ph235 Privacy Policy

This Privacy Policy ("Policy") describes how ph235 ("ph235," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "Data Subject") who access or use the ph235 online casino platform available at ph235.club (the "Platform").

This Policy applies to all personal data processed by ph235 in connection with your use of the Platform, including data collected during account registration, identity verification, gameplay, financial transactions, customer support interactions, and marketing communications.

This Policy should be read alongside the ph235 Terms & Conditions and Responsible Gaming Policy, both of which form part of your agreement with ph235.

By registering an account with ph235 or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform.

ph235 is the data controller responsible for the personal data collected through the Platform. As data controller, ph235 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173, as amended) and its Implementing Rules and Regulations.

ph235 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the ph235 DPO using the contact details provided in Section 15 of this Policy.

ph235 collects the following categories of personal data in connection with your use of the Platform:

• Full legal name as it appears on your government-issued identification.
• Date of birth and age verification information.
• Residential address, including barangay, city or municipality, province, and postal code.
• Email address and mobile phone number.
• Government-issued identification documents (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID, Voter's ID).

• GCash or PayMaya account details (registered name and mobile number).
• Philippine bank account details for bank transfer transactions (account name, account number, bank name).
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references.
• Source of funds documentation where required for anti-money laundering compliance.

• Account username and encrypted password.
• Game history, including games played, wager amounts, win/loss records, and session durations.
• Bonus and promotion usage history.
• Responsible gaming settings, including deposit limits, loss limits, and self-exclusion status.
• Customer support interaction records, including chat transcripts and email correspondence.

• IP address and approximate geographic location derived from IP.
• Device type, operating system, browser type and version.
• Pages visited on the Platform, time spent on pages, and navigation paths.
• Cookie identifiers and similar tracking technology data (see Section 8).
• Login timestamps and session activity logs.

ph235 does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

ph235 collects your personal data through the following means:

• Direct Collection: Data you provide directly when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Data collected automatically when you access and use the Platform, including through cookies, web beacons, server logs, and similar technologies (see Section 8).
• Third-Party Sources: Data received from identity verification service providers, payment processors (such as GCash and PayMaya), fraud detection services, and regulatory bodies where permitted by law.
• Public Sources: In limited circumstances, ph235 may collect data from publicly available sources for fraud prevention and AML compliance purposes.

ph235 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your ph235 player account, including processing your registration, verifying your identity, and managing your account settings.
• Platform Operation: To provide you with access to ph235 games and services, process your wagers, calculate and credit winnings, and manage your account balance.
• Financial Transactions: To process deposits and withdrawals, verify payment method ownership, and maintain accurate financial records.
• Regulatory Compliance: To comply with applicable Philippine laws and regulations, including KYC requirements, anti-money laundering obligations under the AMLA, and PAGCOR regulatory requirements.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling, enforce responsible gaming tools such as deposit limits and self-exclusion, and comply with responsible gaming obligations.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, cheating, and other prohibited conduct on the Platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the ph235 Platform.

ph235 processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or the use of non-essential cookies.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and ph235, including account registration, gameplay, and financial transactions.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to ph235, including KYC verification, AML reporting obligations under the Anti-Money Laundering Act, and PAGCOR regulatory requirements.
• Legitimate Interests: Where processing is necessary for the legitimate interests of ph235, such as fraud prevention, platform security, and improving the quality of our services, provided that such interests are not overridden by your rights and interests.

Where ph235 relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ph235 does not sell, rent, or trade your personal data to third parties. ph235 may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

ph235 engages trusted third-party service providers to assist in operating the Platform, including identity verification providers, payment processors (GCash, PayMaya, and Philippine banks), cloud hosting providers, fraud detection services, and customer support platform providers. These service providers are contractually bound to process your data only on ph235's instructions and in accordance with applicable data protection laws.

ph235 partners with game software providers to deliver casino games on the Platform. These providers may receive limited technical data necessary to deliver game content and verify game outcomes. They are not permitted to use this data for their own marketing or other independent purposes.

ph235 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive. ph235 will notify you of such disclosures where legally permitted to do so.

In the event of a merger, acquisition, restructuring, or sale of all or part of ph235's business, your personal data may be transferred to the acquiring entity as part of that transaction. ph235 will notify you of any such transfer and ensure that the acquiring entity is bound by privacy obligations no less protective than those in this Policy.

ph235 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. ph235 uses the following types of cookies:

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the ph235 Platform. For detailed instructions on managing cookies in your browser, refer to your browser's help documentation.

ph235 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 retention periods apply:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by Philippine AML regulations and PAGCOR requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with the Anti-Money Laundering Act and applicable tax regulations.
• Gaming History: Retained for a minimum of three (3) years from the date of the gaming session, for dispute resolution and regulatory audit purposes.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of consent management.
• Technical and Usage Data: Retained for up to twelve (12) months, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, ph235 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

ph235 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the ph235 Platform is encrypted using TLS (Transport Layer Security) protocols. Sensitive data stored on ph235 servers, including passwords and financial information, is encrypted at rest.
• Access Controls: Access to personal data is restricted to ph235 personnel and service providers who have a legitimate need to access it for the purposes described in this Policy. All access is logged and monitored.
• Two-Factor Authentication: ph235 offers two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorised access.
• Regular Security Audits: ph235 conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the Platform.
• Incident Response: ph235 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, ph235 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay.

While ph235 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your ph235 account credentials.

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 ph235:

To exercise any of these rights, please contact the ph235 Data Protection Officer using the contact details in Section 15. ph235 will respond to all data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further sixty (60) days, in which case ph235 will notify you of the extension and the reasons for it.

ph235 will not charge a fee for processing data subject requests unless the request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

The ph235 Platform is strictly intended for individuals aged twenty-one (21) years and above, as required by Philippine gaming regulations. ph235 does not knowingly collect personal data from individuals under the age of 21.

If ph235 becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that ph235 may have collected data from a minor, please contact us immediately using the details in Section 15.

ph235 employs age verification measures during the registration process to prevent underage individuals from accessing the Platform. These measures include verification of government-issued identification documents.

ph235 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where ph235 uses cloud hosting infrastructure or game software providers with servers located abroad.

Where personal data is transferred outside the Philippines, ph235 ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012. These safeguards may include contractual clauses approved by the National Privacy Commission, adequacy decisions, or other legally recognised transfer mechanisms.

By using the ph235 Platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

ph235 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or Platform features. When we make material changes to this Policy, we will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

The updated Policy will be posted on this page with a revised "Last Updated" date. We encourage you to review this Policy periodically to stay informed about how ph235 protects your personal data. Your continued use of the Platform following the posting of an updated Policy constitutes your acceptance of the changes.

If you have any questions, concerns, or requests regarding this Privacy Policy or ph235's data processing practices, please contact our Data Protection Officer:

• Data Protection Officer, ph235
• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 within your ph235 account dashboard.
• Response Time: ph235 aims to acknowledge all privacy-related enquiries within forty-eight (48) hours and to provide a substantive response within thirty (30) days.

ph235 is committed to resolving all privacy-related concerns promptly and fairly. If you are not satisfied with ph235's response to your concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines.

ph235 serves players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond. Our support team is available in English and Filipino to assist you with any privacy-related queries.