ph01 Privacy Policy

This Privacy Policy ("Policy") describes how ph01 ("ph01," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the ph01 online gaming platform at ph01.app and all associated services (collectively, the "Platform").

ph01 is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. We process personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission ("NPC").

By registering an account on the ph01 Platform or by continuing to use our services, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the ph01 Platform immediately.

ph01 collects personal data that is necessary to provide you with a safe, compliant, and personalised gaming experience. The categories of personal data we collect include:

ph01 does not collect sensitive personal information (as defined under the Philippine DPA) unless strictly required for regulatory compliance purposes, such as identity verification. Where sensitive data is collected, we apply heightened security and access controls.

ph01 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated technologies: Technical and usage data collected automatically when you access the ph01 Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from risk management partners; payment data from GCash, PayMaya, and banking partners;
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory bodies in connection with licensing, compliance, or investigation requirements.

ph01 only collects personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed. We do not collect personal data speculatively or for purposes unrelated to the provision of our gaming services.

ph01 uses your personal data for the following purposes:

• Account management: Creating and maintaining your ph01 player account, verifying your identity and age (21+ requirement), and managing your account settings and preferences;
• Service delivery: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank; providing access to games; crediting bonuses and promotions;
• Legal and regulatory compliance: Meeting our obligations under Philippine gaming regulations, the Data Privacy Act of 2012, anti-money laundering laws, and PAGCOR licensing requirements;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other illegal conduct on the Platform;
• Responsible gaming: Monitoring player behaviour to identify signs of problem gambling and administering responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion;
• Customer support: Responding to your enquiries, resolving disputes, and improving our support services;
• Marketing communications: Sending 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: Analysing usage patterns and technical data to improve the ph01 Platform's performance, features, and user experience.

Under the Philippine Data Privacy Act of 2012, ph01 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you – i.e., to provide the ph01 gaming services you have registered for, including account management, payment processing, and game access;
• Legal obligation: Processing required to comply with applicable Philippine laws, including gaming regulations, anti-money laundering obligations, and tax reporting requirements;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

ph01 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: KYC and age verification service providers who assist ph01 in verifying player identities and meeting regulatory requirements;
• Fraud and risk management partners: Third-party fraud detection and risk screening services that help ph01 identify and prevent fraudulent activity;
• Game software providers: Licensed game developers and providers whose games are available on the ph01 Platform, to the extent necessary for game delivery and technical support;
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), Philippine law enforcement agencies, and courts, where required by applicable law or legal process;
• Professional advisers: Lawyers, auditors, and accountants engaged by ph01 in connection with legal, compliance, or financial matters, subject to professional confidentiality obligations.

ph01 does not transfer your personal data outside the Philippines except where necessary to provide our services (e.g., to internationally-based game software providers) and only where adequate data protection safeguards are in place. Any such transfers comply with the requirements of the Philippine Data Privacy Act of 2012.

ph01 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general guide, ph01 applies the following retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering record-keeping requirements;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations;
• Technical and usage data: Retained for up to two (2) years from collection, unless required for longer periods for fraud investigation or legal proceedings;
• Communications data: Retained for up to three (3) years from the date of the communication, or longer if relevant to an ongoing dispute or legal matter.

When personal data is no longer required, ph01 will securely delete or anonymise it in accordance with our data disposal procedures.

ph01 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph01 Platform;
• Encrypted storage of sensitive personal and financial data at rest;
• Access controls limiting access to personal data to authorised ph01 personnel on a strict need-to-know basis;
• Multi-factor authentication for ph01 staff accessing internal systems containing player data;
• Regular security audits and penetration testing of the ph01 Platform infrastructure;
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC notification requirements.

While ph01 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, ph01 will notify you and the National Privacy Commission in accordance with the requirements of the Philippine Data Privacy Act of 2012.

ph01 uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session security, and gather analytics data. A cookie is a small text file placed on your device when you visit the ph01 Platform.

ph01 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting Platform functionality;
• Functional cookies: Remember your preferences such as language settings and display options to provide a more personalised experience;
• Analytics cookies: Collect anonymised data about how players use the ph01 Platform, helping us identify areas for improvement. These are only placed with your consent;
• Marketing cookies: Used to deliver relevant promotional content within the ph01 Platform. These are only placed with your explicit consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph01 Platform. For more information on managing cookies in popular Philippine browsers and devices, refer to your browser's help documentation.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph01:

• Right to be Informed: You have the right to be informed of how your personal data is being collected and processed. This Privacy Policy fulfils that obligation;
• Right to Access: You may request a copy of the personal data ph01 holds about you, along with information about how it is being used;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you. You can update basic account information directly through your ph01 account dashboard;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where you have grounds relating to your particular situation;
• Right to Data Portability: You may request that ph01 provide your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: If you believe ph01 has not handled your personal data in accordance with the Philippine Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC).

ph01 may need to verify your identity before processing any privacy rights request to ensure we do not disclose personal data to unauthorised parties. We will not charge a fee for exercising your rights unless your request is clearly unfounded or excessive.

The ph01 Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. ph01 does not knowingly collect personal data from individuals under the age of 21.

ph01 employs age verification procedures during account registration to prevent underage access. If ph01 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to ph01, please contact our support team immediately via live chat so that we can investigate and take appropriate action.

ph01 also encourages parents and guardians to make use of parental control software and device-level restrictions to prevent minors from accessing online gaming platforms.

ph01 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players via email or in-platform notification.

We encourage you to review this Privacy Policy periodically to stay informed about how ph01 is protecting your personal data. The most current version of this Policy will always be available at ph01.app/privacy-policy.

Your continued use of the ph01 Platform following the posting of any changes to this Policy constitutes your acceptance of those changes. If you do not agree with the revised Policy, you must stop using the Platform and may request account closure by contacting our support team.

If you have any questions, concerns, or requests regarding this Privacy Policy or ph01's handling of your personal data, please contact our Data Protection Officer through any of the following channels:

• Live Chat: Available 24/7 within your ph01 account dashboard. This is the fastest way to reach our team – average response time is under 5 minutes.
• Privacy Email: [email protected] — for formal privacy rights requests and data-related enquiries. Responses within 15 business days.
• General Support: [email protected] — for general account and platform enquiries.

For complaints that cannot be resolved directly with ph01, Filipino players may contact the National Privacy Commission (NPC) of the Philippines through their official channels. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012.