Privacy Policy — How ph73 Handles Your Personal Data

1. Introduction

ph73 ("ph73," "we," "us," or "our"), operator of the online gaming platform accessible at ph73.cam, respects the privacy of every person who accesses or uses our platform. This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of personal information submitted to or collected by ph73 in the course of providing our gaming services to players in the Philippines.

This Policy applies to all personal data processed in connection with your ph73 account, your use of any game or service available on the Platform, your communications with ph73 customer support, and your participation in any ph73 promotion or loyalty program.

By registering a ph73 account, using the Platform, or otherwise providing your personal information to ph73, 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 to this Policy, please do not create a ph73 account or use the Platform.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, ph73 acts as the personal information controller in respect of the personal data it processes about registered players and site visitors.

ph73 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection laws and this Policy. Contact details for ph73's DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

ph73 collects the following categories of personal data in connection with your use of the Platform:

ph73 does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, or biometric data, except where a government-issued biometric ID (such as a PhilSys card) is submitted as part of KYC verification — in which case only the document image and the data visible on its face are retained.

4. How Your Data Is Collected

ph73 collects personal data through the following means:

• Account Registration: When you create a ph73 account, you directly provide identity, contact, and account data.
• KYC Verification: When you submit documents for identity verification, ph73 collects copies of your government-issued ID and proof of payment method.
• Deposits and Withdrawals: Financial data is collected each time you conduct a payment transaction on ph73.
• Platform Usage: Technical and gaming data is collected automatically as you browse and play on ph73, through cookies, log files, and session tracking technologies.
• Customer Support Interactions: Any information you provide when contacting ph73 via live chat, email, or other support channels is collected and retained.
• Promotions and Surveys: If you opt into a ph73 promotion or respond to a player survey, the information you provide is collected as part of that activity.
• Third-Party Sources: ph73 may receive data from payment processors (e.g., GCash, PayMaya, BDO, BPI, Metrobank) to verify transaction status, and from fraud detection service providers to protect the integrity of the Platform.

5. Purposes of Processing

ph73 processes your personal data for the following purposes:

• To create, maintain, and administer your ph73 player account.
• To verify your identity and age (21+ requirement) as required by PAGCOR guidelines and applicable Philippine law.
• To process deposits, withdrawals, and all financial transactions conducted through your ph73 account.
• To deliver the gaming services, live casino features, sports betting, slots, bingo, and all other products available on ph73.
• To apply and track the conditions of any bonus or promotional offer claimed through your ph73 account.
• To detect, investigate, and prevent fraud, money laundering, cheating, collusion, and other prohibited activities.
• To comply with anti-money laundering (AML) obligations, PAGCOR reporting requirements, and other applicable legal and regulatory obligations.
• To provide customer support and respond to your inquiries, complaints, and feedback.
• To send you service-related communications, including account activity alerts, security notifications, and transaction confirmations.
• To send you promotional communications about ph73 bonuses, new games, and special offers — subject to your opt-in consent and any withdrawal of that consent.
• To improve the ph73 platform through analytics, user experience research, and technical performance monitoring.
• To enforce ph73's Terms & Conditions and this Privacy Policy.

6. Legal Basis for Processing

ph73 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing of identity, contact, account, financial, and gaming data is necessary to perform the contract between you and ph73 (i.e., to operate your account and deliver gaming services).
• Legal Obligation: Processing for KYC, AML compliance, age verification, and regulatory reporting is required by applicable Philippine laws and regulations.
• Legitimate Interests: Processing for fraud prevention, platform security, technical analytics, and responsible gaming monitoring is carried out on the basis of ph73's legitimate interests, balanced against your rights and freedoms.
• Consent: Processing for direct marketing communications is carried out only where you have provided explicit, freely given, specific, and informed consent. You may withdraw this consent at any time through your ph73 account settings or by contacting support.

7. Sharing Your Personal Data

ph73 does not sell your personal data. We may share your data with the following categories of recipients only where strictly necessary and with appropriate data protection safeguards in place:

• Payment Service Providers: GCash (Mynt), PayMaya (Voyager Innovations), BDO Unibank, BPI, and Metrobank receive transactional data necessary to process your deposits and withdrawals.
• Identity Verification Services: Third-party KYC and age verification providers may receive copies of identity documents to complete verification checks required by law.
• Fraud Prevention & AML Providers: Specialist service providers may receive technical and transactional data to assist ph73 in detecting and preventing fraud and money laundering.
• Game Software Providers: Licensed game studios that supply live casino, slot, and other game content to ph73 may receive the minimum player data necessary to deliver and authenticate game sessions.
• Regulatory Authorities: PAGCOR and other applicable Philippine regulatory or law enforcement bodies may receive data where ph73 is legally required to disclose it.
• IT & Infrastructure Providers: Cloud hosting and infrastructure service providers that power ph73's servers may have access to data as part of their service delivery, subject to strict contractual data processing agreements.
• Legal and Professional Advisors: ph73's legal counsel, auditors, and compliance advisors may access data as necessary to provide professional services, subject to professional confidentiality obligations.

All third-party service providers engaged by ph73 are required by contract to process personal data only on ph73's documented instructions and to maintain appropriate technical and organizational security measures.

8. Cookies & Tracking Technologies

ph73 uses cookies and similar tracking technologies (including local storage and session storage) to operate and improve the Platform. Cookies are small text files placed on your device when you access ph73.cam.

ph73 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your ph73 account. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limits display, and game lobby layout. These improve your experience on ph73 but are not essential.
• Performance & Analytics Cookies: Collect anonymized data about how players use the Platform — such as which pages are visited most frequently and where errors occur — to help ph73 improve its services.
• Security Cookies: Support fraud detection and account security by identifying unusual usage patterns relative to your normal ph73 session behavior.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from accessing your ph73 account. ph73 does not use third-party advertising or cross-site tracking cookies.

9. Data Retention

ph73 retains your personal data for as long as your account is active and for a defined period thereafter, depending on the category of data and the applicable legal or regulatory retention obligation:

• Account and Identity Data: Retained for the duration of your ph73 account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements under Republic Act No. 9160 (Anti-Money Laundering Act) as amended.
• Financial and Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, as required by AML regulations and tax record-keeping obligations.
• Gaming Session Data: Retained for three (3) years from the date of each session, for responsible gaming monitoring, dispute resolution, and regulatory reporting purposes.
• Support Communications: Retained for two (2) years from the date of each interaction, unless the communication relates to an ongoing dispute or regulatory investigation, in which case it is retained until the matter is resolved.
• Marketing Preferences: Retained for the duration of your consent and for six (6) months following withdrawal of consent, to demonstrate compliance with consent management obligations.
• Technical & Log Data: Retained for twelve (12) months on a rolling basis, except where required for an ongoing fraud investigation or security incident.

At the end of the applicable retention period, ph73 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

10. Data Security

ph73 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph73's servers.
• Encryption of sensitive data fields (including passwords, which are stored as salted cryptographic hashes and are never stored in plaintext) at rest.
• Role-based access controls limiting internal access to personal data to authorized ph73 staff with a demonstrated need to access it.
• Real-time intrusion detection and prevention systems monitoring ph73's infrastructure for unauthorized access attempts.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Two-factor authentication available to all ph73 players and required for all ph73 administrative staff accounts.

Despite these measures, no internet transmission or electronic storage system is completely secure. ph73 cannot guarantee absolute security of your data. You are responsible for keeping your ph73 login credentials confidential and notifying us immediately if you suspect unauthorized access to your account.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by ph73:

• Right to Be Informed: You have the right to be informed of the personal data ph73 holds about you, the purposes for which it is processed, and the parties with whom it is shared. This Policy is ph73's primary mechanism for fulfilling this right.
• Right of Access: You may request a copy of the personal data ph73 holds about you, along with information about how it is processed. Requests will be fulfilled within 30 days.
• Right to Rectification: If your personal data is inaccurate or incomplete, you have the right to request correction. You can update basic account information directly through your ph73 account settings, or contact support for assistance with information that cannot be self-edited.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where ph73 no longer has a lawful basis to retain it. Note that this right is subject to ph73's legal obligations to retain certain data (e.g., AML records), which may limit its application.
• Right to Data Portability: You may request a copy of the personal data you provided to ph73 in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time, without the need to provide justification. For other processing activities based on legitimate interests, you may object subject to ph73's assessment of competing grounds.
• Right to File a Complaint: If you believe ph73 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, contact ph73's Data Protection Officer at the details provided in Section 15. ph73 will respond to all data subject requests within thirty (30) days of receipt, and will communicate any extension of that period along with the reason for the delay.

12. Minors & Age Restriction

ph73's gaming services are strictly restricted to individuals who are at least 21 years of age, in accordance with PAGCOR's minimum age requirements for online gaming in the Philippines. ph73 does not knowingly collect personal data from individuals under the age of 21.

If ph73 becomes aware that it has inadvertently collected personal data from a person under the age of 21, that data will be deleted immediately and the associated account will be closed. Age verification is conducted as part of the KYC process, and ph73 reserves the right to request proof of age at any point during the account lifecycle.

If you are a parent or guardian and believe that a minor in your care has registered a ph73 account or provided personal information to ph73, please contact us immediately at [email protected] so that we can take appropriate action.

13. International Data Transfers

ph73 primarily stores and processes personal data on servers located within or serving the Philippine region. Where data is transferred to or accessed from service providers operating in other jurisdictions — such as international game content providers or cloud infrastructure providers with global data centers — ph73 ensures that such transfers are subject to appropriate contractual safeguards equivalent to the protections provided by Philippine data protection law.

ph73 does not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards, including standard contractual clauses or binding corporate rules where applicable.

14. Changes to This Privacy Policy

ph73 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable laws and regulations, or the services we offer. When we make material changes to this Policy, we will notify you by posting the updated Policy on this page with a revised "Last Updated" date, and where required by applicable law, by sending a notification to your registered email address.

We encourage you to review this Policy periodically. Your continued use of ph73 following the posting of an updated Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should cease using ph73 and may request account closure by contacting our support team.

15. Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or want to raise a concern about ph73's data processing practices, please contact ph73's Data Protection Officer:

If you are not satisfied with ph73's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Further information about your rights and the complaints process is also available on the ph73 FAQ page.