ph94 Privacy Policy

1 Introduction

ph94 ("ph94," "we," "us," "our") operates the online gaming platform accessible at ph94.app. We are committed to protecting the privacy and personal data of all individuals who interact with our platform, including registered players, visitors, and prospective users.

This Privacy Policy describes how ph94 collects, uses, stores, shares, and protects personal data in connection with the operation of the ph94 platform. It applies to all personal data collected through ph94.app, our mobile-optimized site, and any communications between you and ph94.

This Privacy Policy is issued in compliance with the 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. By using the ph94 platform, you acknowledge that you have read and understood this Privacy Policy.

2 Data Controller

ph94 is the personal information controller responsible for the personal data collected through the ph94 platform. As the data controller, ph94 determines the purposes and means of processing your personal data.

ph94 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and this Privacy Policy. You may contact the ph94 DPO at the contact details provided in Section 16 of this Policy.

3 Personal Data We Collect

ph94 collects the following categories of personal data, depending on how you interact with the platform:

3.1 Registration and Account Data

• Full legal name
• Date of birth (for age verification — you must be 21 or older)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password
• Security questions and answers (if set)

3.2 Identity Verification (KYC) Data

• Government-issued Philippine ID (e.g., PhilSys ID, Passport, UMID, Driver's License, Voter's ID, PRC ID)
• Selfie or live photo for biometric verification (where required)
• Proof of address documents (e.g., utility bill, bank statement)
• Proof of payment method ownership (where required)

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash mobile number, Maya account reference, bank account details — stored in tokenized form where applicable)
• Account balance history
• Bonus and promotional credit records

3.4 Gaming Activity Data

• Game session logs (games played, wagers placed, outcomes, session duration)
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status)
• Customer support interaction records

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Cookie identifiers and session tokens
• Platform access logs and timestamps

3.6 Communications Data

• Live chat transcripts and support ticket records
• Email correspondence with ph94
• Feedback and survey responses (where voluntarily provided)

4 How We Collect Your Data

ph94 collects personal data through the following means:

• Directly from you — when you register an Account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion.
• Automatically — through cookies, session tokens, and server logs when you access and use the ph94 platform.
• From third-party payment processors — transaction confirmation data from GCash, Maya, and partner banks when you make deposits or withdrawals.
• From identity verification service providers — where ph94 uses a third-party KYC provider to assist with document verification and biometric checks.
• From regulatory and law enforcement authorities — where ph94 is required by law to receive or share information with PAGCOR, the AMLC, or other competent authorities.

5 How We Use Your Personal Data

ph94 uses your personal data for the following purposes:

• Account creation and management — to register your ph94 Account, authenticate your identity at login, and manage your Account settings.
• Age and identity verification — to verify that you are at least 21 years of age and to confirm your identity as required by PAGCOR regulations and RA 10173.
• Payment processing — to process deposits and withdrawals via your chosen Philippine payment method (GCash, Maya, bank transfer, or debit card).
• Anti-money laundering compliance — to monitor transactions and fulfill ph94's obligations under the Anti-Money Laundering Act (RA 9160) and AMLC reporting requirements.
• Responsible gaming — to monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and apply deposit limits and other responsible gaming tools.
• Customer support — to respond to your inquiries, resolve disputes, and provide assistance via live chat and email.
• Platform security and fraud prevention — to detect and prevent unauthorized access, fraud, cheating, and other prohibited conduct on the platform.
• Regulatory compliance — to comply with PAGCOR licensing requirements, NPC data privacy obligations, and other applicable Philippine laws and regulations.
• Service improvement — to analyze platform usage patterns and improve the ph94 user experience, game selection, and technical performance.
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.

6 Legal Basis for Processing

ph94 processes your personal data on the following legal bases under RA 10173:

• Contractual necessity — processing is necessary to perform the contract between you and ph94 (i.e., to operate your Account, process transactions, and provide gaming services).
• Legal obligation — processing is required to comply with applicable Philippine laws, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate interests — processing is necessary for ph94's legitimate interests in operating a secure, fair, and compliant gaming platform, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent — for certain processing activities, such as marketing communications and the use of non-essential cookies, ph94 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7 Data Sharing and Disclosure

ph94 does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

7.1 Regulatory and Government Authorities

ph94 is required by law to share certain personal data and transaction records with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful request or as mandated by applicable regulations.

7.2 Payment Service Providers

ph94 shares necessary transaction data with payment processors — including GCash, Maya, and partner banks such as BPI, BDO, Metrobank, UnionBank, Landbank, PNB, and Security Bank — to facilitate deposits and withdrawals. These providers process data under their own privacy policies and are bound by applicable Philippine financial regulations.

7.3 Identity Verification Providers

ph94 may engage third-party KYC and identity verification service providers to assist with document authentication and biometric verification. These providers are contractually bound to process personal data only for the purposes specified by ph94 and in compliance with RA 10173.

7.4 Technology and Infrastructure Providers

ph94 uses third-party cloud hosting, cybersecurity, and platform infrastructure providers to operate the ph94 platform. These providers may process personal data on ph94's behalf as personal information processors and are bound by data processing agreements that require them to maintain appropriate security standards.

7.5 Game Content Providers

Certain game providers whose content is available on the ph94 platform may receive limited technical data (such as session tokens and game round identifiers) necessary to deliver their games. These providers do not receive your full personal profile and are contractually prohibited from using such data for any purpose other than game delivery.

7.6 Law Enforcement

ph94 may disclose personal data to law enforcement agencies where required by a valid court order, subpoena, or other lawful legal process, or where ph94 reasonably believes disclosure is necessary to prevent imminent harm, fraud, or criminal activity.

8 Cookies and Tracking Technologies

ph94 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit ph94.app.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences, such as language settings, display preferences, and responsible gaming tool configurations.
• Analytics Cookies: Help ph94 understand how players use the platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotional content within the ph94 platform. These are only activated with your consent.

8.2 Managing Cookies

You may manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Note that disabling strictly necessary cookies will impair your ability to use the ph94 platform. For analytics and marketing cookies, you may withdraw consent at any time through your Account settings or by contacting ph94 support.

9 Data Retention

ph94 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• 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 Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC record-keeping requirements.
• Gaming activity logs: Retained for three (3) years from the date of each session, for dispute resolution and regulatory audit purposes.
• Customer support records: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your Account and for one (1) year following Account closure, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, ph94 will securely delete or anonymize your personal data in accordance with NPC guidelines.

10 Data Security

ph94 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption: All data transmitted between your device and ph94.app is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest, including payment details and KYC documents, is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized ph94 personnel on a strict need-to-know basis. All access is authenticated, logged, and subject to regular review.
• Firewalls and intrusion detection: ph94's infrastructure is protected by enterprise-grade firewalls and real-time intrusion detection and prevention systems.
• Regular security audits: ph94 conducts regular internal and third-party security assessments, penetration testing, and vulnerability scans to identify and remediate security risks.
• Staff training: All ph94 personnel with access to personal data receive regular data privacy and security training.
• Incident response: ph94 maintains a documented data breach response plan. In the event of a personal data breach, ph94 will notify affected players and the NPC within 72 hours of becoming aware of the breach, as required by NPC Circular 16-03.

While ph94 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your Account credentials and for notifying ph94 immediately if you suspect unauthorized access to your Account.

11 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by ph94:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data ph94 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data ph94 holds about you.
• Right to Erasure or Blocking: You have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful. This right is subject to ph94's legal obligations to retain certain data under PAGCOR and AMLC requirements.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, subject to ph94's overriding legal obligations.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph94 has violated your data privacy rights. The NPC can be reached through its official website at privacy.gov.ph.

To exercise any of the above rights, please submit a written request to ph94's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." ph94 will respond to your request within fifteen (15) business days of receipt, as required by NPC guidelines.

12 Children's Privacy and Age Restriction

The ph94 platform is strictly intended for adults aged 21 years and above. ph94 does not knowingly collect personal data from individuals under the age of 21. The minimum age for casino-style online gaming in the Philippines is 21 years, as mandated by Philippine law and PAGCOR regulations.

ph94 implements age verification controls during the registration process and as part of KYC verification to prevent underage access. If ph94 discovers that personal data has been collected from a person under 21 years of age, ph94 will immediately suspend the associated Account, delete the personal data, and refund any deposits to the original payment method.

If you are a parent or guardian and believe that your child has registered an Account on ph94, please contact ph94 support immediately at [email protected].

13 Cross-Border Data Transfers

ph94 primarily stores and processes personal data within the Philippines. In limited circumstances, personal data may be transferred to or accessed from servers or service providers located outside the Philippines — for example, where ph94 uses internationally hosted cloud infrastructure or game content providers.

Where such cross-border transfers occur, ph94 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under RA 10173.
• Transfers only to countries or organizations that provide an adequate level of data protection as recognized by the NPC.
• Your explicit consent, where required by applicable law.

ph94 does not transfer personal data to jurisdictions that do not provide adequate data protection safeguards without implementing appropriate contractual or technical measures.

14 Third-Party Links and Services

The ph94 platform may contain references to third-party services, such as payment providers (GCash, Maya, partner banks). These third parties operate under their own privacy policies, which ph94 does not control. ph94 is not responsible for the privacy practices of third-party services.

ph94 recommends that you review the privacy policies of any third-party services you use in connection with your ph94 Account, particularly your chosen payment provider, to understand how they handle your personal data.

15 Updates to This Privacy Policy

ph94 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material — meaning they significantly affect how ph94 processes your personal data or your rights as a data subject — ph94 will notify you by email or via an in-platform notification at least fourteen (14) days before the changes take effect.

Your continued use of the ph94 platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the revised policy. If you do not agree with the updated policy, you may request Account closure by contacting ph94 support.

16 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or ph94's handling of your personal data, please contact us through the following channels: