ph858 Privacy Policy

1.1 This Privacy Policy ("Policy") applies to all personal information collected by ph858 through the ph858.app website and any related mobile applications, services, or platforms (collectively, the "Platform"). By accessing or using the ph858 Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and disclosure of your personal information as described herein.

1.2 This Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, which govern your use of the ph858 Platform. Defined terms used in this Policy have the same meaning as in our Terms & Conditions unless otherwise specified.

1.3 ph858 reserves the right to update or modify this Policy at any time. We will notify you of material changes by posting the updated Policy on the Platform and updating the "Last Updated" date. Your continued use of the Platform following any changes constitutes your acceptance of the revised Policy.

2.1 For the purposes of the Data Privacy Act of 2012, the data controller responsible for your personal information is:

2.2 Our Data Protection Officer (DPO) is responsible for overseeing compliance with this Policy and applicable data protection laws. If you have any questions, concerns, or complaints regarding our data practices, please contact our DPO using the contact information provided above.

3.1 ph858 collects various types of personal information to provide, maintain, and improve our services. The categories of personal information we collect include:

3.1.1 Information You Provide Directly

• Account Registration Data: Full name, date of birth, gender, email address, mobile phone number, residential address, and username.
• Identity Verification Documents: Government-issued ID (passport, driver's license, SSS/GSIS ID, PhilSys National ID), proof of address (utility bills, bank statements), and selfie photographs for facial verification.
• Financial Information: Bank account details, GCash or PayMaya account information, transaction history, deposit and withdrawal records, and source of funds documentation where required by AML regulations.
• Communication Data: Messages sent through live chat, emails to customer support, survey responses, and feedback submissions.

3.1.2 Information Collected Automatically

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, clickstream data, and referral sources.
• Location Data: Approximate geographic location derived from IP address to ensure compliance with geographic restrictions.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, and similar technologies (see Section 10 for details).

3.1.3 Information from Third Parties

• Payment Processors: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment providers.
• Identity Verification Services: Results of identity checks, fraud screening, and AML compliance checks performed by third-party verification providers.
• Game Providers: Gameplay data, RNG results, and game session information from third-party game suppliers integrated into the ph858 Platform.

4.1 ph858 uses your personal information for the following purposes:

4.2 We may also use aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you for statistical analysis, research, and business intelligence purposes.

5.1 Under the Data Privacy Act of 2012, ph858 processes your personal information based on one or more of the following legal grounds:

1. Consent: You have given explicit consent for us to process your personal data for specific purposes, such as receiving marketing communications.
2. Contract Performance: Processing is necessary to perform our contract with you (the Terms & Conditions) and to provide the gaming services you have requested.
3. Legal Obligation: Processing is required to comply with Philippine laws and regulations, including PAGCOR licensing requirements, AML obligations under RA 9160, and tax reporting requirements under the National Internal Revenue Code.
4. Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and platform improvement, provided these interests do not override your fundamental rights and freedoms.

5.2 Where we rely on your consent as the legal basis for processing, you have the right to withdraw your consent at any time by contacting [email protected]. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

6.1 ph858 does not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your personal data with the following categories of recipients for the purposes described in this Policy:

6.1.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment processors (GCash, PayMaya, banks) to facilitate deposits and withdrawals;
• Identity verification and KYC service providers to verify your identity and comply with AML regulations;
• Game providers and software suppliers to deliver gaming content;
• Cloud hosting and data storage providers to maintain our infrastructure;
• Customer support platforms and live chat services;
• Analytics and marketing service providers to improve our services and communicate with you.

All service providers are contractually bound to protect your personal information and use it only for the purposes we specify.

6.1.2 Regulatory and Law Enforcement Authorities

We may disclose your personal information to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), law enforcement agencies, and other government authorities when required by law or in response to valid legal requests.

6.1.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy.

6.1.4 With Your Consent

We may share your personal information with other third parties when you have given us explicit consent to do so.

7.1 ph858 implements industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized personnel only, based on the principle of least privilege. All employees and contractors with access to personal data are bound by confidentiality obligations.
• Secure Infrastructure: Our servers are hosted in secure, certified data centers with physical security controls, redundant systems, and regular backups.
• Monitoring and Logging: We maintain comprehensive audit logs and employ intrusion detection systems to monitor for suspicious activity.
• Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing to identify and remediate potential security risks.
• Incident Response: We maintain an incident response plan to quickly detect, contain, and respond to any data breaches or security incidents.

7.2 While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

7.3 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph858 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the requirements of the Data Privacy Act.

8.1 ph858 retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

8.2 Specific retention periods include:

• Account Data: Retained for the duration of your active account plus five (5) years after account closure, as required by PAGCOR regulations and AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLC and BIR requirements.
• KYC Documents: Retained for five (5) years after the termination of the business relationship, as required by AML regulations.
• Marketing Communications: Retained until you withdraw consent or unsubscribe, after which your data will be suppressed from marketing lists.
• Support Communications: Retained for three (3) years to maintain service quality and resolve disputes.

8.3 After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention and disposal procedures.

9.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal information:

1. Right to Be Informed: You have the right to be informed about the collection and processing of your personal data, which we fulfill through this Privacy Policy.
2. Right to Access: You have the right to request access to the personal information we hold about you and to obtain a copy of that information.
3. Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information.
4. Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal information, subject to legal retention requirements and legitimate grounds for continued processing.
5. Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes or where processing is based on legitimate interests.
6. Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
7. Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time.

9.2 To exercise any of these rights, please submit a written request to [email protected] or contact our Data Protection Officer at [email protected]. We will respond to your request within fifteen (15) days, or within such other timeframe as required by the Data Privacy Act.

9.3 We may require verification of your identity before processing your request to ensure the security of your personal information. In certain circumstances, we may be unable to fulfill your request due to legal obligations or legitimate grounds for continued processing, in which case we will explain the reasons for our decision.

9.4 If you are not satisfied with our response to your request or believe we have violated your data protection rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

10.1 ph858 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content and advertisements.

10.2 Types of Cookies We Use:

• Essential Cookies: Required for the Platform to function properly, including session management, authentication, and security features. These cookies cannot be disabled.
• Performance Cookies: Collect information about how you use the Platform, such as pages visited and errors encountered, to help us improve performance.
• Functional Cookies: Remember your preferences and settings to provide a more personalized experience.
• Marketing Cookies: Track your browsing activity to deliver targeted advertisements and measure the effectiveness of marketing campaigns.

10.3 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform and your ability to access certain features.

10.4 For more information about the specific cookies we use and how to manage them, please refer to our Cookie Policy available on the Platform.

11.1 The ph858 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal information from individuals under the age of 21.

11.2 If we become aware that we have inadvertently collected personal information from a person under 21 years of age, we will take immediate steps to delete that information and terminate the associated account.

11.3 If you are a parent or guardian and believe that your child has provided personal information to ph858, please contact us immediately at [email protected] so that we can take appropriate action.

11.4 We implement age verification measures during the account registration and KYC process to prevent underage gambling and comply with Philippine law.

12.1 Your personal information is primarily stored and processed within the Philippines. However, some of our service providers and technology partners may be located outside the Philippines, which may result in the transfer of your personal data to other jurisdictions.

12.2 Where we transfer personal data outside the Philippines, we ensure that appropriate safeguards are in place to protect your information in accordance with the Data Privacy Act, including:

• Ensuring the recipient country has been determined by the National Privacy Commission to have adequate data protection standards;
• Implementing standard contractual clauses or other legally recognized transfer mechanisms;
• Obtaining your explicit consent where required by law.

12.3 By using the ph858 Platform, you acknowledge and consent to the transfer of your personal information as described in this section.

13.1 ph858 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations.

13.2 We will notify you of any material changes by:

• Posting the updated Policy on the ph858 Platform with a revised "Last Updated" date;
• Sending an email notification to the address associated with your account;
• Displaying a prominent notice on the Platform.

13.3 Your continued use of the ph858 Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree to the changes, you must cease using the Platform and may request closure of your account.

13.4 We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information.

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the following information:

14.2 For complaints or concerns regarding our compliance with the Data Privacy Act, you may also contact the National Privacy Commission: