ph29 Privacy Policy

1 Introduction

Welcome to ph29. ph29 ("we", "us", "our") operates the online gaming platform accessible at ph29.app. We are committed to protecting the privacy and personal data of every player and visitor who interacts with our platform.

This Privacy Policy ("Policy") describes how ph29 collects, uses, stores, shares, and protects your personal data when you access or use the ph29 website, mobile interface, and related services (collectively, the "Platform"). It also explains the rights you have over your personal data under Philippine law.

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, as enforced by the National Privacy Commission (NPC) of the Philippines. It should be read together with our Terms & Conditions.

2 Data Controller

ph29 is the personal information controller (PIC) responsible for your personal data collected through the Platform. As PIC, ph29 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 and all applicable regulations.

ph29 has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection strategy and implementation. You may contact the DPO using the details provided in Section 15 of this Policy.

3 Data We Collect

ph29 collects the following categories of personal data:

ph29 does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive data is collected, ph29 applies heightened security and access controls.

4 How We Collect Your Data

ph29 collects your personal data through the following means:

• Direct interactions – data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies – data collected automatically when you use the Platform, including cookies, web beacons, server logs, and similar tracking technologies (see Section 10).
• Third-party sources – data received from payment processors (GCash, Maya, banks), identity verification providers, fraud prevention services, and PAGCOR where required by regulation.

5 How We Use Your Data

ph29 uses your personal data for the following purposes:

• To create and manage your ph29 account and verify your identity .
• To process deposits, withdrawals, and other financial transactions on the ph29 platform.
• To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations, and other applicable Philippine laws and regulations.
• To detect, investigate, and prevent fraud, cheating, bonus abuse, and other prohibited conduct.
• To monitor gaming activity for responsible gaming purposes and to enforce self-exclusion requests.
• To provide customer support and resolve disputes.
• To send you transactional communications (account confirmations, deposit receipts, withdrawal notifications).
• To send you marketing communications about ph29 promotions, new games, and offers — only where you have given your consent or where permitted by law.
• To improve, personalize, and optimize the ph29 Platform and user experience.
• To conduct internal analytics, reporting, and business planning.

ph29 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, ph29 processes your personal data on the following legal bases:

• Contractual necessity – processing required to perform our contract with you (account management, payment processing, game provision).
• Legal obligation – processing required to comply with PAGCOR regulations, AML laws, tax obligations, and NPC requirements.
• Legitimate interests – processing for fraud prevention, platform security, and internal analytics, where such interests are not overridden by your rights.
• Consent – processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Data

ph29 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors – GCash, Maya, and partner banks, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers – third-party services that assist ph29 in verifying your identity and age in compliance with PAGCOR requirements.
• Fraud prevention and security services – providers that help ph29 detect and prevent fraudulent activity on the Platform.
• IT and cloud infrastructure providers – companies that host and maintain the ph29 Platform infrastructure, bound by data processing agreements.
• Regulatory authorities – PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or court order.
• Professional advisers – lawyers, auditors, and accountants, where necessary for legal or compliance purposes, subject to professional confidentiality obligations.

8 Data Retention

ph29 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data – retained for the duration of your account and for a minimum of 5 years after account closure, as required by PAGCOR and AML regulations.
• Financial transaction records – retained for a minimum of 5 years from the date of the transaction, in compliance with Philippine AML and tax laws.
• Gaming history – retained for a minimum of 3 years for dispute resolution and regulatory audit purposes.
• Support communications – retained for 2 years from the date of the last interaction.
• Marketing consent records – retained for the duration of your consent and for 1 year after withdrawal of consent.

When personal data is no longer required, ph29 will securely delete or anonymize it in accordance with its data disposal procedures.

9 Data Security

ph29 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the ph29 Platform.
• Encryption of sensitive data at rest, including financial information and government ID data.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the ph29 Platform.
• Multi-factor authentication requirements for administrative access to ph29 systems.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

10 Cookies & Tracking Technologies

ph29 uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

10.1 Types of Cookies We Use

• Strictly necessary cookies – essential for the Platform to function, including session management and security. These cannot be disabled.
• Functional cookies – remember your preferences such as language settings and game display options.
• Analytics cookies – help us understand how players use the Platform so we can improve it. Data collected is aggregated and anonymized where possible.
• Marketing cookies – used to deliver relevant ph29 promotions and offers. These are only set with your consent.

10.2 Managing Cookies

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 ph29 Platform. Detailed instructions for managing cookies are available in your browser's help documentation.

11 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph29:

• Right to be informed – the right to know that your personal data is being collected and processed, and the purposes for which it is used.
• Right of access – the right to request a copy of the personal data ph29 holds about you.
• Right to rectification – the right to request correction of inaccurate or incomplete personal data.
• Right to erasure – the right to request deletion of your personal data, subject to ph29'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 where technically feasible.
• Right to lodge a complaint – the right to file a complaint with the National Privacy Commission (NPC) if you believe ph29 has violated your data privacy rights.

To exercise any of these rights, please contact ph29's Data Protection Officer using the details in Section 15. ph29 will respond to all verified data subject requests within 15 business days. We may need to verify your identity before processing your request.

12 Minors

ph29 is strictly intended for individuals who are 21 years of age or older, as required by Philippine gaming law. ph29 does not knowingly collect personal data from individuals under the age of 21. If ph29 becomes aware that personal data has been collected from a minor, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that a minor has registered on ph29, please contact our support team immediately so we can take appropriate action.

13 International Data Transfers

ph29 primarily processes and stores your personal data within the Philippines. In limited circumstances, your data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure or fraud prevention providers with international operations.

Where such transfers occur, ph29 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under the Data Privacy Act of 2012. ph29 will not transfer your personal data to countries that do not provide an adequate level of data protection without your explicit consent or a lawful basis for doing so.

14 Changes to This Policy

ph29 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When material changes are made, ph29 will notify registered players via email or an in-platform notification at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Policy periodically. Your continued use of the ph29 Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or ph29's data processing practices, please contact our Data Protection Officer:

• Data Protection Officer, ph29
• Email: [email protected]
• Live Chat: Available 24/7 via the ph29 Platform

If you are not satisfied with ph29's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.