ph946 Privacy Policy

1. Introduction

ph946 ("we," "us," "our," or the "Platform") is committed to protecting the privacy and personal data of all users ("you," "your," or the "User") who access and use the ph946 online gaming platform at ph946.cam. This Privacy Policy describes our practices regarding the collection, processing, storage, sharing, and protection of personal data in connection with your use of ph946's services.

ph946 operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and processes personal data in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the circulars issued by the National Privacy Commission (NPC). By creating an account or using the ph946 platform, 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.

This Privacy Policy should be read in conjunction with ph946's Terms and Conditions, which govern the overall legal relationship between you and the platform.

2. Information We Collect

2.1. Information You Provide Directly

When you register for an account, complete KYC verification, make deposits or withdrawals, or contact our customer support team, ph946 collects the following categories of personal data:

• Registration Data: Full legal name, date of birth, gender, Philippine mobile number, email address, and residential address (including city, province, and region);
• Identity Documents: Copies of government-issued Philippine identification (driver's license, passport, PhilSys national ID, SSS card, UMID, or PRC license) submitted for KYC verification;
• Selfie / Biometric Data: Photographs submitted for identity verification purposes as part of the KYC process;
• Financial Information: GCash wallet numbers, Maya account details, bank account numbers (BPI, BDO, Metrobank, UnionBank, or other Philippine banks), and transaction history on the ph946 platform;
• Account Preferences: Language preferences, notification settings, responsible gaming limits, and other account configurations set by you.

2.2. Information Collected Automatically

When you access the ph946 platform, we automatically collect certain technical data including:

• Device Information: Device type, operating system version, browser type and version, device identifiers, and screen resolution;
• Usage Data: IP address, pages visited, games played, session duration, click patterns, login timestamps, and navigation paths within the platform;
• Connection Data: Internet service provider, mobile network operator, and approximate geographic location derived from IP address;
• Performance Data: Error logs, crash reports, and technical diagnostics generated during platform use.

2.3. Information from Third Parties

ph946 may receive personal data about you from third-party sources in the following circumstances:

• Identity verification service providers who assist in validating KYC documentation;
• Payment processors and e-wallet providers (GCash, Maya) who confirm transaction details;
• Fraud prevention and anti-money laundering screening services that flag potential compliance risks;
• PAGCOR and other regulatory bodies in connection with compliance obligations.

3. How We Use Your Personal Data

ph946 processes personal data for the following purposes:

Purpose	Data Categories Used
Account creation and authentication	Registration data, device information
KYC identity and age verification	Identity documents, selfie, date of birth
Processing deposits and withdrawals	Financial information, transaction data
PAGCOR regulatory reporting	Identity data, transaction history, gameplay data
Anti-money laundering compliance (AMLA)	Identity data, financial information, transaction patterns
Fraud detection and platform security	Usage data, device information, IP address, financial data
Responsible gaming monitoring	Gameplay data, session duration, transaction history
Customer support services	Account data, communication records
Platform analytics and improvements	Usage data, performance data (anonymized where possible)
Promotional communications (opt-in only)	Email address, mobile number, preference data

4. Legal Basis for Processing

ph946 processes your personal data on the following legal bases as recognized under Republic Act No. 10173 and applicable regulations:

• Contractual Necessity: Processing necessary to perform the contract between you and ph946, including account management, gameplay, and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) reporting requirements, National Internal Revenue Code tax obligations, and other applicable Philippine laws;
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your fundamental rights;
• Consent: Processing of data for optional purposes such as promotional communications, where you have provided freely given, specific, and informed consent. You may withdraw consent at any time through your account settings.

5. Data Sharing and Disclosure

5.1. Parties We Share Data With

ph946 does not sell or rent your personal data. We share personal data with third parties only in the following circumstances:

• Payment Processors: GCash (GXI/Globe), Maya (PayMaya Philippines), and Philippine banking institutions as necessary to process financial transactions on your behalf;
• KYC and Identity Verification Providers: Third-party services engaged to assist in verifying identity documents and detecting fraudulent submissions;
• Game Software Providers: Certified gaming software providers whose games are hosted on the ph946 platform may receive limited gameplay and session data for game performance and integrity monitoring purposes;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine government authorities as required by law, court order, or regulatory mandate;
• Technology Service Providers: Cloud hosting, cybersecurity, analytics, and customer support platform providers engaged under data processing agreements that require them to handle data only on our instructions and in compliance with applicable law;
• Professional Advisors: Legal counsel, auditors, and compliance consultants who require access to data in the performance of professional services, subject to confidentiality obligations.

5.2. Cross-Border Data Transfers

Where personal data is transferred to service providers operating outside the Philippines, ph946 ensures that such transfers are subject to appropriate safeguards consistent with NPC requirements, including contractual data protection clauses or transfers to jurisdictions offering equivalent data protection standards.

6. Data Retention

ph946 retains personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, and to resolve disputes. Specific retention periods are determined by the nature of the data and applicable regulatory requirements:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and BIR regulations;
• KYC documentation: Retained for a minimum of five (5) years following account closure or the completion of the last transaction, whichever is later;
• Gameplay and session logs: Retained for up to three (3) years for dispute resolution, responsible gaming monitoring, and regulatory reporting purposes;
• Technical logs: Retained for up to twelve (12) months for security and platform performance purposes;
• Marketing preferences: Retained until you withdraw consent or close your account, whichever occurs first.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be linked to an identifiable individual.

7. Security Measures

ph946 implements a multi-layered approach to personal data security designed to protect against unauthorized access, disclosure, alteration, and destruction of your information. Our security measures include:

• Transport Layer Security (TLS): All data transmitted between your device and ph946's servers is encrypted using 256-bit TLS encryption, the same standard used by Philippine online banking platforms;
• Password Security: Account passwords are stored as one-way cryptographic hashes using industry-standard hashing algorithms. ph946's systems never store your plaintext password;
• Access Controls: Personal data is accessible only to ph946 personnel who require it to perform their job functions, under strict role-based access controls;
• Two-Factor Authentication: Optional SMS-based two-factor authentication is available for all ph946 accounts to provide an additional layer of login security;
• Regular Security Audits: The ph946 platform undergoes regular security assessments and penetration testing conducted by qualified cybersecurity professionals;
• Data Breach Procedures: In the event of a personal data breach that poses risk to affected individuals, ph946 will notify the National Privacy Commission and affected users in accordance with NPC breach notification requirements.

8. Cookies and Tracking Technologies

8.1. Types of Cookies Used

ph946 uses cookies and similar tracking technologies to enhance your experience on the platform, maintain your session state, and collect analytics data. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function, including session management, authentication tokens, and security measures. These cannot be disabled without affecting platform functionality;
• Functional Cookies: Used to remember your preferences, language settings, and account configurations between sessions;
• Analytics Cookies: Used to collect aggregated data about how users interact with the platform, enabling us to identify areas for improvement. Analytics data is processed in a form that does not directly identify individual users;
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and abuse of the platform.

8.2. Managing Cookies

You can manage cookie preferences through your browser settings. Most modern browsers allow you to refuse or delete cookies. Note that disabling strictly necessary cookies will prevent you from logging in to your ph946 account or using core platform features. ph946 does not use third-party advertising cookies or behavioral tracking cookies for marketing profiling.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by ph946:

• Right to be Informed: The right to know what personal data we collect, how it is used, and with whom it is shared — as set out in this Privacy Policy;
• Right of Access: The right to request a copy of the personal data we hold about you, including information about the purposes of processing and categories of recipients;
• Right to Rectification: The right to request correction of inaccurate or outdated personal data. You may update certain information directly through your account settings or by contacting customer support;
• 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 our legal retention obligations;
• Right to Object: The right to object to specific processing activities, particularly processing based on legitimate interests or processing for direct marketing purposes;
• Right to Data Portability: The right to receive personal data you have provided to ph946 in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe ph946 has processed your personal data in violation of applicable law.

To exercise any of these rights, please contact ph946 customer support through our live chat system or by emailing [email protected]. We will respond to data subject requests within thirty (30) days of receipt. Complex requests may require up to sixty (60) days with notification to you of the extended timeline.

10. Minors and Age Verification

ph946's services are strictly restricted to individuals who are 21 years of age or older, as required by PAGCOR regulations and Philippine law. We do not knowingly collect personal data from individuals below the age of 21. Age verification is enforced through mandatory KYC identity verification using government-issued Philippine identification documents.

If ph946 becomes aware that personal data has been collected from a user who is under 21 years of age, we will immediately close the associated account, delete the personal data collected, and void any transactions or balances. Parents and guardians who suspect that a minor has created an account on ph946 are encouraged to contact our customer support team immediately.

11. Changes to This Privacy Policy

ph946 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or operational circumstances. Changes will be effective upon publication of the updated Privacy Policy on ph946.cam. Where changes are material — meaning they significantly affect your rights or how we process your personal data — we will provide prominent notice through your registered email address or platform notification at least 15 days before the change takes effect.

Your continued use of the ph946 platform following the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We recommend reviewing this page periodically to stay informed about how your data is protected.

12. Contact and Data Protection Inquiries

For any questions, concerns, or requests relating to this Privacy Policy or ph946's personal data processing practices, please contact our data privacy team through the following channels:

• Live Chat: Available 24/7 through your ph946 account dashboard — the fastest channel for urgent privacy concerns;
• Email: [email protected] — for formal data subject access requests, complaints, or detailed privacy inquiries;
• Response Time: All privacy-related inquiries are acknowledged within 48 hours and resolved within 30 days of receipt.

If you are dissatisfied with ph946's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines, which is the supervisory authority for data protection in the Philippines.