ph234 Privacy Policy

This Privacy Policy ("Policy") describes how ph234 ("ph234", "we", "us", "our") — the operator of the online gaming platform accessible at ph234.co — collects, processes, stores, and protects the personal information of players, visitors, and other individuals ("you", "User") who interact with our platform, website, and associated services (collectively, the "Platform").

ph234 is a PAGCOR-regulated online gaming operator and is fully committed to its obligations as a personal information controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). Your personal data is important to us, and we handle it with the care and transparency that Philippine data privacy law requires.

This Policy applies to all personal data collected through the ph234 Platform, including data collected when you register an account, make deposits or withdrawals, play Games, interact with our customer support team, participate in promotions, or simply browse our website without registering. By using the Platform, you acknowledge that you have read and understood this Policy.

For the purposes of the Philippine Data Privacy Act of 2012, ph234 acts as the Personal Information Controller in respect of the personal data of Players and Users on the ph234 Platform. As Personal Information Controller, ph234 determines the purposes and means of processing personal data collected through the Platform.

ph234 operates as a PAGCOR-licensed entity in the Republic of the Philippines. Correspondence regarding data privacy matters, data subject rights requests, and privacy complaints should be directed to ph234's designated Data Protection Officer (DPO). Contact details for the DPO are provided in Section 14 of this Policy.

In relation to personal data processed by third-party service providers on ph234's behalf — including payment processors, game content providers, and analytics platforms — those providers act as Personal Information Processors under written data processing agreements that require them to process data solely on ph234's documented instructions and to implement appropriate security measures.

ph234 collects personal data in the following categories. The specific data collected depends on your level of interaction with the Platform:

Sensitive Personal Information

In certain regulated circumstances — particularly in relation to PAGCOR-mandated responsible gaming obligations, self-exclusion requests, or anti-money laundering requirements — ph234 may process data that constitutes sensitive personal information under the DPA, including information about your financial condition. ph234 processes such data only to the extent strictly necessary for compliance with its legal obligations and will implement heightened security controls for sensitive personal information.

ph234 processes your personal data for the following clearly defined purposes:

4.1 Account Registration and Management

To create, verify, and maintain your ph234 Account; to authenticate your identity at login; to communicate with you regarding your Account; and to ensure you meet the eligibility requirements set out in ph234's Terms and Conditions including the 21+ age requirement mandated by PAGCOR.

4.2 Provision of Gaming Services

To make the ph234 gaming platform available to you — including processing wagers, recording game results, crediting winnings, and maintaining your game history. Technical data such as IP address and device information is used to deliver and optimise the gaming experience and to detect technical issues.

4.3 Payment Processing

To process deposits via GCash, Maya, GrabPay, QR Ph, and Philippine bank transfers; to verify that payment instruments are registered in your name; to execute withdrawal requests to your verified payment methods; and to maintain financial transaction records as required by Philippine anti-money laundering law.

4.4 Regulatory Compliance

To fulfil ph234's legal obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act of 2001 (RA 9160) and its amendments, the Philippine Data Privacy Act, and other applicable Philippine laws. This includes KYC verification, suspicious transaction monitoring, and reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other authorities.

4.5 Responsible Gaming

To administer responsible gaming tools including deposit limits, session timers, reality checks, cooling-off periods, and self-exclusion. ph234 uses gameplay and financial data to identify patterns consistent with problem gambling behaviour and to fulfil its PAGCOR obligations in relation to player protection.

4.6 Fraud Prevention and Security

To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, account sharing, and other prohibited conduct under ph234's Terms and Conditions. Technical data and usage patterns are analysed for this purpose using automated and manual review processes.

4.7 Customer Support

To respond to your enquiries, complaints, and data subject rights requests; to maintain records of communications for dispute resolution and service improvement purposes; and to administer ph234's internal disputes process.

4.8 Marketing Communications

To send you promotional offers, bonus notifications, and platform updates, subject to your communication preferences. You may opt out of marketing communications at any time by updating your Account settings or by contacting ph234 Support. Opting out of marketing communications does not affect ph234's ability to send you service-related communications about your Account.

ph234 processes personal data only where a lawful basis exists under the Philippine Data Privacy Act. The applicable legal bases for ph234's data processing activities are:

• Contractual Necessity: Processing necessary to perform ph234's obligations under the Terms and Conditions — including Account management, payment processing, and provision of gaming services.
• Legal Obligation: Processing required for ph234 to comply with applicable Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act, and related regulations.
• Legitimate Interests: Processing carried out for ph234's legitimate business interests — specifically fraud prevention, platform security, and service improvement — where those interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and certain analytics activities, subject to your explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ph234 does not sell your personal data. We share personal data with third parties only in the following circumstances:

6.1 Service Providers (Personal Information Processors)

ph234 engages third-party service providers who process personal data on our behalf under written data processing agreements. These include payment processors (GCash, Maya, bank integrations), game content licensors, cloud hosting infrastructure providers, identity verification and KYC service providers, and customer support platform operators. All processors are contractually required to implement security measures consistent with PAGCOR and NPC standards.

6.2 Regulatory and Legal Disclosures

ph234 is legally obligated to share certain data with Philippine regulatory authorities including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies, in response to lawful requests, court orders, or as required by ph234's PAGCOR operating license. Such disclosures are made without prior notice to the Player where the law prohibits such notification (for example, in suspicious transaction reporting under the AMLA).

6.3 Business Transfers

In the event of a merger, acquisition, or sale of ph234's business or assets, personal data held by ph234 may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy. Players will be notified of any such transfer that materially affects the processing of their personal data.

ph234 retains personal data for the periods set out below, or longer where required by applicable Philippine law:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with NPC guidelines. Anonymised data — data from which all identifying information has been irreversibly removed — may be retained indefinitely for statistical and research purposes.

ph234 implements technical and organisational security measures appropriate to the risks associated with our processing activities. These measures include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and ph234's servers is encrypted using industry-standard TLS 1.3 encryption, preventing interception by third parties.
• Password Hashing: Account passwords are stored using one-way cryptographic hash functions with salting. ph234 never stores passwords in plaintext and cannot retrieve a forgotten password — only reset it.
• Access Controls: Access to personal data within ph234's systems is restricted on a need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and regular security training.
• Two-Factor Authentication: Available to all Account holders. ph234 strongly recommends enabling 2FA, particularly for Accounts with linked GCash or significant balances.
• Infrastructure Security: ph234's platform is hosted on enterprise-grade cloud infrastructure with regular security assessments, intrusion detection systems, and data backup procedures.
• Penetration Testing: ph234's systems undergo periodic security testing by qualified third-party security professionals to identify and remediate vulnerabilities.

ph234 uses cookies and similar tracking technologies on the Platform for the purposes described below. A "cookie" is a small text file stored on your device by your browser when you visit a website.

Essential Cookies

Required for the Platform to function. These cookies manage your login session, maintain your Account state between pages, enable secure connections, and prevent cross-site request forgery. These cookies cannot be disabled without impairing Platform functionality.

Functional Cookies

Used to remember your preferences — such as language settings, game lobby layout, and responsible gaming limit settings — to provide a personalised experience. These cookies persist across sessions and are stored for up to 12 months.

Analytics Cookies

ph234 uses analytics tools to understand how the Platform is used — which game categories are most popular, where users drop out of the registration flow, and how technical errors affect the user experience. Analytics data is collected in aggregate and processed in a manner that does not identify individual users where possible.

Security Cookies

Used to detect suspicious login behaviour, monitor for bot activity, and support fraud prevention systems. These cookies help ph234 distinguish legitimate human users from automated scripts and protect your Account from unauthorised access attempts.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will prevent you from logging into your ph234 Account. ph234 does not use third-party advertising or retargeting cookies.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to personal data ph234 holds about you. ph234 will respond to all verifiable data subject rights requests within the timeframes required by law:

To exercise any of these rights, contact ph234's Data Protection Officer using the details in Section 14. ph234 may need to verify your identity before processing a data subject rights request. Requests are processed free of charge unless manifestly unfounded or excessive.

The ph234 Platform is strictly intended for adults aged 21 years or older, as required by PAGCOR for all online gaming platforms licensed to operate in the Philippines. ph234 does not knowingly collect personal data from persons under the age of 21.

If ph234 becomes aware that personal data of a person under 21 has been collected — whether through a successful underage registration or any other means — ph234 will immediately suspend the relevant Account, delete the personal data of the minor to the extent permitted by applicable law, and, where required, report the matter to PAGCOR. Any financial balance associated with an underage Account will be handled in accordance with PAGCOR guidelines.

ph234 primarily processes personal data within the Republic of the Philippines. In certain circumstances, data may be processed by third-party service providers whose infrastructure is located outside the Philippines — for example, cloud hosting providers, international payment networks, or game content licensors operating regionally.

Any transfer of personal data outside the Philippines is conducted in accordance with the requirements of the Data Privacy Act and NPC issuances on cross-border data flows. ph234 ensures that recipient organisations in other countries provide an adequate level of data protection — whether through contractual data protection clauses, the recipient country's adequacy status under NPC determinations, or other lawful transfer mechanisms.

ph234 does not transfer personal data to countries that have not implemented adequate data protection safeguards without first ensuring that contractual protections equivalent to those required under Philippine law are in place.

ph234 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or NPC guidance. The date of the most recent update is displayed at the top of this Policy.

Material changes to this Policy — changes that significantly affect your rights as a data subject or the manner in which ph234 processes your personal data — will be communicated to you via email to your registered address or via a prominent notice on the Platform, not less than 14 days before the change takes effect. Your continued use of the Platform after a material change takes effect constitutes your acknowledgement of the revised Policy.

For non-material changes (such as clarifications, corrections, or formatting updates), ph234 will update the Policy without advance notice. The "Last Updated" date will reflect any revision. You are encouraged to review this Policy periodically.

ph234 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and the ph234 Privacy Policy. The DPO is your first point of contact for all data privacy matters, including data subject rights requests, privacy complaints, and questions about this Policy.

You may contact ph234's Data Protection Officer through the following channels:

• Email: [email protected] — mark your message "Attn: Data Protection Officer" for priority routing to the privacy team.
• Live Chat: Available on the ph234 Platform 24/7. For data privacy enquiries, request to speak with the DPO team specifically.

ph234 will respond to all data subject rights requests and privacy complaints within the timeframes required by the Data Privacy Act and applicable NPC issuances. Where a request cannot be fulfilled within the standard timeframe, ph234 will notify you of the expected resolution date and the reason for the delay.

If you are not satisfied with ph234's response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines in accordance with the procedures set out under the Data Privacy Act of 2012 and NPC Circular No. 16-03 (Rules on Privacy Complaints).