ph2365 Privacy Policy

1. Introduction

ph2365 is a Philippine-focused online casino and sports betting platform operating under the oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). In the course of providing our gaming services to Filipino players, ph2365 necessarily collects and processes certain personal information. We take this responsibility seriously.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and relevant issuances of the National Privacy Commission (NPC). It applies to all personal data collected through the ph2365 website, customer support channels, and any other interaction you have with ph2365.

This Policy should be read alongside our Terms & Conditions, which govern your overall use of the ph2365 platform. In the event of any inconsistency between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, ph2365 is the Personal Information Controller in respect of the personal data collected and processed through the ph2365 platform.

Our Data Protection Officer (DPO) is responsible for overseeing compliance with this Policy and with the DPA. You may direct any data privacy queries, requests, or complaints to our DPO using the contact details provided in Section 14 of this Policy.

ph2365 has registered its data processing systems with the National Privacy Commission (NPC) as required under the DPA and its implementing rules.

3. Personal Data We Collect

ph2365 collects the following categories of personal data about you, depending on how you interact with our platform:

3.1 Identity & Contact Information

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — you must be 21 or older)
• Gender
• Registered email address
• Philippine mobile number
• Residential address (barangay, city/municipality, province)
• Nationality

3.2 Identity Verification (KYC) Documents

• Scanned copies or photographs of government-issued Philippine identification documents (e.g., Philippine Passport, SSS/UMID Card, PhilSys National ID, Driver's License, Voter's ID, PRC ID)
• Selfie photographs for liveness verification purposes
• Proof of address documentation where required

3.3 Financial Information

• GCash and Maya wallet numbers linked to your account
• Bank account details (BPI, BDO, Metrobank, and other Philippine banks) used for deposits and withdrawals
• Transaction history: deposits, withdrawals, and gaming wagering records
• Account balance and bonus wallet balances

3.4 Gaming Activity Data

• Game session logs (games played, duration, bet amounts, outcomes)
• Sports betting history (markets selected, stakes, results)
• Bonus and promotional offer interactions
• Responsible gaming tool usage (deposit limits set, self-exclusion periods activated)

3.5 Technical & Device Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system, and browser version
• Session timestamps and login/logout records
• Cookie identifiers and similar tracking technology data (see Section 7)

3.6 Communications Data

• Records of customer support interactions (live chat transcripts, email correspondence)
• Feedback and complaint submissions
• Promotional communication preferences (opt-in/opt-out records)

4. How We Collect Your Personal Data

ph2365 collects your personal data through the following means:

Collection Method	Examples
Direct provision by you	Account registration form, KYC document submission, customer support enquiries, payment transactions
Automated technical collection	Cookies, session logs, IP address capture, device fingerprinting on platform access
Payment processor data	Transaction confirmation data received from GCash, Maya, BPI, BDO, and other payment providers upon deposit or withdrawal
Identity verification providers	KYC verification results from accredited Philippine identity verification service providers
Regulatory authorities	Information received from PAGCOR, AMLC, or other competent Philippine regulatory bodies where required by law
Publicly available sources	Publicly available government databases or court records consulted for fraud prevention and AML compliance purposes

5. Purpose of Processing & Legal Basis

ph2365 processes your personal data for the following purposes, each grounded in a legal basis under the Data Privacy Act of 2012:

Purpose	Legal Basis (DPA)
Account registration and management	Performance of contract (your player account agreement with ph2365)
KYC identity and age verification (21+)	Legal obligation (PAGCOR regulations, DPA, AMLA)
Processing deposits, withdrawals, and gaming transactions	Performance of contract
Anti-money laundering monitoring and reporting	Legal obligation (Republic Act No. 9160, as amended)
Fraud detection and platform security	Legitimate interests of ph2365 and protection of other players
Customer support and complaint handling	Performance of contract; legitimate interests
Responsible gaming monitoring and intervention	Legal obligation (PAGCOR responsible gaming requirements)
Sending promotional communications (where opted in)	Your explicit consent
Platform analytics and service improvement	Legitimate interests (using anonymised/aggregated data where possible)
Legal proceedings and regulatory compliance	Legal obligation; legitimate interests

6. Sharing Your Personal Data

ph2365 does not sell, rent, or commercially transfer your personal data to third parties. We share personal data only in the following limited circumstances:

6.1 Regulatory & Law Enforcement Bodies

ph2365 is legally required to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the Bangko Sentral ng Pilipinas (BSP), and other competent Philippine government authorities where mandated by law. We may also disclose data in response to a valid and lawful court order, subpoena, or equivalent legal process.

6.2 Payment Processors

To process your deposits and withdrawals, ph2365 must share relevant transaction data with our Philippine payment partners, including GCash (Globe Fintech Innovations, Inc.), Maya Philippines, Inc., BPI, BDO Unibank, Metrobank, and other payment infrastructure providers. These providers process your data only as strictly necessary to execute the requested transaction and are bound by their own data protection obligations under Philippine law.

6.3 KYC & Identity Verification Providers

ph2365 engages accredited third-party identity verification service providers to conduct KYC checks on player accounts. These providers receive only the minimum data necessary to perform the verification and are contractually prohibited from using the data for any other purpose.

6.4 Technology & Platform Service Providers

ph2365 uses third-party service providers to support platform operations, including cloud hosting, security monitoring, and analytics tools. These providers act as personal information processors on our behalf and are bound by data processing agreements that restrict their use of your data to the provision of services to ph2365 only.

6.5 Game Content Providers

ph2365's game library is powered by third-party providers including, but not limited to, Pragmatic Play, Evolution Gaming, PG Soft, and other certified operators. Certain technical data (such as session tokens and player IDs, but not full identity data) may be transmitted to game servers as part of normal game operation. These providers are subject to their own certification requirements and data handling standards.

6.6 With Your Explicit Consent

In circumstances not covered above, ph2365 will only share your personal data with third parties upon obtaining your prior, explicit, and freely given consent.

7. Cookies & Tracking Technologies

ph2365 uses cookies and similar tracking technologies to operate the platform effectively, enhance your experience, and gather analytics that help us improve our services. The following categories of cookies are used:

Cookie Type	Purpose	Required?
Strictly Necessary	Essential for the platform to function — manages your login session, security tokens, and shopping cart	Yes — cannot be disabled
Functional	Remembers your preferences such as language settings and responsible gaming limits	Optional
Analytics	Collects anonymised data on platform usage patterns to help us improve performance and UX	Optional
Security	Used for fraud detection, bot prevention, and suspicious session identification	Yes — cannot be disabled

You may control optional cookies through your browser settings. Note that disabling certain functional cookies may affect your experience on the ph2365 platform. ph2365 does not use cookies for third-party advertising or cross-site behavioural tracking.

8. Data Security

ph2365 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and ph2365 servers
• At-rest encryption for all personal data and sensitive financial information stored in ph2365 databases
• Access controls: strict role-based access to personal data, limited to employees who require it to perform their job functions
• Two-factor authentication (2FA) available and strongly recommended for all player accounts
• Regular penetration testing and vulnerability assessments conducted by independent security professionals
• Security incident response procedures with defined timeframes for breach notification to the NPC and to affected players, as required by the DPA
• Employee data privacy training conducted regularly for all ph2365 staff handling personal data

9. Retention Periods

ph2365 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention period required by Philippine law. The following general retention periods apply:

Data Category	Retention Period	Basis
Account identity & KYC documents	5 years after account closure	PAGCOR requirements; AMLA obligations
Financial transaction records	5 years from transaction date	AMLA (RA 9160, as amended); BSP regulations
Gaming activity logs	3 years after account closure	PAGCOR audit requirements
Customer support communications	2 years from last interaction	Legitimate interests (complaint resolution)
Security and access logs	1 year from creation	Security monitoring and incident investigation
Marketing consent records	Until consent withdrawn + 1 year	NPC guidance on consent records

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised such that it can no longer be associated with you as an individual.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by ph2365. These rights are not absolute and are subject to certain legal limitations, but ph2365 is committed to facilitating their exercise:

To exercise any of the above rights, please contact our Data Protection Officer as described in Section 14. ph2365 will respond to data subject requests within 30 calendar days of receipt of a complete and verified request. In complex cases, this period may be extended by a further 30 days, in which case we will notify you of the extension and the reasons for it.

ph2365 will not charge a fee for data subject requests unless they are manifestly unfounded, excessive, or repetitive, in which case a reasonable administrative fee may apply.

11. Minors & Age Policy

The ph2365 platform is strictly for players aged 21 years and above, in compliance with PAGCOR regulations governing online gambling in the Philippines. ph2365 does not knowingly collect or process personal data from individuals under the age of 21.

If ph2365 becomes aware that it has inadvertently collected personal data from an individual who is under 21 years of age, we will take immediate steps to permanently delete that data and close the associated account. All deposits and gaming balances will be handled in accordance with applicable PAGCOR guidelines on underage gambling incidents.

If you believe that a minor has accessed or registered on ph2365, please contact us immediately at [email protected] so we can take prompt action.

12. International Data Transfers

As an online platform, ph2365 may use cloud infrastructure, game servers, or service providers whose data centres are located outside the Philippines. In any instance where personal data is transferred to or processed in a country outside the Philippines, ph2365 ensures that such transfers comply with the Data Privacy Act of 2012 by implementing appropriate safeguards, which may include:

• Contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under Philippine law
• Transferring only to jurisdictions recognised by the NPC as providing an adequate level of data protection
• Implementing binding corporate rules where applicable

ph2365 does not transfer your sensitive personal information (including KYC documents and financial data) to third parties located outside the Philippines except where strictly required to fulfil a regulatory obligation.

13. Changes to This Privacy Policy

ph2365 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidelines. We will notify registered players of material changes via the email address associated with their ph2365 account at least 15 days before the revised Policy takes effect. The effective date of the current version is displayed at the top of this page.

We encourage you to review this Policy periodically. Continued use of the ph2365 platform after a revised Policy takes effect constitutes your acceptance of the updated terms. If you do not agree with the changes, you may close your account by contacting our support team.

14. Contact Us & Privacy Complaints

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a data privacy concern or complaint, please contact ph2365's Data Protection Officer using the details below:

If you are not satisfied with ph2365's response to your privacy complaint or believe that ph2365 has violated your rights under the Data Privacy Act of 2012, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and enforcing the DPA in the Philippines.

For further information about responsible gaming, please visit our Responsible Gaming page. For the full terms governing your use of the ph2365 platform, please read our Terms & Conditions.