ph93 Privacy Policy – How We Collect, Use, and Protect Your Data

1. Introduction

ph93 ("ph93," "we," "us," or "our") is the operator of the online gaming platform accessible at ph93.club and its associated mobile interfaces (collectively, the "Platform"). ph93 is committed to protecting the privacy and personal data of all users ("you," "your," or "Data Subject") in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy describes the categories of personal data we collect, the purposes for which we process that data, the legal bases for processing, how long we retain data, with whom we share it, and the rights you hold as a Data Subject under Philippine law. By accessing the Platform or creating a ph93 account, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy should be read together with ph93's Terms & Conditions and Responsible Gaming Policy.

2. Personal Data We Collect

ph93 collects the following categories of personal data, depending on how you interact with the Platform:

3. How We Collect Personal Data

ph93 collects personal data through the following methods:

• Direct Collection: Information you provide when registering a ph93 account, completing KYC verification, making deposits or withdrawal requests, contacting support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including via cookies, web beacons, and server logs. See Section 8 for details on cookies.
• Third-Party Sources: Identity and document verification data from KYC service providers; payment transaction data from GCash, PayMaya, and banking partners; fraud screening data from anti-money laundering compliance providers; and publicly available data sources where required by PAGCOR compliance obligations.
• Regulatory Sources: Data received from PAGCOR or other Philippine government agencies in connection with licensing, compliance audits, or legal proceedings.

4. Legal Basis and Purposes of Processing

ph93 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its IRR:

• Contract Performance: Processing necessary to provide the ph93 gaming platform services, process deposits and withdrawals, manage your account, and fulfil our obligations under the ph93 Terms & Conditions.
• Legal Obligation: Processing required to comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA) as amended by RA 10365 and RA 11521, the Philippine Data Privacy Act, and other applicable Philippine laws and regulations including NPC issuances.
• Legitimate Interest: Processing for platform security and fraud prevention, responsible gaming monitoring, platform performance improvement, and internal analytics, where such interests do not override your fundamental rights.
• Consent: Processing for marketing communications and non-essential cookies, where we rely on your freely given, specific, and informed consent. You may withdraw consent at any time by contacting ph93 support.

The primary purposes for which ph93 processes your personal data include: operating your ph93 account; processing financial transactions; verifying identity and age (21+); complying with AMLA and PAGCOR reporting obligations; detecting and preventing fraud, money laundering, and platform abuse; providing customer support; administering bonuses and promotions; and, where you have consented, sending marketing communications about ph93 offers and new features.

5. Disclosure of Personal Data

ph93 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data sharing agreements or legal obligations:

• Payment Service Providers: GCash (G-Xchange, Inc.), PayMaya Philippines, BPI, BDO Unibank, and Metrobank, for the purpose of processing deposits and withdrawals to and from your ph93 wallet.
• KYC and Identity Verification Providers: Third-party identity document verification and facial recognition service providers engaged to assist ph93 in fulfilling its KYC obligations under PAGCOR regulations.
• PAGCOR and Philippine Government Authorities: ph93 is legally required to share certain player and transaction data with PAGCOR and other competent Philippine government agencies, including the Anti-Money Laundering Council (AMLC), in compliance with applicable law. ph93 will not disclose this information to any other party without a lawful basis.
• Technology and Infrastructure Partners: Cloud hosting providers, platform software vendors, and cybersecurity service providers who process data on ph93's behalf under strict data processing agreements that prohibit unauthorized use or disclosure.
• Legal and Regulatory Advisers: Where required in connection with legal proceedings, regulatory investigations, or enforcement of ph93's rights under the Terms & Conditions.

6. Data Retention

ph93 retains personal data for as long as necessary to fulfil the purposes for which it was collected, and in any event for no shorter period than required by applicable Philippine law. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AMLA compliance obligations.
• Financial transaction records: Retained for a minimum of five (5) years following the date of the transaction, in compliance with AMLA record-keeping requirements.
• Gaming session records: Retained for a minimum of two (2) years for responsible gaming monitoring and dispute resolution purposes.
• Support and communications records: Retained for two (2) years following closure of the relevant support case.
• Marketing consent records: Retained for the duration of your active account and three (3) years following withdrawal of consent or account closure.

Following expiry of the applicable retention period, ph93 will securely delete or anonymize your personal data in accordance with the NPC's standards for personal data disposal.

7. Data Security

ph93 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Security measures include:

• 256-bit TLS (Transport Layer Security) encryption for all data transmitted between your device and the ph93 Platform
• AES-256 encryption at rest for sensitive personal and financial data stored on ph93 servers
• Password hashing using industry-standard cryptographic algorithms — ph93 staff cannot read your password in plain text
• Multi-factor authentication (MFA) for ph93 administrative access to data systems
• Regular penetration testing and vulnerability assessments conducted by qualified information security professionals
• Role-based access controls limiting ph93 staff access to personal data strictly to what is necessary for their job function
• Real-time intrusion detection and security monitoring systems

In the event of a personal data breach affecting your rights and freedoms, ph93 will notify the National Privacy Commission and affected Data Subjects within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03.

8. Cookies and Tracking Technologies

The ph93 Platform uses cookies and similar tracking technologies to operate core platform functions and to improve your experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies that keep you logged in to your ph93 account during an active session. These cannot be disabled without affecting platform functionality.
• Performance Cookies: Used to collect anonymized data about how users interact with the Platform — which pages are visited most, where errors occur, and how session flows work — to help ph93 improve the platform experience.
• Functional Cookies: Store your preferences such as language, preferred game category, and notification settings, so the Platform remembers them between visits.
• Marketing Cookies: Used to deliver ph93 promotional content relevant to your interests. These are only set with your prior consent. You may opt out at any time by adjusting your cookie preferences or contacting ph93 support.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from accessing authenticated areas of the Platform.

9. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012 and its IRR, you have the following rights with respect to your personal data held by ph93:

• Right to be Informed: To know what personal data ph93 holds about you, how it is processed, and on what legal basis.
• Right to Access: To obtain a copy of your personal data held by ph93 in a commonly used electronic format.
• Right to Correction: To request correction of inaccurate or incomplete personal data about you. Some corrections (such as legal name changes) may require supporting documentation.
• Right to Erasure or Blocking: To request deletion or blocking of your personal data where processing is no longer necessary, where consent has been withdrawn, or where the data was unlawfully processed — subject to ph93's legal retention obligations under AMLA and PAGCOR regulations, which may prevent immediate deletion.
• Right to Object: To object to processing based on legitimate interest, in particular for direct marketing purposes. You may unsubscribe from ph93 marketing communications at any time.
• Right to Data Portability: To receive your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: To file a complaint with the National Privacy Commission of the Philippines if you believe ph93 has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 12 below. ph93 will respond to verified requests within fifteen (15) business days.

10. Minors and Age Restriction

The ph93 Platform is strictly for individuals aged 21 years and above, as required by PAGCOR regulations and applicable Philippine law. ph93 does not knowingly collect personal data from individuals under 21 years of age. Age is verified through the KYC process as part of account activation for real-money gaming.

If ph93 becomes aware that personal data of a person under the age of 21 has been collected, ph93 will immediately suspend the relevant account, notify relevant regulatory authorities as required, and securely delete the personal data concerned.

If you are a parent or guardian and believe that your child has provided personal data to ph93, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

ph93 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, the Platform's features, or applicable Philippine law. When material changes are made, ph93 will notify registered users via their registered email address and/or a prominent notice on the Platform. The effective date of the current version is displayed at the top of this document.

Your continued use of the ph93 Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the revised Privacy Policy, you should cease using the Platform and may request account closure by contacting ph93 support.

12. Contact and Data Protection Officer

ph93 has designated a Data Protection Officer (DPO) in compliance with Section 21 of the Philippine Data Privacy Act and NPC Circular No. 16-01. For any privacy-related inquiries, requests to exercise Data Subject rights, or to report a suspected data breach, please contact:

• Data Protection Officer, ph93
• Email: [email protected]
• Live Chat: Available 8:00 AM – 12:00 MN PHT, 7 days a week

ph93 targets a response time of fifteen (15) business days for all written data privacy requests. Complex requests involving data portability or large-volume access requests may take up to thirty (30) business days, and you will be notified if this is the case.

If you are not satisfied with ph93's handling of your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines through its official channels.