ph93 Privacy Policy

1. Who We Are

ph93 is a PAGCOR-regulated online gaming platform operating under the Philippine Amusement and Gaming Corporation's licensing framework. ph93 is the data controller responsible for the personal information of all registered players on the ph93 Platform accessible at ph93.app. For all data privacy inquiries, ph93's designated Data Protection Officer (DPO) may be contacted at [email protected].

2. Scope of This Privacy Policy

This Privacy Policy applies to all personal information collected by ph93 through or in connection with the ph93 Platform, including:

• Account registration and KYC verification processes;
• Deposit, withdrawal, and payment transactions;
• Gameplay activity across all ph93 games (casino, slots, bingo, Dragon Tiger Luck, Coin, and others);
• Customer support communications conducted via live chat, email, Messenger, or Viber;
• Use of ph93's website and mobile browser interface, including passive data collection through cookies and server logs.

This Policy is governed by the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable PAGCOR data handling directives. To the extent that ph93 processes data of individuals located in the European Union, the General Data Protection Regulation (GDPR) principles are also observed as a matter of best practice.

3. Personal Data We Collect

ph93 collects the following categories of personal data from players:

4. How We Collect Your Data

ph93 collects personal data through the following means:

• Direct submission: Information you provide during Account registration, KYC document upload, deposit and withdrawal forms, and customer support interactions.
• Automated collection: Technical data collected passively as you use the Platform, including server access logs, session cookies, and device fingerprinting for fraud prevention purposes.
• Third-party sources: Identity verification data received from PAGCOR's KYC verification system, payment confirmation data received from GCash, Maya, BPI, BDO, Metrobank, and other payment providers.

5. Legal Basis for Processing

ph93 processes personal data under the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between ph93 and the Player — including Account operation, game provision, deposit processing, and withdrawal fulfillment.
• Legal obligation: Processing required to comply with PAGCOR licensing requirements, AML obligations under Republic Act No. 9160, tax reporting obligations, and law enforcement cooperation duties.
• Legitimate interest: Processing for fraud detection, security monitoring, responsible gaming oversight, and Platform improvement — where ph93's interests do not override the rights and interests of the Player.
• Consent: Processing for marketing communications and optional analytics features, where the Player has provided explicit opt-in consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6. How ph93 Uses Your Personal Data

ph93 uses collected personal data for the following purposes:

• Creating, maintaining, and securing your ph93 Account, including OTP delivery and two-factor authentication;
• Verifying your identity and age (21+) as required by PAGCOR and Philippine law before enabling real-money gaming;
• Processing deposits and withdrawals via GCash, Maya, and banking channels in Philippine Peso (PHP);
• Detecting and preventing fraud, money laundering, unauthorized access, and prohibited conduct as defined in ph93's Terms & Conditions;
• Monitoring gameplay for responsible gaming indicators and delivering responsible gaming interventions where warranted;
• Compiling anonymized statistical reports for PAGCOR regulatory submissions;
• Improving the Platform through aggregated usage analytics — players may opt out of non-essential analytics cookies via their browser settings;
• Sending transactional communications (deposit confirmations, withdrawal alerts, security OTPs, account status updates) via SMS to your registered Philippine mobile number;
• Sending promotional communications where you have given explicit consent — players may opt out at any time by contacting [email protected].

7. Sharing Your Personal Data

ph93 does not sell personal data to third parties. ph93 may share personal data with the following categories of recipients only for the purposes described in this Policy:

• PAGCOR: ph93 is obligated to report player data as required under its PAGCOR operating license, including KYC records, transaction logs, and responsible gaming intervention reports.
• Payment processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), BPI, BDO, Metrobank, and other payment providers receive only the data necessary to process transactions.
• Identity verification providers: Third-party KYC service providers accredited by PAGCOR may process government ID images and biometric data solely for identity verification. Such providers are bound by confidentiality and data protection agreements.
• Anti-money laundering authorities: The Anti-Money Laundering Council (AMLC) and law enforcement agencies under the authority of a valid Philippine court order or applicable law.
• Legal and regulatory authorities: Courts, government agencies, and regulatory bodies as required by Philippine law or in connection with legal proceedings involving ph93.
• Platform technology providers: Cloud hosting, cybersecurity, and customer support technology vendors operating under strict data processing agreements that prohibit secondary use of ph93 player data.

8. Cookies & Tracking Technologies

ph93 uses cookies and similar tracking technologies on the ph93 Platform for the following purposes:

• Essential cookies: Required for basic Platform functions including login session management, security token validation, and remembering your cookie preferences. These cannot be disabled without impairing Platform functionality.
• Security cookies: Used for fraud detection, bot prevention, and identifying suspicious login patterns. These are essential to PAGCOR's security requirements for online gaming platforms.
• Analytics cookies: Aggregate, anonymized data on page usage patterns used to improve the ph93 Platform. These are non-essential and may be declined via your browser's privacy settings.

ph93 does not use third-party advertising or retargeting cookies. ph93 does not share cookie-derived data with advertising networks. Players may manage cookie preferences through their browser settings; however, disabling essential cookies will prevent normal use of the ph93 Platform.

9. Data Security

ph93 implements technical and organizational security measures appropriate to the risk associated with processing player personal data, including:

• 256-bit TLS/SSL encryption for all data in transit between the player's browser and ph93's servers;
• AES-256 encryption at rest for all sensitive personal data stored on ph93's servers, including government ID documents and financial records;
• Role-based access controls ensuring that ph93 staff can only access player data necessary for their specific function;
• Two-factor authentication on all administrative systems that can access player data;
• Regular penetration testing conducted by independent cybersecurity firms;
• Breach response procedures aligned with the National Privacy Commission's mandatory 72-hour breach notification requirement under the Data Privacy Act.

Despite these measures, no internet-based data transmission is completely secure. Players are encouraged to maintain strong, unique passwords for their ph93 Account and to enable Account-level two-factor authentication.

10. Data Retention

ph93 retains personal data for the following minimum periods:

• Account and KYC data: Minimum of 5 years following Account closure, as required by PAGCOR's record-keeping obligations and the Anti-Money Laundering Act.
• Transaction records: Minimum of 5 years from the date of each transaction, in compliance with AML record-keeping requirements.
• Customer support communications: 3 years from the date of the communication, for dispute resolution and training purposes.
• Technical and security logs: 12 months from the date of collection, unless an active fraud investigation requires extended retention.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with ph93's data disposal procedures.

11. Your Privacy Rights

Under the Data Privacy Act of 2012, ph93 players have the following rights with respect to their personal data:

To exercise any of these rights, submit a written request to ph93's Data Protection Officer at [email protected], identifying your ph93 Account and the specific right you wish to exercise. ph93 will acknowledge all rights requests within 5 business days and resolve them within 30 calendar days.

Limitations: The right to erasure and right to object may be limited where ph93 has a legal obligation to retain data (e.g., PAGCOR record-keeping, AML compliance, active dispute resolution). ph93 will inform you of any applicable limitations at the time of your request.

If you believe that ph93 has violated your data privacy rights, you may lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

12. Children and Minors

The ph93 Platform is strictly prohibited for use by persons under 21 years of age in accordance with PAGCOR regulations. ph93 does not knowingly collect personal data from individuals under the age of 21.

If ph93 discovers that personal data has been collected from a person under the age of 21, ph93 will immediately suspend the relevant Account, return any deposited funds after administrative processing, and permanently delete all personal data associated with that Account from its active systems. Parents or guardians who believe a minor may have created a ph93 Account should contact [email protected] immediately.

13. Cross-Border Data Transfers

ph93 is a Philippines-focused platform and stores the majority of player personal data on servers located within the Philippines. Where ph93 engages third-party service providers whose infrastructure is located outside the Philippines — for example, cloud computing providers or cybersecurity vendors — ph93 ensures that appropriate data transfer mechanisms are in place, including contractual obligations to comply with the Data Privacy Act and standards materially equivalent to those applicable in the Philippines.

ph93 does not transfer player personal data to jurisdictions that do not offer adequate data protection standards without appropriate safeguards. A list of countries to which ph93 may transfer data and the applicable safeguards in place is available upon written request to the ph93 Data Protection Officer.

14. Changes to This Privacy Policy

ph93 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. The most current version of the Privacy Policy will always be published at ph93.app/privacy-policy with the effective date clearly stated.

Where changes are material — meaning they affect the categories of data collected, the purposes of processing, data sharing arrangements, or player rights — ph93 will notify registered players via SMS to their registered Philippine mobile number or in-Platform notification at least 7 days before the changes take effect. Continued use of the ph93 Platform after the effective date of any revised Privacy Policy constitutes acceptance of the changes.

15. Contact & Data Protection Officer

ph93 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. All data privacy inquiries, rights requests, and complaints should be directed to:

Players who remain unsatisfied following ph93's internal resolution process may escalate their complaint to the National Privacy Commission of the Philippines.