Privacy Policy — ph769 Online Casino

1. Introduction & Scope

1.1 ph769 is committed to protecting the privacy and personal data of its members in accordance with Republic Act No. 10173, known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as administered and enforced by the National Privacy Commission ("NPC") of the Philippines.

1.2 This Policy applies to all personal data collected, processed, stored, and used by ph769 in connection with the registration, operation, and maintenance of Member accounts, game participation, financial transactions, customer service interactions, and marketing communications on the ph769 platform.

1.3 This Policy should be read in conjunction with ph769's Terms & Conditions, which govern the overall legal relationship between ph769 and its Members. In the event of any conflict between this Policy and the Terms & Conditions on a privacy matter, this Policy shall prevail.

1.4 ph769 also operates under a license issued by the Philippine Amusement and Gaming Corporation ("PAGCOR"). PAGCOR's regulatory requirements impose certain mandatory data collection and reporting obligations on ph769, which are reflected in this Policy.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, ph769 is the Personal Information Controller ("PIC") in respect of the personal data of its Members. ph769 determines the purposes and means of processing your personal data.

2.2 ph769 has designated a Data Protection Officer ("DPO") responsible for overseeing this Policy and compliance with RA 10173. Members may contact the DPO through ph769's live chat support channel, available 24 hours a day, 7 days a week on the platform.

2.3 Third-party service providers who process personal data on ph769's behalf — including payment processors, identity verification services, and game content providers — act as Personal Information Processors ("PIPs") under data processing agreements that bind them to handling Member data consistently with this Policy and applicable Philippine law.

3. Data We Collect

3.1 ph769 collects the following categories of personal data from its Members:

3.2 ph769 does not intentionally collect sensitive personal information as defined under Section 3(l) of the DPA — such as racial origin, political opinions, religious beliefs, health data, or sexual orientation — except where health-related data is voluntarily provided in the context of a responsible gaming interaction or self-exclusion request, in which case it is processed solely for the purpose of member protection.

4. How We Collect Data

4.1 Directly From You. ph769 collects personal data directly from Members through: (a) the account registration process, where you provide your mobile number and create credentials; (b) the KYC verification process, where you submit identity documents; (c) payment transactions, where financial details are submitted through GCash, PayMaya, or bank transfer channels; and (d) customer support interactions via live chat.

4.2 Automatically Through Platform Use. When you access and use the ph769 platform, technical data including your IP address, device identifiers, browser characteristics, and game session data is collected automatically through server logs, session tracking, and standard web analytics mechanisms. This collection is necessary for platform security, performance monitoring, and geographic compliance verification.

4.3 From Third-Party Service Providers. ph769 may receive supplementary data from identity verification service providers engaged to assist with KYC compliance, and from payment processors confirming transaction completion. Such third-party data sources are contractually bound to provide data lawfully obtained and consistent with applicable Philippine privacy law.

4.4 Cookies and Similar Technologies. ph769 uses cookies and similar tracking technologies on the platform. See Section 8 of this Policy for a full description of ph769's cookie practices.

5. Legal Basis for Processing

5.1 ph769 processes Member personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to deliver the services you have contracted for by creating a ph769 account — including account management, game delivery, payment processing, and customer support.
• Legal Obligation: Processing required to comply with ph769's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine law — including mandatory KYC verification, transaction reporting, and AMLC disclosures.
• Legitimate Interests: Processing for ph769's legitimate business interests where these do not override Members' fundamental rights — including fraud detection, platform security, responsible gaming monitoring, and platform analytics for service improvement.
• Consent: Processing for marketing communications and optional promotional features is conducted on the basis of Member consent, which may be withdrawn at any time without affecting the lawfulness of prior processing.

6. How We Use Your Data

6.1 ph769 uses Member personal data for the following purposes:

• Creating and managing your ph769 account, including authentication and access control;
• Processing deposits and withdrawals through GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven, and DragonPay;
• Verifying your identity and age (21+) through the PAGCOR-mandated KYC process;
• Delivering game services and tracking game session data for account integrity and regulatory reporting;
• Administering bonuses, promotions, and VIP program benefits;
• Monitoring account activity for fraud, money laundering indicators, and security threats;
• Implementing responsible gaming measures, including identifying accounts with behavioral indicators of problem gambling;
• Providing customer support through live chat and resolving disputes;
• Complying with PAGCOR, AMLC, and NPC regulatory requirements;
• Sending account-related transactional communications including OTPs, deposit confirmations, and withdrawal notifications via SMS;
• Sending promotional communications and offers where you have provided consent — subject to your right to withdraw consent at any time;
• Analyzing platform usage patterns to improve game selection, user experience, and performance.

7. Data Sharing & Disclosure

7.1 ph769 does not sell your personal data. Data sharing is limited to the categories and recipients described in this section.

7.2 Service Providers (Personal Information Processors). ph769 shares Member data with third-party service providers engaged to deliver platform services, including: (a) payment processors facilitating GCash, PayMaya, and bank transfer transactions; (b) identity verification providers conducting KYC document checks; (c) game content providers (JILI, PG Soft, Pragmatic Play, and others) who receive game session data necessary to deliver their games; and (d) customer service platform providers hosting the live chat function. All service providers are contractually bound by data processing agreements requiring them to process Member data only as instructed by ph769 and in compliance with RA 10173.

7.3 Regulatory Authorities. As a PAGCOR-licensed operator, ph769 is legally required to disclose Member data to the following authorities upon lawful demand or as required by ongoing regulatory obligation: PAGCOR (gaming regulatory compliance and reporting); the Anti-Money Laundering Council (AMLC) — suspicious transaction reporting under the AMLA; the National Privacy Commission (NPC) — data breach notifications and compliance inquiries; and law enforcement authorities pursuant to lawful court order or subpoena.

7.4 Business Transfers. In the event of a merger, acquisition, or sale of substantially all of ph769's assets, Member personal data may be transferred to the successor entity as part of such transaction, subject to the same level of data protection as described in this Policy. Members will be notified of any such transfer through the ph769 platform.

7.5 With Your Consent. ph769 may share your data with additional third parties where you have provided explicit consent to such sharing.

8. Cookies & Tracking Technologies

8.1 ph769 uses cookies and similar web technologies on the ph769.app platform. Cookies are small data files stored on your device that help ph769 deliver and improve platform services.

8.2 ph769 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function — including session management, login authentication, and security tokens. These cannot be disabled without preventing access to the platform.
• Functional Cookies: Remember your preferences such as language settings, game lobby filters, and display preferences to improve your experience on return visits.
• Analytics Cookies: Collect aggregate data about how Members use the platform — pages visited, game categories accessed, session duration — to help ph769 improve the platform. This data is anonymized or pseudonymized where possible.
• Security Cookies: Used to detect unusual login patterns, identify bot activity, and prevent fraudulent access to Member accounts.

8.3 Most modern browsers allow you to control cookie settings through browser preferences. Disabling strictly necessary cookies will impair or prevent access to ph769 platform features. Disabling analytics and functional cookies will not prevent access but may affect user experience.

9. Data Retention

9.1 ph769 retains Member personal data for no longer than is necessary for the purposes described in this Policy, subject to mandatory retention periods imposed by Philippine law and PAGCOR regulation.

9.2 Specific retention periods are as follows:

• Account and KYC Data: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and the AMLA for record-keeping and audit purposes.
• Financial Transaction Records: Retained for a minimum of five (5) years from the transaction date, in compliance with AMLC regulations and Bureau of Internal Revenue (BIR) requirements.
• Gaming Session Logs: Retained for a minimum of two (2) years for dispute resolution and regulatory audit purposes.
• Customer Support Records: Retained for two (2) years from the date of the support interaction.
• Marketing Consent Records: Retained for the duration of consent plus three (3) years, to demonstrate compliance with consent requirements.
• Technical Logs (IP, device data): Retained for twelve (12) months for security and fraud analysis purposes.

9.3 Upon expiry of applicable retention periods, personal data is securely deleted or anonymized through ph769's data lifecycle management process. Anonymized aggregate data may be retained indefinitely for statistical analysis purposes.

10. Data Security

10.1 ph769 implements technical and organizational security measures designed to protect Member personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between Member devices and ph769 servers;
• Encryption of sensitive data at rest within ph769's database infrastructure;
• Password hashing using industry-standard cryptographic algorithms — ph769 does not store passwords in plain text;
• OTP-based two-factor authentication for Member logins from new devices;
• Role-based access controls limiting internal staff access to Member data to authorized personnel on a need-to-know basis;
• Regular security audits and vulnerability assessments of the ph769 platform;
• 24/7 fraud monitoring and automated detection systems for suspicious account activity;
• Mandatory data security training for all ph769 staff with access to Member personal data.

10.2 Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected Members, ph769 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, as required by NPC Circular No. 16-03. Affected Members will be notified without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

11. Your Rights as a Data Subject

11.1 Under the Data Privacy Act of 2012, Members have the following rights in respect of their personal data held by ph769:

12. Children's Privacy and Age Restriction

12.1 The ph769 platform is strictly for individuals who are 21 years of age or older, in compliance with PAGCOR regulations. ph769 does not knowingly collect personal data from individuals under 21 years of age.

12.2 Age verification is conducted as part of the mandatory KYC process required before any Member's first withdrawal. Where ph769 discovers or suspects that a Member is under 21 years of age, the account will be immediately suspended, all data retained only as required to comply with PAGCOR reporting obligations, and the incident reported to PAGCOR.

12.3 If a parent or guardian believes that a person under the age of 21 has provided personal data to ph769 or created an account, they should contact ph769 immediately through the live chat support channel.

13. International Data Transfers

13.1 ph769 processes Member data primarily within the Philippines. Where data is transferred to third-party service providers or game content providers whose infrastructure is located outside the Philippines, ph769 ensures that such transfers are made only to recipients who provide an adequate level of data protection as required under the Data Privacy Act of 2012 and NPC regulations.

13.2 International data transfers by ph769 are governed by contractual clauses consistent with the NPC's requirements for cross-border data flows, ensuring that your personal data receives the same standard of protection regardless of the jurisdiction in which it is processed.

14. Policy Amendments

14.1 ph769 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, ph769's data practices, or platform functionality. Material changes to this Policy will be communicated to Members by notice on the ph769 platform at least 7 days before taking effect, except where immediate amendment is required by NPC directive, PAGCOR requirement, or applicable law.

14.2 The effective date of the most current version of this Policy is displayed at the top of this document. Continued use of the ph769 platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not accept the revised Policy, you should discontinue use of the platform and may request account closure in accordance with the Terms & Conditions.

14.3 The most current version of this Policy is always accessible at ph769.app/privacy-policy.

15. Contact & Complaints

15.1 Contact ph769's Data Protection Officer. Members with questions, concerns, or requests regarding this Privacy Policy or ph769's data processing practices should contact ph769 through the live chat support channel available 24/7 on the platform. ph769's Data Protection Officer is responsible for overseeing compliance with this Policy and will respond to all inquiries.

15.2 Right to Lodge a Complaint with the NPC. If you believe that ph769 has processed your personal data in a manner inconsistent with the Data Privacy Act of 2012 and ph769 has not resolved your concern to your satisfaction, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC can be reached through its official website and complaint channels. ph769 will cooperate fully with any NPC investigation of a Member complaint.