ph935 Casino – Privacy Policy

ph935 ("ph935," "we," "us," "our") is committed to protecting the privacy and personal data of every Filipino player who uses the ph935 platform at ph935.club ("Platform"). This Privacy Policy ("Policy") describes how ph935 collects, uses, discloses, retains, and protects personal data in connection with the provision of our online casino, sports betting, bingo, and live dealer gaming services.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission of the Philippines ("NPC"). By registering a ph935 account, accessing the Platform, or providing personal data to ph935, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy applies to all personal data processed by ph935 in connection with your use of the Platform, regardless of the device or connection method used to access ph935 services in the Philippines.

ph935 acts as the Personal Information Controller ("PIC") for the personal data of Filipino players using the Platform, as that term is defined under the Philippine Data Privacy Act of 2012. ph935 determines the purposes and means of processing your personal data. ph935 has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with Philippine data privacy law. Contact details for the ph935 DPO are provided in Section 15 of this Policy.

When you register a ph935 account or use Platform services, you may provide the following personal data:

• Full legal name, date of birth, and nationality
• Residential address (including city — e.g., Manila, Cebu, Davao, Makati, Quezon City)
• Email address and mobile phone number
• Government-issued identification numbers (e.g., PhilSys ID, driver's license, passport, UMID)
• Payment information, including GCash wallet numbers, PayMaya details, and bank account information for BDO, BPI, and Metrobank
• Source-of-funds information provided during KYC verification
• Communications with ph935 customer support (including live chat transcripts)

When you access the ph935 Platform, the following technical data may be collected automatically:

• IP address and geolocation data
• Device type, operating system, and browser type
• Session start and end times, pages visited, and features accessed
• Game play logs, including bets placed, wagering history, and session duration
• Cookie identifiers and similar tracking technologies (see Section 8)

ph935 may receive personal data from third parties in connection with identity verification services, payment processing, fraud prevention, and regulatory compliance. Such data is processed in accordance with this Policy and applicable Philippine law.

ph935 processes the personal data of Filipino players for the following purposes:

• Account Management: Creating, maintaining, and managing your ph935 account, processing login authentication, and enabling platform features.
• Identity Verification (KYC): Verifying your identity and age (21+) in compliance with PAGCOR regulations and the Anti-Money Laundering Act.
• Payment Processing: Processing deposits and withdrawals via GCash, PayMaya, BDO, BPI, Metrobank, and other supported payment methods in Philippine Peso.
• Customer Support: Responding to your inquiries, resolving disputes, and providing assistance in Filipino and English.
• Regulatory Compliance: Meeting ph935's obligations under Philippine law, including PAGCOR requirements, the Anti-Money Laundering Act, and the Data Privacy Act.
• Responsible Gaming: Monitoring player activity to identify potential problem gambling behavior and implementing responsible gaming tools including deposit limits and self-exclusion.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, unauthorized account access, and breaches of the ph935 Terms and Conditions.
• Platform Improvement: Analyzing aggregated usage data to improve Platform performance, game selection, and user experience for Filipino players.
• Marketing Communications: Sending you promotional offers, bonus notifications, and updates about ph935 services, subject to your communication preferences and applicable Philippine regulations. You may opt out of marketing communications at any time.

ph935 processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform the agreement between you and ph935, including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including KYC verification, AMLC reporting, and PAGCOR compliance obligations.
• Legitimate Interests: Processing for fraud prevention, security monitoring, and Platform improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

ph935 does not sell, rent, or trade your personal data to third parties. ph935 may share your personal data with the following categories of recipients only where necessary and lawful:

• Payment Processors: GCash (G-Xchange, Inc.), PayMaya Philippines, BDO, BPI, Metrobank, and other payment service providers for transaction processing.
• Identity Verification Providers: Third-party KYC service providers engaged by ph935 to verify the identity and age of Filipino players.
• Game Providers: Licensed online casino game suppliers whose games are accessible through the ph935 Platform, to the extent necessary for game delivery and integrity.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities, where required by law or regulation.
• Legal & Compliance Advisors: External legal counsel and compliance consultants engaged by ph935 to manage legal risk and regulatory obligations.
• IT Service Providers: Cloud infrastructure, hosting, and cybersecurity service providers engaged by ph935 under appropriate data processing agreements.

All third-party service providers engaged by ph935 are contractually required to process personal data only as directed by ph935 and in accordance with applicable Philippine data privacy law.

ph935 retains personal data for no longer than is necessary for the purposes for which it was collected, or as required by applicable Philippine law and regulation. Specific retention periods include:

• Account Data: Retained for the duration of your active ph935 account, plus a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine anti-money laundering regulations.
• KYC Documents: Retained for the period required by PAGCOR regulations, which is generally a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required by law.
• Marketing Preferences: Retained for the duration of your ph935 account, unless you withdraw consent for marketing communications earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ph935's data lifecycle management procedures.

Cookies are small text files placed on your device when you access the ph935 Platform. ph935 uses cookies and similar technologies (such as local storage and session tokens) to ensure Platform functionality, maintain your logged-in session, and analyze Platform usage patterns.

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication tokens that maintain your ph935 login state. These cannot be disabled.
• Functional Cookies: Store your preferences such as language settings, responsible gaming limits, and display preferences to improve your experience on ph935.
• Analytical Cookies: Used to collect aggregated, anonymized data about how Filipino players use the Platform. This data is used to improve Platform performance and game selection. ph935 uses privacy-respecting analytics tools for this purpose.

You may control cookie settings through your browser settings. Disabling strictly necessary cookies may prevent certain ph935 features from functioning correctly, including account login.

ph935 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, and disclosure. Security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph935 servers
• Encryption at rest for sensitive personal data stored in ph935 databases
• Access controls ensuring that only authorized ph935 personnel can access personal data, on a strict need-to-know basis
• Regular penetration testing and security audits of Platform infrastructure
• Multi-factor authentication for ph935 internal systems handling personal data
• Employee training on data privacy obligations under Philippine law

While ph935 applies industry-standard security measures, no online platform can guarantee absolute security. In the event of a personal data breach, ph935 will fulfill its notification obligations to affected Filipino players and the NPC as required under the DPA.

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by ph935:

• Right to Be Informed: The right to be informed of how ph935 collects, uses, and processes your personal data (fulfilled through this Policy).
• Right of Access: The right to obtain confirmation of whether ph935 processes your personal data and, if so, to access a copy of that data.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or updated in your ph935 account.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ph935'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 service provider where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (privacy.gov.ph) if you believe your data privacy rights have been violated.

To exercise any of these rights, contact ph935 via live chat or email at [email protected]. ph935 will respond to data privacy rights requests within fifteen (15) days of receipt, in accordance with NPC guidelines.

The ph935 Platform is strictly intended for adult players aged 21 years and above in compliance with PAGCOR regulations. ph935 does not knowingly collect personal data from individuals under the age of 21. If ph935 determines that personal data has been collected from a person under 21, such data will be deleted immediately and the associated account permanently closed. If you believe that ph935 has inadvertently collected data from a minor, please contact ph935 support immediately.

The ph935 Platform does not contain links to external third-party websites. ph935 is not responsible for the privacy practices of any external websites that may reference or link to ph935.club from their own platforms. This Policy applies solely to data processing activities conducted by ph935 in connection with the ph935 Platform.

Where ph935 engages third-party service providers whose infrastructure is located outside the Philippines, ph935 ensures that appropriate safeguards are in place for the cross-border transfer of personal data, including contractual data processing agreements that impose equivalent data protection standards to those required under Philippine law. ph935 will not transfer personal data of Filipino players to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards.

ph935 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidelines, or ph935's data processing practices. When material changes are made, ph935 will notify registered Filipino players via email or on-Platform notification. The updated Policy will be effective from the date of publication. Your continued use of the Platform following notification of any amendment constitutes your acceptance of the revised Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or ph935's data processing practices, please contact the ph935 Data Protection Officer:

• Method: Live chat available 24/7 on the ph935 Platform, or by email
• Email: [email protected]
• Response Time: ph935 will respond to data privacy inquiries within fifteen (15) days of receipt

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with ph935's handling of your data privacy request. The NPC can be contacted via the official Philippine government portal for data privacy matters.