Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") is issued by ph354 ("we," "us," "our," or "ph354") and applies to all personal information collected from individuals ("you," "your," or "Data Subject") who access, register for, or use the ph354 online gaming platform available at ph354.cam and any associated mobile or browser-based interfaces (collectively, the "Service").

This Policy is designed to comply with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines. It is also consistent with the data-handling requirements imposed on PAGCOR-licensed operators.

By using the ph354 Service, you consent to the collection, use, storage, and processing of your personal information as described in this Policy. If you do not agree with any part of this Policy, you should immediately stop using the Service and contact our support team to close your account.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

ph354 acts as the Personal Information Controller (PIC) in respect of all personal data collected through the Service, as that term is defined under the Data Privacy Act of 2012. This means ph354 determines the purposes and means of processing your personal information and bears primary responsibility for its safekeeping.

Certain data processing activities may be performed on ph354's behalf by authorized third-party service providers acting as Personal Information Processors (PIP). Such processors are bound by data processing agreements that require them to handle your information only on ph354's instructions and in accordance with applicable Philippine privacy law.

For all data privacy concerns, inquiries, or requests, you may contact our designated Data Protection Officer (DPO) by writing to [email protected] with the subject line "Data Privacy Request."

3. Data We Collect

3.1 Information You Provide Directly

When you register for a ph354 account or use the Service, you provide us with:

• Identity data: Full legal name, date of birth, nationality, and gender;
• Contact data: Residential address (within the Philippines), mobile phone number, and email address;
• Identification documents: Scans or photographs of government-issued ID (e.g., Philippine passport, driver's license, UMID, SSS ID, Postal ID) submitted for KYC verification;
• Financial data: GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history, and deposit/withdrawal records;
• Account credentials: Username, hashed password (we do not store plaintext passwords), and security question answers;
• Communications: Records of your interactions with ph354 customer support, including live chat transcripts and email correspondence.

3.2 Information Collected Automatically

When you use the ph354 platform, we automatically collect certain technical information:

• Device and browser data: IP address, device type, operating system version, browser type and version, screen resolution, and device identifiers;
• Usage data: Pages visited, games played, session duration, click patterns, and navigation paths within the platform;
• Transaction logs: Timestamps and details of all deposit, withdrawal, wager, and game result events associated with your account;
• Location data: General geographic location derived from IP address, used to verify that you are accessing the Service from within the Philippines.

3.3 Information from Third Parties

ph354 may receive personal information about you from:

• Payment processors (GCash, PayMaya, banks) to verify transaction authenticity;
• Identity verification and KYC service providers authorized by PAGCOR;
• Fraud prevention and anti-money-laundering screening services;
• PAGCOR and other Philippine regulatory authorities, where required by law.

4. How We Use Your Data

ph354 processes your personal information for the following purposes:

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, ph354 processes your personal information on the following lawful grounds:

• Contractual necessity: Processing required to perform our obligations under the ph354 Terms & Conditions, including account creation, payment processing, and game operation;
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, court orders, or other applicable Philippine law;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your privacy rights;
• Consent: Processing for direct marketing communications and non-essential cookies, subject to your right to withdraw consent at any time without affecting prior processing.

Where processing is based on consent, you may withdraw that consent at any time by contacting our support team or adjusting your account settings. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6. Sharing Your Data

ph354 does not sell your personal information. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other authorized payment partners, for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers: Third-party services engaged by ph354 to perform identity checks and document verification as required by PAGCOR;
• Gaming technology providers: JILI, Evolution Gaming, Pragmatic Play, and other licensed game suppliers who may process limited gameplay data as part of game delivery;
• Fraud and AML screening services: Authorized providers used to screen transactions and player activity against sanctions lists and fraud databases;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, or courts — where ph354 is legally required to disclose information;
• Professional advisers: Lawyers, auditors, and compliance consultants bound by professional confidentiality obligations.

All third parties with whom ph354 shares personal data are required to maintain appropriate technical and organizational security measures and to process your data only for the specific purposes for which it was shared.

7. Cookies & Tracking Technologies

ph354 uses cookies, web beacons, pixel tags, and similar tracking technologies to operate and improve the Service. The types of cookies we use are:

• Strictly necessary cookies: Essential for the operation of the ph354 platform, including session management, authentication, and security. These cannot be disabled without affecting core functionality;
• Functional cookies: Used to remember your preferences, language settings, and display options to personalize your experience;
• Analytics cookies: Used to collect aggregated, anonymized data on how players interact with the platform, helping us identify and resolve performance issues;
• Security cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other unauthorized access.

ph354 does not use advertising or cross-site tracking cookies. You can manage or delete cookies through your browser settings at any time. Note that disabling certain cookies may affect your ability to use some features of the ph354 platform.

8. Data Retention

ph354 retains your personal information for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods are as follows:

• Account and identity records: Retained for a minimum of five (5) years after account closure, as required under PAGCOR licensing conditions and AMLA regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLC reporting requirements;
• Customer support records: Retained for three (3) years after the resolution of each support interaction;
• Marketing consent records: Retained for the duration of your account and for one (1) year after account closure as evidence of lawful marketing processing.

Upon the expiration of the applicable retention period, ph354 will securely delete or anonymize your personal information, except where a longer retention period is required by a court order, regulatory directive, or ongoing investigation.

9. Data Security

ph354 implements appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and ph354 servers is protected by 256-bit SSL/TLS encryption. Sensitive data at rest is encrypted using industry-standard algorithms;
• Access controls: Access to personal data is restricted to ph354 personnel and authorized processors who require it to perform their specific duties, under role-based access control policies;
• Two-factor authentication: Available on all ph354 player accounts and mandatory for all administrative access to ph354 internal systems;
• Security monitoring: Continuous monitoring of platform activity for anomalies, unauthorized access attempts, and suspicious patterns;
• Incident response: ph354 maintains a documented data breach response procedure. In the event of a breach likely to prejudice your rights, we will notify the NPC and affected individuals in accordance with the Data Privacy Act of 2012.

While ph354 takes all reasonable precautions, no online platform can guarantee absolute security. You are responsible for keeping your ph354 account credentials confidential and for notifying us immediately of any unauthorized access to your account.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and NPC regulations, you have the following rights with respect to your personal information held by ph354:

• Right to be informed: The right to know what personal data ph354 collects, how it is used, and who it is shared with — as set out in this Policy;
• Right of access: The right to request a copy of the personal information ph354 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data in your ph354 account;
• Right to erasure: The right to request deletion of your personal data, subject to ph354's legal obligations to retain certain records under PAGCOR and AMLA requirements;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability: The right to receive a copy of certain personal data in a structured, commonly used, and machine-readable format;
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission if you believe ph354 has violated your data privacy rights.

To exercise any of these rights, please contact ph354's Data Protection Officer by emailing [email protected] with the subject line "Data Privacy Request." ph354 will respond to all verified requests within fifteen (15) business days, consistent with NPC guidelines.

11. Children's Privacy

The ph354 Service is strictly intended for individuals who are twenty-one (21) years of age or older, consistent with Philippine law governing casino-style gambling activities. ph354 does not knowingly collect personal information from individuals under the age of 21.

If ph354 discovers that personal data has been collected from a person under the age of 21 without proper verification, that account will be immediately suspended, all associated transactions will be reviewed, and the personal data will be deleted or anonymized as appropriate.

If you believe that ph354 may hold personal information relating to a person under 21 years of age, please contact us immediately at [email protected].

12. Third-Party Services

The ph354 platform integrates third-party gaming providers and payment processors to deliver the Service. These third parties operate under their own privacy policies and data handling practices. ph354 vets all third-party partners for compliance with applicable Philippine data privacy standards before integration.

ph354 is not responsible for the privacy practices of third-party websites or services that are not operated by or on behalf of ph354. This Policy applies solely to data processed through the ph354 platform. We encourage you to review the privacy policies of any third-party services you use in connection with ph354.

13. Changes to This Policy

ph354 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes to this Policy will be communicated to registered users via email or through a prominent notice on the ph354 platform at least seven (7) days before the changes take effect, where reasonably practicable.

The date of the most recent update is displayed at the top of this page. Your continued use of the ph354 Service following the effective date of any amended Policy constitutes your acknowledgment of the changes. If you do not agree with the revised Policy, you must discontinue use of the Service and request account closure.

14. Contact & Complaints

For questions, concerns, or requests relating to this Privacy Policy or ph354's data handling practices, please contact our Data Protection Officer:

• Email: [email protected] (subject: "Data Privacy Request")
• Live Chat: Available 24/7 through your ph354 account dashboard
• Coverage: Serving players across Manila, Cebu, Davao, Quezon City, Makati & beyond

If you are not satisfied with ph354's response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Data Privacy Act of 2012. ph354 fully cooperates with NPC investigations and audits.