Privacy Policy – ph152 Data Protection

1 Introduction & Scope

This Privacy Policy ("Policy") describes how ph152 ("ph152," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the ph152 website at https://ph152.com and all associated services, games, and features (collectively, the "Platform").

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as well as applicable guidelines issued by the National Privacy Commission ("NPC") of the Philippines. It applies to all personal data collected through the Platform, whether submitted during registration, during gameplay, through customer support interactions, or through your use of payment services.

By registering an account on ph152 or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform and contact our support team to close your account.

2 Data Controller Information

ph152 is the data controller responsible for your personal data collected through the Platform. As data controller, ph152 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data privacy laws.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer ("DPO") using the following details:

• Email: [email protected] (plain text – not a clickable link)
• Live Chat: Available 24/7 through the ph152 Platform
• Response Time: We aim to respond to all data privacy inquiries within 15 business days of receipt.

3 Personal Data We Collect

ph152 collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

ph152 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law (for example, information relevant to responsible gaming assessments).

4 How We Use Your Personal Data

ph152 processes your personal data only for specific, legitimate purposes. The table below outlines the primary purposes for which we use your data and the legal basis for each:

ph152 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

5 Sharing Your Personal Data

ph152 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML service providers who assist us in verifying your identity and complying with our regulatory obligations.
• Game Software Providers: Licensed game studios and software providers whose games are available on the ph152 Platform, to the extent necessary to deliver game services.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulation.
• IT and Security Service Providers: Cloud hosting providers, cybersecurity firms, and data analytics providers who support the operation and security of the Platform, subject to strict confidentiality obligations.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by ph152, subject to professional confidentiality obligations.

Where ph152 engages third-party processors to handle your personal data on our behalf, we ensure that appropriate data processing agreements are in place, requiring those processors to handle your data only in accordance with our instructions and applicable Philippine data privacy law.

6 Cookies & Tracking Technologies

ph152 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymized data about how players interact with the Platform, helping us identify areas for improvement.
• Functional Cookies: Used to remember your preferences, such as language settings and game lobby layout, to provide a more personalized experience.
• Marketing Cookies: Used to deliver relevant promotional content based on your gaming activity and preferences. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, disabling them may prevent you from accessing your ph152 account.

7 Data Retention

ph152 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. Our general data retention periods are as follows:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML obligations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of the Philippines.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing Preferences: Retained until you withdraw your consent or close your account, whichever is earlier.
• Technical & Log Data: Retained for up to twelve (12) months for security and fraud detection purposes.

Upon expiry of the applicable retention period, ph152 will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

8 Data Security

ph152 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the ph152 Platform is encrypted using TLS 1.2 or higher. Stored personal and financial data is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized ph152 personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: ph152 supports two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Regular Security Audits: ph152 conducts regular internal and third-party security audits and penetration testing to identify and remediate vulnerabilities.
• Incident Response: ph152 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, ph152 will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act.

9 Your Data Privacy Rights

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 ph152:

To exercise any of the above rights, please contact our Data Protection Officer via live chat on the Platform or by email at [email protected] (plain text – not a clickable link). We will respond to all verified data subject requests within fifteen (15) business days of receipt.

10 Cross-Border Data Transfers

In certain circumstances, ph152 may transfer your personal data to service providers or partners located outside of the Philippines, for example, to cloud hosting providers or game software studios operating in other jurisdictions. Where such transfers occur, ph152 ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission;
• Implementing contractual clauses that require the recipient to protect your personal data to a standard equivalent to that required under Philippine law; and
• Obtaining your explicit consent where required by applicable law.

ph152 will not transfer your personal data to jurisdictions that do not provide adequate data protection safeguards without first implementing appropriate protective measures and, where required, obtaining your consent.

11 Children's Privacy

The ph152 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. ph152 does not knowingly collect, process, or store personal data from individuals under the age of 21.

If ph152 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to:

• Delete all personal data associated with the underage individual;
• Permanently close the associated account; and
• Void all transactions and forfeit all balances associated with the account.

If you are a parent or guardian and believe that your child under 21 has registered on ph152, please contact our support team immediately via live chat so we can take prompt action.

12 Marketing Communications

With your consent, ph152 may send you promotional communications about new games, bonuses, special offers, and platform updates via email, SMS, or in-platform notifications. You can manage your marketing preferences at any time through your account settings or by contacting our support team.

Even if you opt out of marketing communications, ph152 will continue to send you essential transactional communications related to your account, such as deposit confirmations, withdrawal notifications, security alerts, and updates to our Terms & Conditions or Privacy Policy.

ph152 does not share your contact details with third-party marketers. All promotional communications you receive will be from ph152 directly.

13 Responsible Gaming & Data

ph152 uses your gaming data – including bet history, session duration, deposit frequency, and loss patterns – to support our responsible gaming program. This data may be used to:

• Identify players who may be exhibiting signs of problem gambling;
• Trigger responsible gaming interventions, such as pop-up reminders or cooling-off suggestions;
• Process self-exclusion requests and enforce exclusion periods; and
• Comply with PAGCOR responsible gaming requirements.

The processing of your gaming data for responsible gaming purposes is carried out in your vital interest and in compliance with our legal obligations. This processing cannot be opted out of, as it forms a core part of our regulatory compliance obligations. For more information, please visit our Responsible Gaming page.

14 Changes to This Policy

ph152 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is always displayed at the top of this page.

Where changes to this Policy are material, ph152 will notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

We encourage you to review this Policy periodically to stay informed about how ph152 protects your personal data.

15 Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph152, please do not hesitate to reach out to our Data Protection Officer:

• Email: [email protected] (plain text – not a clickable link)
• General Support: [email protected] (plain text – not a clickable link)
• Live Chat: Available 24/7 on the ph152 Platform
• Response Time: Within 15 business days for data privacy requests

If you are not satisfied with our response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.