ph654 Privacy Policy

1 Who We Are

ph654 (referred to in this Privacy Policy as "ph654," "we," "us," or "our") is the operator of the online gambling platform accessible at ph654.club. ph654 acts as a Personal Information Controller within the meaning of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) with respect to the personal data of individuals who register on and use the ph654 platform.

ph654 operates under PAGCOR regulatory oversight and is registered with the National Privacy Commission (NPC) of the Philippines as required under the Data Privacy Act and its Implementing Rules and Regulations.

For all data privacy matters, including the exercise of your rights under the Data Privacy Act, please contact our Data Protection Officer using the details provided in Section 13 of this Policy.

2 Personal Data We Collect

ph654 collects personal data at various points during your use of the platform. The categories of data we collect are described below:

2.1 Registration Data

When you create a ph654 Account, we collect:

• Full legal name as it appears on your government-issued ID;
• Date of birth for age verification (21+ requirement);
• Philippine residential address;
• Mobile number (Philippine format: +63 9XX XXX XXXX);
• Email address;
• Username and hashed password.

2.2 Identity Verification (KYC) Data

To comply with PAGCOR licensing requirements and the Philippine Anti-Money Laundering Act (Republic Act No. 9160, as amended), ph654 may request:

• Government-issued photo identification (passport, PhilSys ID, driver's licence, SSS/GSIS ID);
• Proof of address (utility bill, bank statement issued within 90 days);
• Selfie photograph for liveness verification;
• Source of funds documentation for withdrawals above prescribed thresholds.

2.3 Financial Data

ph654 collects financial information necessary to process deposits and withdrawals, including:

• GCash or Maya mobile wallet reference numbers;
• Bank account details (bank name, account name — not full account numbers) for bank transfer withdrawals;
• Transaction history including deposit and withdrawal amounts, dates, and payment methods used.

ph654 does not store full credit or debit card numbers. Payment card data, where applicable, is processed exclusively by PCI-DSS certified payment gateways.

2.4 Gameplay & Betting Data

• Game session records including games played, bets placed, outcomes, and session duration;
• Sports betting slip history and settlement records;
• Bonus eligibility status and wagering progress;
• VIP tier and loyalty point balance.

2.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Session login and logout timestamps;
• Platform interaction logs for fraud detection and responsible gaming monitoring;
• Cookie identifiers and similar tracking data (see Section 6).

2.6 Communications Data

• Live chat transcripts between you and ph654 support agents;
• Email correspondence with ph654;
• Responses to surveys, promotions, or feedback requests.

3 How We Use Your Personal Data

ph654 uses your personal data for the following purposes:

4 Legal Bases for Processing

ph654 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing required to perform the contract between you and ph654 — including Account registration, payment processing, and game access.
• Legal Obligation: Processing required to comply with Philippine law — including PAGCOR licensing requirements, AMLA obligations, and NPC registration duties.
• Legitimate Interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where our legitimate interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 Data Sharing & Third-Party Disclosure

5.1 Service Providers

ph654 shares personal data with trusted third-party service providers who process data on our behalf under written data processing agreements that prohibit onward transfer and require appropriate security measures. These include:

• Payment processors: GCash (G-Xchange Inc.), Maya (Paymaya Philippines Inc.), BPI, BDO, and other payment gateway partners for deposit and withdrawal processing;
• KYC verification providers: Third-party identity verification services for document and liveness checks;
• Cloud infrastructure providers: Hosting and database services operating under strict data processing agreements;
• Analytics providers: Anonymised, aggregated platform usage analytics only — no individually identifiable data.

5.2 Regulatory Authorities

ph654 is legally obligated to disclose personal data to Philippine regulatory authorities where required, including:

• PAGCOR — for licence compliance audits and player complaint investigations;
• Anti-Money Laundering Council (AMLC) — for suspicious transaction reporting under the AMLA;
• National Privacy Commission (NPC) — for data breach notifications and privacy investigations;
• Philippine law enforcement agencies — where we receive a valid court order or lawful request.

5.3 No Data Sales

6 Cookies & Tracking Technologies

ph654 uses cookies and similar technologies on ph654.club. The table below describes the categories in use:

ph654 does not use third-party advertising or retargeting cookies. You may manage or delete cookies through your browser settings at any time; however, disabling essential cookies will prevent the ph654 platform from functioning correctly.

7 Data Retention

ph654 retains personal data only for as long as is necessary for the purpose for which it was collected or as required by applicable Philippine law. The following retention periods apply:

• Account and registration data: Retained for the duration of your Account and for 5 years following permanent Account closure, as required by AMLA record-keeping obligations;
• KYC documents: Retained for a minimum of 5 years from the date of verification, as required by PAGCOR and AMLA;
• Transaction records: Retained for a minimum of 5 years from the transaction date;
• Gameplay and betting logs: Retained for 2 years for responsible gaming monitoring and dispute resolution purposes;
• Support communication records: Retained for 3 years from the date of the last interaction;
• Marketing consent records: Retained for the period of consent plus 3 years to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted, destroyed, or anonymised in accordance with ph654's data deletion procedures.

8 Security Measures

ph654 implements comprehensive technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure:

• Encryption at rest: AES-256 encryption for all personal data stored in ph654 databases;
• Encryption in transit: TLS 1.3 for all data transmitted between your device and ph654 servers;
• Access controls: Role-based access control (RBAC) ensuring ph654 staff can only access data necessary for their specific role;
• Multi-factor authentication: MFA required for all ph654 internal system access;
• Penetration testing: Regular third-party security assessments and vulnerability testing;
• Data breach response: ph654 maintains a documented Data Breach Response Procedure. In the event of a personal data breach likely to result in risk to your rights and freedoms, ph654 will notify the NPC within 72 hours and affected individuals without undue delay as required by the Data Privacy Act.

9 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you hold the following rights with respect to your personal data processed by ph654:

• Right to Be Informed: You have the right to be informed that your personal data is being processed, and of the details of such processing — which this Privacy Policy fulfils;
• Right of Access: You may request a copy of the personal data ph654 holds about you, the purposes for which it is processed, and details of any third parties to whom it has been disclosed;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ph654's legal obligations to retain records under AMLA and PAGCOR requirements;
• Right to Restrict Processing: You may request that ph654 restrict the processing of your data in certain circumstances;
• Right to Data Portability: Where processing is based on your consent or a contract, you may request a machine-readable copy of your personal data;
• Right to Object: You may object to the processing of your personal data for marketing purposes or where processing is based on legitimate interest, subject to ph654's overriding legitimate grounds;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing;
• Right to Lodge a Complaint: If you believe ph654 has violated your privacy rights, you may file a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, contact our Data Protection Officer using the details in Section 13. ph654 will respond to all data subject rights requests within 15 business days of receipt. We may request proof of identity before processing your request.

10 Children's Privacy

The ph654 platform is strictly for individuals aged 21 years and older in accordance with Philippine gambling law and PAGCOR regulations. ph654 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under the minimum age, we will immediately close the relevant Account, delete all associated personal data, and report the matter to PAGCOR as required.

If you are a parent or guardian and believe that a person under 21 has created a ph654 Account using your or their personal information, please contact our Data Protection Officer immediately using the contact details in Section 13.

11 Cross-Border Data Transfers

The majority of ph654's personal data processing takes place within the Philippines. Where ph654 engages service providers that may process data outside the Philippines — such as cloud infrastructure providers or international KYC verification services — we ensure that such transfers are subject to appropriate safeguards consistent with the Philippine Data Privacy Act, including:

• Data processing agreements incorporating standard contractual clauses;
• Transfer to jurisdictions with substantially similar data protection standards;
• Your explicit consent where required under applicable NPC guidance.

ph654 does not transfer personal data to jurisdictions that lack adequate data protection frameworks without implementing the contractual and technical safeguards required by Philippine law.

12 Amendments to This Privacy Policy

ph654 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or business operations. Material changes — particularly those that affect your rights or the categories of data we collect — will be communicated to registered players via the mobile number or email address on file at least 14 days before the amended Policy takes effect.

The current version number and effective date of this Privacy Policy are displayed at the top of this page. Continued use of the ph654 platform after the effective date of any amendment constitutes your acknowledgement of the updated Policy. We recommend reviewing this Policy periodically.

13 Contact & Data Protection Officer

For all privacy-related enquiries, requests to exercise your Data Privacy Act rights, or to report a data protection concern, please contact the ph654 Data Protection Officer:

• Live Chat: Available 24/7 at ph654.club — select "Privacy / Data Request" from the support menu. Response time: under 2 minutes.
• Email: [email protected] — subject line: "Data Privacy Request"

ph654 will acknowledge all data privacy requests within 3 business days and resolve them within 15 business days, or within the timeframe required by law where applicable.

If you are dissatisfied with ph654's response to a data privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC) in accordance with the Data Privacy Act and NPC rules of procedure.