ph49 Privacy Policy

ph49 ("ph49", "we", "us", "the Platform") operates the online gaming platform accessible at ph49.club. As a platform serving Filipino players, ph49 handles personal data in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and the Implementing Rules and Regulations issued by the National Privacy Commission of the Philippines ("NPC").

This Privacy Policy ("Policy") applies to all personal data collected from individuals who visit, register on, or interact with ph49's website, mobile browser interface, customer support channels, and related services. By creating a ph49 account or using ph49 services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with ph49's Terms and Conditions and Responsible Gaming Policy, both of which are available on ph49.club and incorporate privacy-related obligations.

For the purposes of the Philippine Data Privacy Act and this Policy, ph49 acts as the Personal Information Controller (PIC) with respect to the personal data of its registered players and website visitors. ph49 determines the purposes and means of processing personal data collected through its platform.

Where ph49 engages third-party service providers — such as payment processors, game software developers, identity verification services, or customer support tools — those providers may act as Personal Information Processors (PIPs) on ph49's behalf and are bound by data processing agreements consistent with the requirements of the DPA.

ph49 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the DPA. Contact details for the ph49 DPO are provided in Section 14 of this Policy.

ph49 collects personal data from you through the following channels: account registration, KYC verification, deposits and withdrawals, gameplay activity, customer support interactions, and your use of ph49's website. The categories of personal data we collect include:

• Full legal name as it appears on a government-issued Philippine identification document
• Date of birth (for 21+ age verification)
• Registered Philippine mobile number
• Account username and encrypted password credentials
• Email address (where provided)
• Residential address in the Philippines

• Government-issued photo identification (e.g., Philippine National ID, passport, driver's license, SSS/GSIS ID)
• Proof of address documents where required
• Selfie or facial image submitted for identity matching purposes
• Source of funds documentation for high-value accounts as required by AML obligations

• GCash number and/or PayMaya account details used for deposits and withdrawals
• Philippine bank account details (BPI, BDO, Metrobank) where used as withdrawal destination
• Deposit amounts, withdrawal requests, transaction timestamps, and payment references
• Wallet balance history and bonus credit records

• Game sessions including titles played, bet amounts, results, and session durations
• Responsible gaming limit settings and self-exclusion status
• Bonus and promotion participation records

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Session identifiers, authentication tokens, and login timestamps
• Cookie and tracking data as described in Section 7

• Records of customer support interactions via live chat
• Account notifications and system messages
• Feedback, complaints, and dispute records

ph49 processes your personal data only for specified, explicit, and legitimate purposes. The table below summarizes the primary purposes for which ph49 uses the personal data it collects:

ph49 does not use your personal data for purposes incompatible with those listed above. ph49 does not sell or rent personal data to third-party marketers.

Under the Philippine Data Privacy Act, ph49 processes your personal data on the following lawful bases:

• Contractual necessity: Processing necessary to perform the contract between you and ph49, including account registration, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR-aligned operational requirements, and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for ph49's legitimate interests, including platform security, fraud prevention, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for optional marketing communications and certain non-essential cookie processing. You may withdraw consent at any time.

ph49 does not sell, rent, or trade your personal data. ph49 may share personal data with third parties only in the following circumstances and only to the minimum extent necessary:

• Payment processors: GCash (GXI), PayMaya (Maya Bank), and Philippine banking institutions for the processing of deposits and withdrawals. These entities are independent data controllers subject to their own privacy policies and Philippine BSP regulations.
• Game software providers: Licensed game developers (e.g., PG Soft, Pragmatic Play, Jili) may receive anonymized or pseudonymized session data necessary for game delivery and fair play monitoring.
• Identity verification services: Third-party KYC and AML screening providers engaged to verify player identities and screen against financial crime watchlists.
• Customer support platform providers: Live chat and support ticketing tools used to manage player communications may process limited account identifiers.
• Legal and regulatory authorities: ph49 will disclose personal data to Philippine government agencies, law enforcement, courts, or regulators where required to do so by law, valid court order, or regulatory directive.

All third-party processors engaged by ph49 are required to maintain data protection standards consistent with the Philippine Data Privacy Act and are bound by data processing agreements prohibiting unauthorized secondary use of your data.

ph49 uses cookies and similar tracking technologies on its website to support platform functionality, enhance user experience, and analyze site performance. The types of cookies used by ph49 include:

• Essential cookies: Required for the platform to function. These include session authentication tokens, login state cookies, and security identifiers. These cannot be disabled without disrupting service functionality.
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits across sessions.
• Analytics cookies: Collect aggregate, anonymized data about how players navigate and use ph49's platform, used to improve site performance and user experience.
• Security cookies: Used for fraud detection and to identify suspicious login patterns or bot activity.

ph49 does not use third-party advertising cookies or share cookie data with advertising networks. You may configure your browser to block or delete cookies; however, disabling essential cookies will prevent you from accessing ph49 account features.

ph49 retains personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law. Specific retention periods applicable to key data categories:

• Account and identity data: Retained for the duration of your active ph49 account, plus a minimum of 5 years following account closure, in compliance with AML record-keeping requirements under Philippine law.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction.
• KYC verification documents: Retained for the period of the account relationship plus 5 years post-closure.
• Customer support communications: Retained for 3 years from the date of the communication.
• Technical and device data: Retained for 12 months for security and fraud analysis purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ph49's data disposal procedures. Data subject to an ongoing legal or regulatory proceeding will be retained until the matter is fully resolved.

ph49 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph49 servers
• Encryption of sensitive data fields (passwords, financial identifiers) at rest in ph49's databases
• Access controls limiting personal data access to authorized ph49 personnel on a need-to-know basis
• Regular security assessments and vulnerability monitoring of ph49's platform infrastructure
• Multi-factor authentication requirements for administrative system access
• Incident response procedures for detecting and managing personal data breaches

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by ph49:

• Right to be Informed: The right to be notified of how your personal data is being collected and processed — as provided by this Policy.
• Right of Access: The right to request a copy of the personal data ph49 holds about you, including information on how it is being processed.
• Right to Correction/Rectification: The right to request correction of inaccurate, incomplete, or outdated personal data in your ph49 account.
• Right to Erasure/Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph49's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data on grounds relating to your particular situation, or where processing is for direct marketing purposes.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format where processing is carried out by automated means.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe ph49 has violated your data privacy rights.

To exercise any of the above rights, please contact ph49's Data Protection Officer using the contact details in Section 14. ph49 will respond to rights requests within thirty (30) days of receipt. Identity verification may be required before processing rights requests.

ph49 does not knowingly collect personal data from individuals under 21 years of age. The 21-year minimum age requirement for ph49 account registration is enforced through identity verification at registration and ongoing KYC procedures. ph49 does not direct any of its services, communications, or marketing toward minors.

If ph49 becomes aware that it has inadvertently collected personal data from an individual who is under 21 years of age, ph49 will promptly delete such data, suspend the associated account, and take appropriate corrective action. If you believe a minor has accessed or registered on ph49's platform, please contact ph49 support immediately.

Some of ph49's third-party service providers — including game software developers and technical infrastructure providers — may be located or operate servers outside of the Philippines. Where personal data is transferred to recipients in countries outside the Philippines, ph49 ensures such transfers are conducted in compliance with the Data Privacy Act and applicable NPC guidelines, including through appropriate contractual safeguards or adequacy determinations.

ph49 does not transfer personal data to jurisdictions that do not provide an adequate level of protection without implementing appropriate safeguards, including data processing agreements that impose obligations equivalent to those required by Philippine data privacy law.

ph49 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The revised Policy will be published on ph49.club with an updated effective date. Material changes will be communicated to registered players via account notifications.

Your continued use of ph49 services after the effective date of a revised Policy constitutes your acknowledgment of and agreement to the updated terms. If you do not accept the revised Policy, you should discontinue use of ph49 services and may request account closure in accordance with ph49's Terms and Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or ph49's handling of your personal data, please contact ph49's Data Protection Officer:

You also have the right to file a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government website at privacy.gov.ph.