ph002 Privacy Policy

1. Introduction & Data Controller

ph002 ("we," "us," "our," or "ph002") operates the online gaming platform accessible at ph002.co and all associated subdomains and mobile interfaces (the "Platform"). ph002 acts as the data controller in respect of all personal data collected from players and visitors through the Platform.

This Privacy Policy applies to all personal data processed by ph002 in connection with your use of the Platform, including account registration, gaming activity, financial transactions, customer support interactions, and marketing communications. It should be read alongside our Terms & Conditions and Responsible Gaming policy.

ph002 processes personal data in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission ("NPC").

2. Personal Data We Collect

ph002 collects personal data from you directly when you register, transact, or interact with the Platform, and indirectly through automated means when you browse or play. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, gender, government-issued Philippine ID number (e.g., PhilSys, UMID, Passport, Driver's License), and facial image (for KYC verification).
• Contact Data: Email address, Philippine mobile number, and residential address (for KYC and withdrawal processing).
• Financial Data: GCash number or registered PayMaya account, BPI/BDO/Metrobank account details submitted for withdrawal, transaction amounts, deposit history, and withdrawal records.
• Gaming Data: Game session logs, bet history, game outcomes, wagering patterns, win/loss records, and bonus redemption history.
• Technical Data: IP address, device type and identifier, browser type and version, operating system, session duration, pages visited, and referring URLs.
• Communications Data: Records of support interactions via live chat, Messenger, Viber, and email, including the content of those communications.
• Preference Data: Responsible gaming settings, communication preferences, and opted-in marketing categories.

ph002 does not collect special categories of personal data (such as health data, political opinions, or religious beliefs) and does not require such data for any platform function.

3. How We Use Your Personal Data

ph002 uses the personal data described in Section 2 for the following purposes:

• Account Registration & Management: To create, verify, and maintain your ph002 player account, including KYC identity verification required before processing withdrawals.
• Gaming Services: To deliver the games, sports betting, and other products available on the Platform, record game outcomes, and settle wagers accurately.
• Payment Processing: To process deposits via GCash, PayMaya, BPI, BDO, and Metrobank, and to fulfil withdrawal requests to your verified payment method.
• Regulatory & Legal Compliance: To comply with PAGCOR online gaming compliance requirements, the Anti-Money Laundering Act of 2001 (as amended), the Data Privacy Act of 2012, and other applicable Philippine laws. This includes transaction monitoring, suspicious activity reporting, and record retention obligations.
• Responsible Gaming: To monitor gaming patterns for indicators of problem gambling behaviour, enforce self-exclusion and deposit limit requests, and conduct age verification checks.
• Customer Support: To respond to queries, resolve complaints, and improve support quality through interaction records and feedback.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, account takeovers, collusion, money laundering, and other prohibited activities on the Platform.
• Marketing & Promotions: To send you promotional offers, bonus notifications, and platform updates via your preferred channel, where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time (see Section 11).
• Platform Improvement: To analyse aggregated usage data and improve the performance, user experience, and content of the Platform.

4. Legal Basis for Processing

ph002 processes your personal data on one or more of the following legal bases as provided under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform the contract between you and ph002 — including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulations, AML obligations, and NPC data protection requirements.
• Legitimate Interests: Processing for ph002's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed consent — primarily for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Cookies & Tracking Technologies

ph002 uses cookies and similar tracking technologies (collectively "Cookies") on the Platform for the following purposes:

• Strictly Necessary Cookies: Essential for the Platform to function, including session authentication, load balancing, and security tokens. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences, language settings, and responsible gaming configuration between sessions.
• Analytical Cookies: Collect anonymised data on how players interact with the Platform to help ph002 improve navigation, game presentation, and support workflows.
• Marketing Cookies: Used to deliver personalised promotional content within the Platform. Only applied where you have consented to marketing communications.

You may manage non-essential Cookie preferences through your browser settings or the cookie preference panel available on the Platform. Disabling strictly necessary Cookies will impair your ability to log in and use gaming features.

6. Data Sharing & Third Parties

ph002 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following limited circumstances:

• Payment Processors: Your financial data is shared with GCash (Mynt), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank solely to process your deposit and withdrawal transactions. Each processor is bound by its own data protection obligations.
• Game Content Providers: Game providers receive pseudonymised session and wagering data necessary to deliver game content and verify RNG certification compliance. Personal identity data is not shared with game providers.
• Identity Verification Services: KYC verification providers process your identity documents and facial images under strict data processing agreements, and may only use that data for the purpose of verifying your identity for ph002.
• Regulatory Authorities: ph002 may be required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government agencies in response to lawful demands or mandatory reporting obligations.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by ph002, under obligations of confidentiality.

All third-party service providers engaged by ph002 are required to process personal data only on ph002's documented instructions and to maintain appropriate technical and organisational security measures.

7. Data Retention

ph002 retains your personal data for as long as your account remains active and for such additional periods as required by applicable law or legitimate business purpose:

• Active Accounts: Personal data is retained throughout the life of your registered account.
• Closed Accounts: Following account closure, ph002 retains identity and transaction data for a minimum of five (5) years in compliance with AML record-keeping obligations under the Anti-Money Laundering Act of 2001, as amended.
• Communications Records: Support interaction logs are retained for up to three (3) years from the date of the interaction.
• Technical & Log Data: Server logs and session data are retained for up to twelve (12) months.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents re-identification.

8. Your Data Subject Rights

Under the Data Privacy Act of 2012 and subject to applicable exceptions, you have the following rights in respect of your personal data held by ph002:

• Right to Be Informed: The right to be notified of how your personal data is collected and processed — as set out in this Privacy Policy.
• Right of Access: The right to obtain confirmation of whether ph002 holds personal data about you and to receive a copy of that data.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update most account information directly through your account settings.
• 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 retention obligations under Philippine law.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller where technically feasible.
• Right to Object: The right to object to processing based on legitimate interests, including profiling for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact ph002's Data Protection Officer at the details provided in Section 13. ph002 will respond to verified requests within thirty (30) days of receipt.

9. Data Security

ph002 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph002 servers.
• Encryption of sensitive data fields (passwords, payment credentials) at rest using industry-standard hashing and encryption algorithms.
• Role-based access controls limiting access to personal data to ph002 staff with a legitimate need to process it.
• Regular security assessments, vulnerability scanning, and penetration testing of the Platform infrastructure.
• Two-factor authentication available to all registered players and mandatory for administrative access by ph002 staff.

Despite these measures, no method of internet transmission or electronic storage is completely secure. ph002 cannot guarantee absolute security but commits to notifying affected players and the National Privacy Commission in the event of a data breach that is likely to result in high risk to your rights and freedoms, in accordance with NPC Circular 16-03.

10. Children & Minors

ph002 does not knowingly collect personal data from or provide gaming services to persons under the age of twenty-one (21). The Platform is strictly intended for adult players aged 21 and above, consistent with PAGCOR's age requirements for online gaming in the Philippines.

If ph002 becomes aware that personal data has been collected from a person under 21, the account will be immediately suspended, all associated personal data will be deleted (subject to any mandatory legal retention obligations), and any balances will be returned to the payment method of record after identity verification of the account holder.

If you believe that a minor has registered on the Platform, please contact ph002 support immediately at the details provided in Section 13.

11. Marketing Communications

ph002 may send you promotional offers, bonus notifications, and platform news via email, SMS, Viber, or Messenger where you have opted in to receive marketing communications during registration or through your account settings.

You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any ph002 marketing email.
• Updating your communication preferences in the notifications section of your account settings.
• Contacting ph002 support via live chat or email to request removal from marketing lists.

Opting out of marketing communications does not affect transactional communications necessary for account management, such as withdrawal confirmations, security alerts, and KYC request notifications.

12. Changes to This Privacy Policy

ph002 may update this Privacy Policy from time to time to reflect changes in data processing practices, applicable law, or Platform features. Material changes will be notified to registered players via email or in-platform notification at least fourteen (14) days before the change takes effect, except where immediate amendment is required for legal compliance.

The "Last updated" date at the top of this page indicates when the Privacy Policy was most recently revised. Continued use of the Platform after the effective date of any amendment constitutes your acknowledgement of the revised Privacy Policy. If you do not accept the revised Privacy Policy, you must cease using the Platform and request account closure.

13. Contact & Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or your personal data held by ph002, you may contact us through the following channels:

• Live Chat: 24/7 via the chat widget on ph002.co
• Messenger / Viber: via ph002's official channels
• Email: [email protected]

If you are not satisfied with ph002's response to a data protection concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through the NPC's official channels. ph002 encourages you to contact us first to allow us the opportunity to address your concern directly.