ph46 Casino — Privacy Policy

ph46 Casino operates the online gaming platform accessible at ph46.club. For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173), ph46 is the Personal Information Controller with respect to all personal data collected through the platform.

ph46 operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to PAGCOR's data protection requirements in addition to those imposed by the National Privacy Commission (NPC) under RA 10173.

This Privacy Policy applies to all users of ph46.club, including registered Players, prospective Players who browse the platform without registering, and any person who contacts ph46 customer support.

ph46 collects the following categories of personal data, as necessary for the purposes described in Section 4:

ph46 does not collect sensitive personal information as defined under RA 10173 (e.g., health data, political affiliations, religious beliefs) except where required by PAGCOR regulations for responsible gaming purposes (e.g., self-exclusion records).

ph46 collects personal data through the following channels:

• Direct collection: Information you provide when registering an account, completing KYC, making a deposit or withdrawal, contacting customer support, or responding to a survey.
• Automated collection: Technical data collected automatically when you access ph46.club, including through cookies, web beacons, and server logs (see Section 7).
• Payment processors: Confirmation data returned by GCash, Maya, BPI, BDO, Metrobank, and GrabPay when a transaction is processed. ph46 does not store full payment credentials — only the reference data necessary to reconcile transactions.
• Identity verification providers: Data returned from third-party KYC verification services used to validate government-issued identification documents.
• Regulatory sources: Data received from PAGCOR or law enforcement authorities pursuant to lawful regulatory processes, such as self-exclusion registry checks.

ph46 processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your ph46 account; verifying your identity and age; managing login credentials and 2FA.
• Service delivery: Processing deposits and withdrawals; recording game history; calculating and crediting bonuses and VIP points; settling sports bets.
• Legal and regulatory compliance: Conducting KYC in accordance with PAGCOR requirements; fulfilling anti-money laundering reporting obligations under RA 9160 (AMLA); maintaining records required by PAGCOR for audit purposes.
• Fraud prevention and security: Detecting and preventing unauthorized access, fraudulent transactions, bonus abuse, and other prohibited activities described in ph46's Terms & Conditions.
• Responsible gaming: Enforcing deposit limits, session limits, cooling-off periods, and self-exclusion restrictions; monitoring for signs of problem gambling behaviour in accordance with PAGCOR responsible gaming guidelines.
• Customer support: Responding to inquiries, resolving disputes, and maintaining records of support interactions for quality assurance.
• Platform improvement: Analysing aggregated, anonymised usage data to improve game performance, website usability, and overall Player experience.
• Marketing (where consented): Sending promotional offers, bonus notifications, and platform updates via email or mobile notification, where you have opted in. You may withdraw marketing consent at any time through your account notification settings.

Under the Data Privacy Act of 2012, ph46 processes personal data on the following lawful bases:

• Contractual necessity: Processing required to perform the Player Agreement (account registration, gameplay, payments, KYC).
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLA reporting obligations, and NPC requirements.
• Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your privacy rights.
• Consent: Marketing communications and optional data processing not strictly required by contract or law, which you may withdraw at any time without affecting your ability to use ph46.

ph46 does not sell, rent, or trade your personal data to third parties for commercial purposes. ph46 shares personal data only in the following circumstances:

• PAGCOR and regulatory authorities: As required by our license conditions and applicable Philippine law, ph46 reports specified player and transaction data to PAGCOR. ph46 also cooperates with the Anti-Money Laundering Council (AMLC), the National Bureau of Investigation (NBI), and other Philippine law enforcement bodies pursuant to valid legal orders.
• Payment processors: GCash, Maya, BPI, BDO, Metrobank, and GrabPay receive the minimum data required to process your deposit or withdrawal transaction.
• KYC verification providers: Identity document images and verification data are shared with certified third-party KYC providers for identity validation. These providers operate under data processing agreements with ph46 and are bound by equivalent data protection standards.
• Game software providers: Game providers whose titles appear on ph46 may receive session data required to deliver their games. No personally identifiable information beyond a pseudonymous player identifier is shared with game providers.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers who process data solely on ph46's instructions under binding data processing agreements.

All third-party processors engaged by ph46 are required by contract to maintain data security standards equivalent to those described in this Policy and to use personal data only for the purposes for which it was shared.

ph46 uses cookies and similar technologies on ph46.club for the following purposes:

• Essential cookies: Required for the platform to function, including maintaining your login session, storing your game preferences, and remembering responsible gaming settings. These cannot be disabled without impairing platform functionality.
• Analytics cookies: Aggregated, anonymised data about how Players navigate ph46.club, used to identify usability issues and improve the platform. Analytics data does not identify individual players.
• Security cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other security threats.

ph46 does not use third-party advertising cookies or tracking pixels that monitor your activity across other websites. You may manage cookie preferences through your browser settings; however, disabling essential cookies may prevent you from logging in to your ph46 account or using certain platform features.

ph46 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by applicable Philippine law and PAGCOR regulations:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR and AMLA.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Game history and session logs: Retained for a minimum of two (2) years from the date of the session, or longer if required for an ongoing dispute or regulatory investigation.
• Customer support records: Retained for three (3) years following closure of the relevant support case.
• Self-exclusion records: Retained for the duration of the exclusion period plus five (5) years thereafter, for PAGCOR compliance purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Anonymised data that cannot be re-identified may be retained indefinitely for statistical and analytical purposes.

ph46 implements technical and organisational security measures proportionate to the risk associated with processing player personal data, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and ph46 servers;
• Encryption at rest for stored personal data, including database encryption for identity and financial records;
• Access controls: Role-based access limiting staff access to personal data to those with a legitimate business need; multi-factor authentication for all staff with data access;
• Password hashing using bcrypt with appropriate salt rounds — ph46 does not store plaintext passwords;
• Intrusion detection and monitoring on all production systems;
• Regular security audits and penetration testing by independent security professionals;
• Incident response procedures designed to detect, contain, and notify affected users and the NPC of any data breach within the timeframes required by RA 10173.

While ph46 employs industry-standard security measures, no online platform can guarantee absolute security. Players are responsible for maintaining the security of their own login credentials and should report any suspected unauthorized access to ph46 support immediately.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph46:

• Right to Access: You may request a copy of the personal data ph46 holds about you, the purposes for which it is processed, and details of any third parties with whom it has been shared.
• Right to Correction: You may request correction of inaccurate or incomplete personal data. Some corrections (e.g., name or date of birth corrections on verified accounts) may require supporting documentation.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose collected, subject to ph46's retention obligations under PAGCOR and AMLA regulations.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. Objection to marketing processing takes effect immediately upon request.
• Right to Data Portability: You may request a copy of personal data you provided to ph46 in a structured, commonly used, machine-readable format.
• Right to File a Complaint: If you believe ph46 has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

Data subject rights requests may be submitted to ph46's Data Protection Officer at the contact details in Section 14. ph46 will respond within fifteen (15) business days of receiving a valid request, as required under RA 10173.

ph46 strictly prohibits the registration or use of its platform by any person under the age of twenty-one (21) years, in accordance with Philippine law and PAGCOR regulations. ph46 does not knowingly collect personal data from individuals under 21.

If ph46 becomes aware that an account has been registered by, or personal data has been collected from, a person under 21, ph46 will immediately close the account, void any associated transactions, and securely delete the personal data involved. Parents or guardians who believe a minor has accessed ph46 should contact our support team immediately.

ph46 employs age verification checks at registration and may request additional identity documentation at any time to confirm a player's eligibility.

ph46 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines (for example, certain cloud infrastructure or KYC providers), ph46 ensures that such transfers are subject to appropriate safeguards, including:

• Data processing agreements requiring the recipient to maintain data protection standards equivalent to or exceeding those required by RA 10173;
• Transfer only to jurisdictions recognised by the NPC as providing adequate data protection, or subject to binding contractual clauses;
• Minimum data transfer principles — only the specific data elements necessary for the third party's function are transferred.

ph46 does not transfer personal data to any jurisdiction for the primary purpose of circumventing Philippine data protection law.

ph46 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes to this Policy will be communicated to registered Players via their registered email address and/or through a prominent notice on the ph46 platform, with a minimum of seven (7) days' notice before the changes take effect.

The date of the most recent revision of this Policy is indicated at the top of the page. Players are encouraged to review this Policy periodically. Continued use of ph46 following the effective date of any update constitutes acceptance of the revised Policy.

ph46 has appointed a Data Protection Officer (DPO) as required under the Data Privacy Act of 2012. For all data privacy inquiries, data subject rights requests, and privacy complaints, please contact:

• Data Protection Officer — ph46 Casino
• Email: [email protected] (Subject line: "Data Privacy Request") — plain text, not a link
• Live Chat: Available 24/7 on ph46.club. Identify your inquiry as a data privacy matter for routing to the DPO team.
• Response time: ph46 commits to acknowledging all data privacy requests within two (2) business days and providing a substantive response within fifteen (15) business days.

If you are not satisfied with ph46's response to your privacy inquiry, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.