ph351 Privacy Policy

This Privacy Policy applies to all personal data collected and processed by ph351 ("ph351", "we", "us", "our") in connection with the operation of the ph351.club online gaming platform, including its website, account portal, casino games, sports betting interface, bingo rooms, and customer support channels.

ph351 acts as the personal information controller in respect of the data described in this Policy, as that term is defined under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines (the "DPA"), and its Implementing Rules and Regulations ("IRR").

By creating an account, depositing funds, placing a wager, or otherwise using ph351 Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

ph351 collects the following categories of personal data in connection with the provision of its Services:

ph351 does not collect special categories of sensitive personal information — such as racial or ethnic origin, political opinions, religious beliefs, or health data — except to the extent that information about problem gambling risks is recorded as part of our responsible gaming obligations.

ph351 collects personal data through the following channels:

• Directly from you — when you create an account, submit KYC documents, make a deposit or withdrawal request, use live chat support, fill in a survey, or communicate with ph351 by any channel.
• Automatically through technical systems — when you access and navigate the ph351 platform, our servers and analytics systems collect technical and behavioural data through server logs, cookies, and similar tracking technologies as described in Section 9.
• From third-party service providers — including identity verification bureaus used during KYC processing, payment processors (including GCash, PayMaya, and banking partners), and fraud detection service providers. Data received from these sources is used only to supplement and verify the information you have already provided to ph351.

ph351 processes your personal data for the following purposes, each of which is supported by a lawful processing basis under the Data Privacy Act of 2012:

• Account creation and management — to establish and maintain your ph351 account, verify your identity, and administer your profile and preferences.
  • Legal basis: Performance of a contract (your agreement to the ph351 Terms & Conditions).
• Payment processing — to process deposits to and withdrawals from your ph351 wallet via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other supported payment methods.
  • Legal basis: Performance of a contract; compliance with legal obligations under applicable payment regulations.
• KYC and identity verification — to verify your identity and the authenticity of your payment methods in compliance with anti-money laundering obligations applicable in the Philippines.
  • Legal basis: Compliance with a legal obligation.
• Fraud prevention and security monitoring — to detect, investigate, and prevent fraudulent activity, money laundering, match-fixing, and other conduct prohibited under the ph351 Terms & Conditions and Applicable Law.
  • Legal basis: Legitimate interests of ph351; compliance with a legal obligation.
• Responsible gaming monitoring — to monitor player behaviour for indicators of problem gambling, to administer responsible gaming tools, and to fulfil any statutory reporting obligations.
  • Legal basis: Compliance with a legal obligation; legitimate interests of ph351 in promoting safe gambling.
• Customer support — to respond to your support requests, complaints, and dispute resolution queries.
  • Legal basis: Performance of a contract; legitimate interests.
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications.
  • Legal basis: Consent. You may withdraw consent at any time by updating your notification preferences in your account settings or by contacting support.
• Platform improvement and analytics — to understand how players navigate and use the ph351 platform, identify technical issues, and improve game offerings and user experience.
  • Legal basis: Legitimate interests of ph351 in improving its services.

ph351 does not sell or rent your personal data to third parties. We may share your data with the following categories of recipients only where necessary and consistent with the purposes described in Section 4:

• Payment service providers — GCash (Mynt), PayMaya (PayMongo/Voyager), and banking partners, for the purpose of processing your deposits and withdrawals.
• Identity verification providers — third-party KYC and document verification bureaus engaged to verify player identity and document authenticity as part of our compliance obligations.
• Technology and hosting providers — cloud infrastructure, data hosting, and platform technology providers who process data on ph351's behalf under binding data processing agreements.
• Fraud and AML service providers — third-party anti-money laundering screening and fraud detection systems that ph351 uses to monitor transactions and account activity.
• Regulatory and law enforcement authorities — where required by Applicable Law, court order, or official regulatory request from competent Philippine authorities, including PAGCOR and the AMLC (Anti-Money Laundering Council).
• Professional advisers — lawyers, auditors, and accountants who are bound by professional confidentiality obligations and who access data only as necessary to provide services to ph351.

All third-party data processors engaged by ph351 are required to process personal data only on documented instructions from ph351 and in accordance with the security and confidentiality requirements of the DPA and its IRR.

ph351 may transfer your personal data to service providers and technology partners whose systems are located outside the Philippines. Where such transfers occur, ph351 ensures that appropriate safeguards are in place consistent with Section 21 of the DPA, which may include:

• Data processing agreements incorporating the standard contractual clauses recognised under Philippine data privacy regulations.
• Transfers to jurisdictions that the National Privacy Commission has recognised as providing an adequate level of data protection.
• Binding corporate rules where the recipient is a member of ph351's corporate group.

ph351 will not transfer your personal data internationally in circumstances where adequate protections cannot be established.

ph351 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, unless a longer retention period is required by law. The following general retention principles apply:

• Account data is retained for the duration of your active ph351 account and for a period of up to five (5) years following account closure, consistent with Philippine statutory limitation periods for civil claims.
• Transaction and financial records are retained for a minimum of five (5) years following the transaction date, as required under the Anti-Money Laundering Act of 2001 (AMLA) and its amendments.
• KYC documents are retained for the period required under applicable AML and gaming regulations, typically five (5) years from the date of submission.
• Customer support communications are retained for a period of two (2) years from the date of last communication, unless they relate to a dispute or investigation that requires longer retention.
• Marketing preference data is retained until you withdraw consent or until your account is closed, whichever occurs first.

Upon expiry of the applicable retention period, ph351 will securely delete or anonymise your personal data so that it can no longer be attributed to any identifiable individual.

ph351 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, disclosure, or destruction. These measures include:

• 256-bit Secure Sockets Layer (SSL) encryption for all data transmitted between your browser or device and the ph351 platform.
• Encrypted storage of sensitive personal and financial data at rest, using industry-standard encryption algorithms.
• Role-based access controls that limit internal access to personal data to personnel who require it for their job function.
• Regular security assessments and penetration testing of ph351's platform and infrastructure.
• Automated monitoring systems that detect and alert to anomalous account activity, failed authentication attempts, and potential fraud indicators.
• Incident response procedures consistent with the data breach notification requirements of the DPA and its IRR, including notification to the National Privacy Commission where required.

ph351 uses cookies and similar tracking technologies on the ph351.club website and platform. Cookies are small text files stored on your device that enable ph351 to recognise your browser, maintain your session, and improve your experience.

ph351 uses the following categories of cookies:

• Strictly necessary cookies — required for the platform to function correctly. These enable account login sessions, security token validation, and basic platform navigation. They cannot be disabled without impairing your ability to use ph351 Services.
• Functional cookies — used to remember your preferences, such as game display settings, language preferences, and responsible gaming limit configurations.
• Analytics cookies — used to collect aggregated data about how players navigate and interact with the ph351 platform. This information is used to improve the platform experience and is not used to identify individual players for marketing purposes.
• Security cookies — used to detect fraudulent activity, identify unusual login patterns, and protect against cross-site request forgery and other web security threats.

You may configure your browser to refuse some or all cookies. Note that disabling strictly necessary cookies will affect your ability to log in and use real-money features on ph351. ph351 does not use third-party advertising or behavioural tracking cookies.

Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights in respect of your personal data held by ph351. These rights may be exercised by contacting ph351's privacy contact at the email address listed in Section 13:

ph351 will respond to verified data subject requests within thirty (30) days of receipt, or within such other timeframe as required by the DPA. We may request proof of identity before processing your request to ensure that personal data is not disclosed to an unauthorised party.

ph351 Services are intended exclusively for individuals who are 21 years of age or older. ph351 does not knowingly collect personal data from individuals under the age of 21. If ph351 becomes aware that a minor has provided personal data in connection with an account registration, the account will be closed immediately and any associated personal data will be deleted promptly, subject to any overriding legal retention obligations.

ph351 reserves the right to amend this Privacy Policy at any time to reflect changes in Applicable Law, regulatory guidance from the National Privacy Commission, changes in our data processing practices, or changes in the services we provide.

Where a material amendment is made to this Policy, ph351 will provide advance notice by email to your registered address or by a prominent notice on the ph351 platform, at least fourteen (14) days before the amended Policy takes effect. Continued use of ph351 Services after the effective date of an amendment constitutes your acceptance of the updated Policy.

The current version of this Policy, together with its "Last Updated" date, is always available at ph351.club/privacy-policy. We recommend that you review this page periodically to stay informed of any changes.

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or wish to raise a concern about how ph351 has handled your personal data, please contact ph351's privacy contact through either of the following channels:

• 24/7 Live Chat — available directly within your ph351 account portal for immediate assistance.
• Email — send your privacy enquiry to the support address listed in the footer of this page. Please mark the subject line with "Privacy Enquiry" to ensure prompt routing to the correct team.

ph351 will acknowledge receipt of your enquiry promptly and will endeavour to resolve it as quickly as possible. Complex requests may require additional time to process.

If you are not satisfied with ph351's response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC), which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information about the NPC's complaint process is available through the NPC's official government channels.