tracking Technologies

ph35b uses cookies and similar tracking technologies on the ph35b.app platform. Cookies are small text files stored on your device that help ph35b recognise you, remember your preferences, and understand how you use the platform.

ph35b uses the following types of cookies:

• Strictly necessary cookies: Essential for the ph35b platform to function. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised ph35b experience.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the ph35b platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Security cookies: Used to detect and prevent fraudulent activity, account takeover attempts, and other security threats on the ph35b platform.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the ph35b platform. ph35b does not use third-party advertising cookies or cross-site tracking technologies.

9. Data Security

ph35b implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph35b platform.
• Encryption at rest for sensitive personal and financial data stored on ph35b servers.
• Multi-factor authentication options for player accounts to prevent unauthorised access.
• Access controls limiting ph35b staff access to personal data on a strict need-to-know basis.
• Regular security audits and penetration testing of the ph35b platform infrastructure.
• Incident response procedures to detect, contain, and report data security incidents 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, ph35b will notify the National Privacy Commission and affected players in accordance with the timelines prescribed by the Data Privacy Act of 2012 and NPC Circular No. 16-03.

While ph35b takes all reasonable steps to protect your personal data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your ph35b login credentials and for notifying ph35b immediately if you suspect unauthorised access to your account.

10. Data Retention

ph35b retains personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your ph35b account and for a minimum of five (5) years following account closure, as required by AMLA and PAGCOR regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA record-keeping requirements.
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of lawful processing.

Upon expiry of the applicable retention period, ph35b will securely delete or anonymise your personal data. Where anonymisation is used, the resulting data no longer constitutes personal data and may be retained indefinitely for statistical and analytical purposes.

11. Your Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by ph35b:

• Right to be informed: The right to be told how your personal data is collected and used, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data ph35b holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held by ph35b.
• 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 ph35b'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 ph35b's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• 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 ph35b has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, contact the ph35b Data Protection Officer using the details in Section 14. ph35b will respond to all data rights requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, with prior notification to you.

ph35b may need to verify your identity before processing a data rights request to ensure that personal data is not disclosed to an unauthorised person.

12. Children & Minors

The ph35b platform is strictly intended for persons aged 21 years and above, in accordance with Philippine law and PAGCOR regulations governing online gaming. ph35b does not knowingly collect personal data from persons under 21 years of age.

If ph35b becomes aware that personal data has been collected from a person under 21 years of age, the associated account will be immediately suspended, all data will be deleted, and any deposits will be returned to the payment method used, subject to verification. If you believe that a minor has registered a ph35b account, please contact the ph35b support team immediately.

ph35b implements age verification procedures during registration and KYC review to prevent underage access to the platform. These procedures include documentary verification of date of birth using government-issued identification.

13. Changes to This Policy

ph35b 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. Where changes are material, ph35b will notify registered players by email or through an in-platform notification prior to the changes taking effect.

The date of the most recent update is displayed at the top of this page. Your continued use of the ph35b platform following the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about how ph35b protects your personal data.

14. Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or ph35b's handling of your personal data, please contact the ph35b Data Protection Officer:

If you are not satisfied with ph35b's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information about filing a complaint with the NPC is available through official Philippine government channels.

ph35b takes all privacy complaints seriously and will investigate every concern raised in good faith. We are committed to resolving privacy issues promptly and transparently in accordance with our obligations under Philippine data protection law.