ph351 Privacy Policy

This Privacy Policy ("Policy") is issued by ph351 and applies to all personal data collected, processed, stored, or disclosed by ph351 in connection with the operation of the ph351 online gaming platform accessible at ph351.org ("Platform").

This Policy applies to all individuals who interact with ph351, including registered players, prospective players who browse the Platform without creating an account, and individuals who contact ph351's customer support team.

ph351 operates in the Philippines and is committed to compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC). Where ph351 also processes the personal data of individuals from other jurisdictions, ph351 will apply the data protection standards required by the applicable law of that jurisdiction.

This Policy should be read together with ph351's Terms & Conditions, which constitute the overarching agreement between you and ph351 governing your use of the Platform.

For the purposes of the Data Privacy Act of 2012 and this Policy, the personal information controller (data controller) responsible for your personal data is:

ph351 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy laws. The DPO may be contacted at the email address above, with "Data Privacy — DPO" included in the subject line of your message.

ph351 is registered with the National Privacy Commission as required under the Data Privacy Act of 2012. Players who wish to verify ph351's NPC registration may do so through the NPC's official channels.

ph351 collects the following categories of personal data from players and platform users:

ph351 does not collect or store sensitive personal information as defined under the Data Privacy Act of 2012 (such as health information, religious beliefs, or political affiliations) unless it is directly relevant to a specific responsible gaming assessment and you have provided explicit written consent.

ph351 does not store payment credentials. GCash PINs, Maya passwords, bank account passwords, and payment card CVV numbers are processed exclusively by the relevant payment gateway and are never transmitted to or stored on ph351's systems.

ph351 collects personal data through the following channels and methods:

• Direct collection: Information you voluntarily provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or updating your account settings.
• Automated collection: Technical data (IP address, device information, browser type, session data) is automatically collected whenever you access or use the ph351 Platform, through server logs and session management systems.
• Cookies and similar technologies: ph351 uses cookies and similar tracking technologies to collect information about how you interact with the Platform, including which pages you visit and how long you remain on each. See Section 10 for full details on ph351's cookie practices.
• Third-party sources: ph351 may receive identity verification data from third-party KYC service providers during the account verification process. ph351 may also receive fraud screening signals from third-party anti-fraud systems.
• Payment processors: When you make a deposit or request a withdrawal, ph351 receives transaction confirmation data (such as transaction reference numbers and amounts) from the relevant payment gateway. Payment credentials themselves are not shared with ph351.

ph351 processes personal data only for specific, legitimate purposes. The primary purposes for which ph351 processes your personal data are as follows:

• Account creation and management: To register your ph351 account, maintain account records, enable login, manage your account settings, and provide account-related communications.
• Identity and age verification (KYC): To verify your identity and confirm that you meet the 21-year minimum age requirement in compliance with PAGCOR regulations and applicable Philippine law.
• Payment processing: To process deposits made to your ph351 account and withdrawals requested by you, and to maintain a complete and accurate transaction history.
• Platform provision and game delivery: To deliver the games, betting products, and all other services available on the ph351 Platform to you.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, underage gambling, multiple account abuse, and other prohibited conduct on the Platform.
• Regulatory compliance: To comply with ph351's obligations under Philippine law, PAGCOR regulations, the Data Privacy Act of 2012, and the Anti-Money Laundering Act (AMLA) of 2001, as amended.
• Customer support: To respond to your queries, resolve complaints, and provide technical assistance.
• Responsible gaming: To monitor gaming activity for indicators of problem gambling behavior, administer player-activated responsible gaming tools, and comply with applicable player protection requirements.
• Marketing communications: To send promotional offers, bonus notifications, and other marketing communications to players who have opted in to receive them. You may withdraw your marketing consent at any time through your account settings.
• Platform improvement and analytics: To analyze aggregated, anonymized Platform usage data for the purpose of improving the Platform's design, performance, and user experience. ph351 does not use individually identifiable data for pure analytics purposes without a separate legitimate basis.

ph351 does not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or otherwise establishing a lawful basis for such processing.

Under the Data Privacy Act of 2012, ph351 must have a lawful basis for processing your personal data. The legal bases ph351 relies upon are:

ph351 retains 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 retention periods apply:

Upon the expiry of the applicable retention period, ph351 will securely delete or irreversibly anonymize the personal data concerned, unless retention is required by a specific ongoing legal obligation (such as active litigation or a regulatory investigation).

ph351 does not sell, rent, or trade your personal data to third parties for their independent commercial purposes. ph351 may share your personal data with the following categories of third parties, strictly on a need-to-know basis and for the limited purposes described:

• Payment processors and financial institutions: GCash (Mynt), Maya (PayMaya), BancNet, and other Philippine payment gateway providers, for the purpose of processing your deposits and withdrawals. These providers are bound by their own regulatory obligations and data protection standards.
• KYC and identity verification providers: Third-party KYC service providers engaged by ph351 to assist with identity verification and age verification processes. These providers process data on ph351's behalf under data processing agreements.
• Game providers and technology partners: Licensed game studios and technology vendors whose products and services are integrated into the ph351 Platform. Data shared is limited to what is necessary for game delivery (e.g., player session tokens and bet data) and does not include full identity records.
• Anti-fraud and security service providers: Third-party providers engaged to assist with fraud detection, cybersecurity monitoring, and platform integrity.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other competent Philippine government authorities, where ph351 is required by law or regulatory obligation to disclose information.
• Law enforcement: Philippine law enforcement agencies, where ph351 receives a lawful court order, warrant, or equivalent legal process requiring disclosure.
• Professional advisers: Legal, audit, and compliance professionals engaged by ph351 in connection with the operation of the Platform, subject to applicable confidentiality obligations.

All third parties with whom ph351 shares personal data are required to maintain the confidentiality and security of the data received and to process it only for the specific purpose for which it was disclosed. ph351 conducts due diligence on third-party data processors to ensure their data protection standards are consistent with ph351's obligations under the Data Privacy Act of 2012.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by ph351. ph351 is committed to honoring all of these rights promptly and without unnecessary barriers.

To exercise any of these rights, contact ph351's Data Protection Officer at [email protected] with "Data Privacy Rights Request" in the subject line. ph351 will respond to all rights requests within 10 business days of receipt of a valid, verified request. Verification of your identity may be required before a request is actioned.

Please note that certain rights may be subject to limitations where ph351 has a legal obligation to retain your data (e.g., under AMLA record-keeping requirements). ph351 will inform you of any such limitation when responding to your request.

If you are not satisfied with ph351's response to your rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

ph351 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device by a web server. Cookies cannot execute programs or deliver viruses to your device. The following categories of cookies are used on the ph351 Platform:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function and cannot be disabled in our systems. They include session cookies that maintain your login state, security tokens, and load balancing cookies. These do not require your consent.
• Functional Cookies: These cookies remember your preferences and settings (such as your preferred language and responsible gaming settings) to provide a more personalized experience. They may be disabled, but doing so may affect Platform functionality.
• Analytics Cookies: ph351 uses anonymized analytics data to understand how players navigate the Platform and to improve its design and performance. Analytics data is aggregated and does not identify individual users. These cookies require your consent.
• Security and Fraud Prevention Cookies: These cookies assist with detecting and preventing fraudulent activity, including bot detection and unusual session behavior. They are necessary for maintaining Platform integrity.

You can manage cookie preferences through your browser settings. Most browsers allow you to block cookies or delete existing cookies. Note that blocking all cookies may prevent you from logging into your ph351 account, as session cookies are strictly necessary for the login function.

ph351 implements a comprehensive range of technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and ph351's servers is encrypted using 256-bit TLS encryption. This applies to all Platform pages, including login, deposit, and account management screens.
• Data encryption at rest: Sensitive personal data stored on ph351's servers — including identity documents and KYC records — is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to personal data within ph351's internal systems is restricted on a role-based, need-to-know basis. All staff and contractors with access to personal data are subject to confidentiality obligations and undergo data privacy training.
• Two-factor authentication (2FA): ph351 offers and strongly recommends the use of two-factor authentication (OTP via registered Philippine mobile number) for all player accounts.
• Intrusion detection and monitoring: ph351's platform infrastructure is monitored continuously for security anomalies, unauthorized access attempts, and potential breaches.
• Penetration testing: ph351 conducts regular security assessments and penetration testing of the Platform to identify and remediate vulnerabilities.
• Vendor security requirements: All third-party processors engaged by ph351 are required to maintain security standards consistent with ph351's own obligations and to notify ph351 promptly of any security incidents affecting data processed on ph351's behalf.

While ph351 takes all reasonable steps to protect your personal data, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. You also have a role to play in protecting your account — please keep your ph351 login credentials confidential and enable 2FA on your account.

The ph351 Platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR regulations governing the minimum age for casino-style gambling in the Philippines.

ph351 does not knowingly collect personal data from individuals under the age of 21. If ph351 becomes aware — through KYC verification, a complaint, or any other means — that personal data has been collected from an individual who is under 21 years of age, ph351 will:

• Immediately suspend the relevant account pending investigation;
• Permanently close the account upon confirmation that the account holder is under 21;
• Delete or anonymize all personal data collected in connection with the underage account, to the extent permissible under applicable law;
• Report the incident to the appropriate Philippine regulatory authorities where required.

If you are a parent or guardian and you believe that your child (under 21 years of age) has created a ph351 account, please contact ph351 immediately at [email protected]. ph351 will take immediate action to close the account and remove the associated data.

The ph351 Platform may contain links to third-party websites, applications, or services that are not owned or controlled by ph351. This Privacy Policy applies solely to the ph351 Platform and does not extend to any third-party website or service.

ph351 has no control over the content, privacy practices, or data collection activities of third-party websites. ph351 strongly recommends that you read the privacy policy of any third-party website you visit from a link on the ph351 Platform before providing any personal data to that third party.

The presence of a link to a third-party website on the ph351 Platform does not constitute an endorsement, recommendation, or approval of that website or its privacy practices by ph351.

ph351 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or ph351's data processing practices. The revised Policy will be published at ph351.org/privacy-policy with the updated effective date clearly indicated at the top of the document.

For material changes to this Policy — that is, changes that significantly affect how ph351 collects, uses, or shares your personal data — ph351 will notify registered players via email to their registered email address or via a prominent notice on the Platform, at least seven (7) calendar days before the change takes effect where practicable.

Your continued use of the ph351 Platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the updated Policy. If you do not agree to the updated Policy, you should cease using the Platform and may request voluntary account closure in accordance with the ph351 Terms & Conditions.

ph351 recommends bookmarking the Privacy Policy page and reviewing it periodically. The current version is always the authoritative version.

For any questions, concerns, or requests relating to this Privacy Policy or ph351's handling of your personal data, please contact ph351's Data Protection Officer through any of the following channels:

ph351 aims to respond to all privacy-related inquiries within 10 business days. Where a request involves a complex rights exercise or requires identity verification, ph351 will acknowledge receipt within 3 business days and provide a full response within 30 calendar days.

If you are not satisfied with ph351's response to your privacy inquiry or believe that ph351 has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through the NPC's official complaint channels.