ph39 Privacy Policy

1. Introduction

ph39 is committed to protecting the privacy and personal data of all users of the ph39 platform. We understand that Filipino players trust us with sensitive personal and financial information, and we take that responsibility seriously. This Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

This Policy applies to all personal data collected through the ph39 website, mobile interface, customer support channels, and any other touchpoints through which you interact with ph39. It covers data collected from players based in the Philippines and from any other jurisdiction where ph39 operates.

By accessing or using the ph39 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the ph39 platform.

2. Data We Collect

ph39 collects the following categories of personal data from users:

Identity & Contact Data:

• Full legal name
• Date of birth (for age verification — ph39 requires players to be 21 years of age or older)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence) submitted during KYC verification

Financial Data:

• GCash account details, PayMaya account details, or bank account information (BPI, BDO, Metrobank, etc.) used for deposits and withdrawals
• Transaction history, including deposit amounts, withdrawal requests, and gaming activity records

Technical & Usage Data:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, features used, and session duration on the ph39 platform
• Login timestamps and access logs

Communications Data:

• Records of your communications with ph39 customer support, including live chat transcripts and email correspondence
• Survey responses and feedback submitted to ph39

3. How We Collect Data

ph39 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the ph39 platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification and fraud prevention data from authorised third-party KYC and AML service providers, and payment data from payment processors such as GCash and PayMaya.

4. How We Use Your Data

ph39 uses your personal data for the following purposes:

• To create and manage your ph39 account and verify your identity and age (21+ requirement).
• To process deposits, withdrawals, and other financial transactions on the platform.
• To comply with anti-money laundering (AML) obligations and Know Your Customer (KYC) requirements under Philippine law.
• To provide customer support and respond to your enquiries and complaints.
• To send you transactional communications, including account notifications, deposit confirmations, and withdrawal updates.
• To send you promotional communications about ph39 bonuses, offers, and new features — where you have consented to receive such communications.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited activities on the platform.
• To improve the ph39 platform, personalise your experience, and conduct internal analytics and research.
• To comply with applicable laws, regulations, and regulatory requirements, including PAGCOR compliance obligations.

5. Legal Basis for Processing

ph39 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary to perform the contract between you and ph39 — i.e., to operate your account and provide gaming services.
• Legal obligation: Where processing is required to comply with applicable laws and regulations, including AML, KYC, and PAGCOR compliance requirements.
• Legitimate interests: Where processing is necessary for ph39's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests.

6. Data Sharing

ph39 does not sell, rent, or trade your personal data to third parties for marketing purposes. We 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, solely to process your deposits and withdrawals.
• KYC and AML service providers: Authorised identity verification and fraud prevention partners engaged to assist ph39 in meeting its regulatory obligations.
• IT and platform service providers: Third-party technology vendors who host, maintain, and support the ph39 platform infrastructure, bound by strict confidentiality and data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and accountants engaged by ph39, subject to professional confidentiality obligations.

Any third party with whom ph39 shares personal data is required to handle that data in accordance with applicable Philippine data protection laws and ph39's data processing standards.

7. Cookies & Tracking Technologies

ph39 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the ph39 website. We use the following types of cookies:

• Essential cookies: Necessary for the platform to function correctly, including maintaining your login session and enabling secure transactions. These cannot be disabled.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the ph39 platform, helping us identify areas for improvement.
• Preference cookies: Used to remember your settings and preferences, such as language and display options, to personalise your experience.
• Marketing cookies: Used to deliver relevant promotional content about ph39 offers and features. These are only set where you have provided consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph39 platform.

8. Data Retention

ph39 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specifically:

• Account and identity data is retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and PAGCOR record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years as required under Philippine AML regulations.
• Customer support communications are retained for up to three (3) years from the date of the interaction.
• Technical and usage data collected via cookies and logs is retained for up to twelve (12) months.

Upon expiry of the applicable retention period, ph39 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph39:

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which this Policy fulfils.
• Right of access: The right to request a copy of the personal data ph39 holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data ph39 holds about you.
• Right to erasure: The right to request deletion of your personal data, subject to ph39's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph39 has not handled your personal data in accordance with applicable law.

To exercise any of the above rights, please contact the ph39 Data Privacy Officer using the contact details provided in Section 14 of this Policy. ph39 will respond to all verified requests within thirty (30) days.

10. Children's Privacy

The ph39 platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. ph39 does not knowingly collect personal data from individuals under the age of 21. If ph39 becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that a minor has provided personal data to ph39, please contact us immediately using the details in Section 14 so that we can take appropriate action.

11. Security

ph39 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph39 platform.
• Encrypted storage of sensitive personal and financial data at rest.
• Role-based access controls ensuring that only authorised ph39 personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits, vulnerability assessments, and penetration testing of the ph39 platform.
• Multi-factor authentication requirements for internal system access.
• Staff training on data protection and information security best practices.

While ph39 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. ph39 cannot guarantee absolute security, and you use the platform at your own risk. You are responsible for maintaining the confidentiality of your ph39 login credentials.

12. Third-Party Links

The ph39 platform may contain links to third-party websites or services for informational purposes. ph39 is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to the ph39 platform. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Policy

ph39 reserves the right to update or modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the revised Policy to the ph39 platform. Where changes are material, ph39 will endeavour to notify registered users via email or an in-platform notification prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the ph39 platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how ph39 protects your data.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by ph39, please contact our Data Privacy Officer:

Email: [email protected]

General Support: [email protected]

ph39 aims to acknowledge all privacy-related enquiries within 48 hours and to resolve them within 30 days. For complex requests, we may require additional time and will keep you informed of progress.

If you are not satisfied with ph39's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC).