ph86 Privacy Policy

In this Privacy Policy, the following terms have the meanings set out below:

2.1 ph86 is the data controller responsible for personal data processed through the ph86 platform at ph86.club. As data controller, ph86 determines the purposes and means of processing personal data collected from its Account Holders, visitors, and other individuals who interact with the platform.

2.2 ph86 processes personal data in accordance with Republic Act 10173 (Data Privacy Act of 2012), its implementing rules and regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines, as well as applicable PAGCOR regulations governing player data management in the online gaming sector.

2.3 For any privacy-related queries, requests to exercise data subject rights, or complaints regarding ph86's handling of personal data, please contact ph86 using the contact information provided in Section 15 of this Policy.

3.1 ph86 collects the following categories of personal data in connection with the provision of its gaming services:

3.2 ph86 does not collect sensitive personal information beyond what is strictly necessary for KYC compliance and AML obligations. ph86 does not collect biometric data except where required by PAGCOR regulations for identity verification purposes.

4.1 ph86 collects personal data through the following channels:

• Direct submission: Information you provide when registering an Account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or setting responsible gaming limits;
• Automated collection: Technical and usage data collected automatically when you access the ph86 platform, including IP address, device identifiers, browser information, and session activity logs;
• Payment providers: Transaction confirmation data received from GCash, Maya, BPI, BDO, and other payment service providers in connection with your deposit and withdrawal activity;
• Third-party verification services: Identity verification data returned from KYC service providers as part of the document verification process;
• Cookies and tracking technologies: Behavioural and preference data collected via cookies and similar technologies as described in Section 10 of this Policy.

5.1 ph86 processes personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Contractual necessity: Processing required to perform the contract between ph86 and the Account Holder — including account management, gaming service delivery, payment processing, and customer support;
• Legal obligation: Processing required to comply with ph86's obligations under Philippine law, including PAGCOR licensing conditions, AML obligations under Republic Act 9160 (Anti-Money Laundering Act), and KYC requirements;
• Legitimate interests: Processing for ph86's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — where such interests are not overridden by the Data Subject's rights;
• Consent: Processing based on the Data Subject's explicit consent, including for marketing communications (where opted in) and certain non-essential cookies. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6.1 ph86 uses the personal data it collects for the following purposes:

• To create, verify, and manage your ph86 Account, including processing your KYC documents and confirming your eligibility to use the Platform;
• To provide access to ph86 Gaming Services, including live casino, slots, bingo, and sports betting, and to process all associated wagers, results, and payouts;
• To process and reconcile deposits and withdrawals via GCash, Maya, bank transfer, and other supported payment methods;
• To conduct AML screening and monitor transaction patterns for suspicious activity in compliance with Republic Act 9160 and PAGCOR requirements;
• To verify your identity and age at registration and at any subsequent point where additional verification is required by regulation or platform policy;
• To communicate with you about your Account, including security alerts, transaction confirmations, and support responses;
• To send you promotional communications about ph86 bonuses and offers, where you have not opted out of such communications;
• To operate ph86's responsible gaming tools, including monitoring wagering patterns that may indicate problem gambling and applying limits or restrictions where necessary;
• To prevent, detect, and investigate fraud, cheating, account sharing, bonus abuse, and other prohibited conduct;
• To improve the ph86 platform through analysis of usage patterns, technical performance data, and player feedback.

6.2 ph86 does not use personal data for automated individual decision-making that produces legal or similarly significant effects on the Data Subject, except where required by AML or compliance obligations, in which case the Data Subject will be notified and may request human review.

7.1 ph86 does not sell, rent, or trade personal data to third parties for commercial purposes. ph86 may share personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment service providers: GCash, Maya, BPI, BDO, UnionBank, Metrobank, and other payment processors, solely for the purpose of processing your transactions;
• Game providers: Third-party game studios and live dealer operators integrated into the ph86 platform (e.g., PG Soft, JILI, Pragmatic Play, Evolution Gaming), to the minimum extent necessary to operate game sessions and resolve disputes;
• KYC and identity verification services: Third-party providers used to verify the authenticity of government-issued identification documents submitted during the KYC process;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, and other Philippine government bodies, where disclosure is required by law, regulation, court order, or regulatory direction;
• IT and platform service providers: Cloud hosting, security, analytics, and customer support technology providers who process data on ph86's behalf under binding data processing agreements;
• Legal and professional advisors: Lawyers, auditors, and other professional advisors who require access to data for the purpose of advising ph86 in connection with specific matters.

7.2 All third-party service providers who process personal data on behalf of ph86 are required to maintain appropriate technical and organisational security measures and to process data only in accordance with ph86's documented instructions.

8.1 ph86 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

8.2 Upon expiry of the applicable retention period, ph86 will securely delete or anonymise personal data in accordance with its data disposal procedures, unless a longer retention period is required by a specific legal obligation or regulatory direction.

9.1 ph86 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between players' devices and ph86's servers;
• Hashing and salting of Account passwords — ph86 does not store passwords in plain text;
• Access controls limiting data access to authorised personnel on a strict need-to-know basis;
• Multi-factor authentication requirements for administrative access to ph86's data systems;
• Regular security assessments, penetration testing, and vulnerability management procedures;
• Incident response procedures for detecting, containing, and reporting personal data breaches.

9.2 In the event of a personal data breach that is likely to result in a high risk to the rights and freedoms of affected Data Subjects, ph86 will notify the NPC and affected Account Holders in accordance with the breach notification requirements under the Data Privacy Act of 2012 and NPC regulations.

9.3 Notwithstanding ph86's security measures, no data transmission or storage system can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your ph86 Account credentials and for ensuring that your registered mobile number and email address remain current and under your control.

10.1 ph86 uses cookies and similar tracking technologies to operate and improve the platform, maintain session state, analyse usage patterns, and detect fraudulent activity. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function correctly, including session management, authentication, and security features. These cannot be disabled without impairing platform functionality;
• Performance and analytics cookies: Used to collect aggregated data on how players use the ph86 platform, which pages are accessed most frequently, and where technical errors occur. This data is used solely to improve platform performance;
• Functional cookies: Used to remember your preferences — such as language settings and responsible gaming tool configurations — to improve your experience across sessions;
• Security cookies: Used to detect abnormal login behaviour, identify suspicious access patterns, and protect against session hijacking and cross-site request forgery (CSRF) attacks.

10.2 ph86 does not use cookies for cross-site advertising or behavioural profiling by third-party advertising networks. ph86 does not permit third-party advertisers to place tracking cookies on the ph86 domain.

10.3 You may manage your browser's cookie settings to restrict or delete cookies. However, disabling strictly necessary cookies will impair your ability to use the ph86 platform, including the ability to log in and access Gaming Services.

11.1 As a Data Subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph86:

11.2 To exercise any of the above rights, please contact ph86 using the details in Section 15. ph86 will respond to verified requests within fifteen (15) business days of receipt. ph86 may require identity verification before actioning a data subject request.

12.1 ph86 is strictly restricted to individuals aged 21 years and above in accordance with PAGCOR regulations applicable to casino-style gaming in the Philippines. ph86 does not knowingly collect personal data from persons under the age of 21.

12.2 Age is a mandatory field in the ph86 registration process and is verified through KYC document submission. Any Account found to belong to a person under 21 years of age will be immediately closed, and any funds in the Account will be returned to the registered payment method after identity verification.

13.1 The ph86 platform integrates third-party game content, live dealer streams, and payment processing services. While ph86 takes reasonable steps to ensure that its third-party service providers maintain appropriate data protection standards, ph86 is not responsible for the privacy practices of independent third parties.

13.2 Each third-party game provider and payment processor operates under its own privacy policy and data handling procedures. Players are encouraged to review the privacy policies of relevant service providers — particularly payment networks such as GCash and Maya — for information about how those providers handle your personal data in connection with transactions.

13.3 ph86 does not operate external social media accounts linked to the ph86.club domain that collect personal data from players. If you encounter a social media profile claiming to be affiliated with ph86, please verify its authenticity through ph86's official support channel before providing any personal information.

14.1 ph86 reserves the right to update or revise this Privacy Policy at any time to reflect changes in its data processing practices, applicable law, or regulatory requirements. The effective date displayed at the top of this document will be updated to reflect the date of any material revision.

14.2 Where changes are material — meaning they significantly affect how ph86 processes your personal data or your rights as a Data Subject — ph86 will provide advance notice via your registered email address or through a prominent notice on the ph86 platform prior to the effective date of the change.

14.3 Your continued use of the ph86 platform following the effective date of a revised Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree to the revised Policy, you should cease using the platform and may request Account closure in accordance with the ph86 Terms and Conditions.

14.4 The current version of this Privacy Policy is always accessible at ph86.club/privacy-policy. Prior versions are available upon request from ph86 support.

15.1 For any privacy-related queries, requests to exercise your data subject rights, or concerns about ph86's handling of your personal data, please contact ph86 using the contact details available in the footer of the ph86.club website.

15.2 ph86 takes privacy complaints seriously. Upon receiving a written privacy complaint, ph86 will: (a) acknowledge receipt within three (3) business days; (b) investigate the complaint; and (c) provide a written response within fifteen (15) business days, including the outcome of the investigation and any corrective action taken.

15.3 If you are not satisfied with ph86's response to your privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). Information about how to file a complaint with the NPC is available on the NPC's official website. ph86 will cooperate fully with any NPC investigation.