ph643 Privacy Policy

This Privacy Policy ("Policy") describes how ph643 ("ph643," "we," "us," or "our") collects, uses, stores, shares, and protects the personal data of users ("you," "Player," or "Data Subject") who access or use the ph643 Platform at ph643.app. This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission of the Philippines ("NPC").

By registering for a ph643 account or using the ph643 Platform in any capacity, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please do not use the ph643 Platform.

1. Introduction

1.1 ph643 is an online gaming platform serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond. As a platform that handles financial transactions and personal account data, ph643 takes data privacy seriously and has implemented comprehensive measures to protect the personal information of every player.

1.2 This Policy applies to all personal data collected through the ph643 website (ph643.app), mobile applications, customer support channels, and any other touchpoints through which you interact with ph643.

1.3 This Policy should be read alongside the ph643 Terms & Conditions, which govern your use of the Platform generally.

2. Data Controller

2.1 ph643 acts as the Data Controller in respect of the personal data it collects from players and users of the Platform. As Data Controller, ph643 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the DPA and its IRR.

2.2 ph643 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data privacy laws. Contact details for the DPO are provided in Section 15 of this Policy.

3. Data We Collect

3.1 ph643 collects the following categories of personal data:

a) Identity & Contact Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (to verify the 21+ age requirement);
• Nationality and country of residence;
• Residential address, including barangay, city, and province;
• Email address and mobile number.

b) Account Data

• ph643 username and encrypted password;
• Account registration date and history;
• Communication preferences and marketing opt-in status.

c) Financial Data

• Deposit and withdrawal transaction records;
• Payment method details (e.g., GCash mobile number, PayMaya account, BPI or BDO account name — never full card numbers);
• Account balance history and wagering activity.

d) Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence);
• Proof of address documents;
• Selfie or liveness verification images where required.

e) Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Pages visited, session duration, and clickstream data;
• Login timestamps and session activity logs.

f) Communications Data

• Records of live chat, email, and support ticket interactions with ph643 customer support;
• Survey responses and feedback submitted through the Platform.

4. How We Collect Data

4.1 ph643 collects personal data through the following means:

• Direct collection: Information you provide when registering a ph643 account, completing KYC verification, making deposits or withdrawals, or contacting customer support;
• Automated collection: Technical and usage data collected automatically when you access the ph643 Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering (AML) screening services; and payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank.

4.2 ph643 does not collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

5. How We Use Your Data

5.1 ph643 uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your ph643 account;
• Identity verification: To verify your identity and age (21+) in compliance with applicable Philippine gaming regulations;
• Transaction processing: To process deposits, withdrawals, and bonus credits through supported payment channels including GCash, PayMaya, BPI, BDO, and Metrobank;
• Customer support: To respond to your enquiries, complaints, and support requests;
• Regulatory compliance: To comply with anti-money laundering (AML), counter-terrorism financing (CTF), and other legal obligations applicable to online gaming operators in the Philippines;
• Fraud prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the ph643 Platform;
• Responsible gaming: To monitor gaming behaviour and apply responsible gaming tools such as deposit limits, session reminders, and self-exclusion where appropriate;
• Platform improvement: To analyse usage patterns and improve the features, performance, and user experience of the ph643 Platform;
• Marketing communications: To send you promotional offers, bonus notifications, and news about ph643 — but only where you have opted in to receive such communications. You may opt out at any time.

5.2 ph643 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

6. Legal Basis for Processing

6.1 ph643 processes your personal data on the following legal bases under the DPA:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications;
• Contractual necessity: Where processing is necessary to perform the contract between you and ph643 — i.e., to operate your account and provide gaming services;
• Legal obligation: Where processing is required to comply with a legal obligation applicable to ph643, including AML/CTF regulations and gaming licensing requirements;
• Legitimate interests: Where processing is necessary for the legitimate interests of ph643, such as fraud prevention, Platform security, and improving our services, provided that such interests are not overridden by your rights and freedoms.

7. Data Sharing

7.1 ph643 does not sell, rent, or trade your personal data to third parties for commercial or marketing purposes. ph643 may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions;
• KYC and AML service providers: Third-party identity verification and anti-money laundering screening providers engaged by ph643 to fulfil its regulatory obligations;
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers who process data on ph643's behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: Government agencies, including the National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), and law enforcement bodies, where ph643 is legally required to disclose information;
• Professional advisers: Lawyers, auditors, and accountants engaged by ph643 in connection with legal, compliance, or financial matters, subject to professional confidentiality obligations.

7.2 All third parties with whom ph643 shares personal data are required to handle such data in accordance with the DPA and ph643's data protection standards.

8. Data Retention

8.1 ph643 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your ph643 account and for a period of five (5) years following account closure, in accordance with Philippine AML regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act;
• KYC documents: Retained for five (5) years following account closure or the completion of the relevant transaction;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications.

8.2 Upon expiry of the applicable retention period, ph643 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Data Security

9.1 ph643 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph643 Platform;
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and financial information;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication (MFA) for administrative access to ph643 systems;
• Continuous monitoring of Platform activity for suspicious behaviour and potential security incidents.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph643 will notify the National Privacy Commission and affected data subjects in accordance with the DPA's breach notification requirements.

9.3 While ph643 takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your ph643 login credentials and for notifying ph643 immediately if you suspect any unauthorised access to your account.

10. Cookies Policy

10.1 ph643 uses cookies and similar tracking technologies (such as web beacons and local storage) to enhance your experience on the Platform, remember your preferences, and analyse how the Platform is used. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled;
• Functional cookies: Used to remember your preferences, such as language settings and login status;
• Analytics cookies: Used to collect anonymised data about how players use the ph643 Platform, helping us improve performance and user experience;
• Marketing cookies: Used to deliver relevant promotional content based on your interests, where you have consented to receive marketing communications.

10.2 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the ph643 Platform.

11. Your Rights as a Data Subject

11.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ph643:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data ph643 holds about you;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data;
• 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 ph643's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another data controller;
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

11.2 To exercise any of the above rights, please contact ph643's Data Protection Officer using the contact details in Section 15. ph643 will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with the DPA.

11.3 If you believe that ph643 has not handled your personal data in accordance with the DPA, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

12. Children's Privacy

12.1 The ph643 Platform is strictly intended for adults aged 21 years and above. ph643 does not knowingly collect personal data from individuals under the age of 21. If ph643 becomes aware that it has inadvertently collected personal data from a minor, it will take immediate steps to delete such data and close the associated account.

12.2 If you are a parent or guardian and believe that your child has registered on the ph643 Platform, please contact our support team immediately at [email protected] so that we can take appropriate action.

13. International Data Transfers

13.1 ph643 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or KYC verification services operating internationally.

13.2 Where personal data is transferred outside the Philippines, ph643 ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses consistent with the requirements of the DPA and NPC guidelines.

14. Policy Updates

14.1 ph643 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The date of the most recent revision will always be indicated at the top of this page.

14.2 Where changes to this Policy are material, ph643 will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect. Your continued use of the ph643 Platform following the publication of any amendments constitutes your acceptance of the revised Policy.

15. Contact & Data Protection Officer

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph643, please contact our Data Protection Officer:

15.2 ph643 aims to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within fifteen (15) business days. For complex requests, we will keep you informed of progress throughout the process.

15.3 If you are not satisfied with ph643's response to your privacy concern, you may escalate your complaint to the National Privacy Commission of the Philippines at [email protected] or through the NPC's official website.