ph334 Privacy Policy — Your Data, Your Rights, Our Commitment

1 About This Privacy Policy

1.1 This Privacy Policy ("Policy") describes how ph334 ("ph334," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal information of registered players, visitors, and users ("you" or "Player") of the ph334 platform located at ph334.club and its associated mobile applications and services (collectively, the "Platform").

1.2 ph334 is committed to protecting the privacy and security of your personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

1.3 This Policy should be read together with ph334's Terms & Conditions and any other supplementary policies published on the Platform. In the event of conflict, this Privacy Policy governs with respect to all data protection matters.

1.4 ph334 may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Section 14 of this Policy describes how we will notify you of material changes.

2 Data Controller Information

2.1 For the purposes of the Philippine Data Privacy Act and all applicable data protection legislation, ph334 is the Personal Information Controller (PIC) responsible for the personal data you provide to us through the Platform.

2.2 ph334 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and with applicable data protection laws. Contact information for the ph334 DPO is provided in Section 15 of this Policy.

2.3 Certain third-party service providers — including payment processors, game software providers, and identity verification services — act as Personal Information Processors (PIPs) on ph334's behalf. These parties process your data only according to ph334's documented instructions and are bound by data processing agreements that require them to maintain equivalent levels of data protection.

3 Personal Data We Collect

3.1 ph334 collects the following categories of personal data from Players:

3.2 ph334 does not collect or store full payment card numbers. Payment transactions are handled through certified third-party processors, and ph334 retains only tokenized or masked references sufficient to process refunds or match transactions to accounts.

3.3 ph334 does not intentionally collect sensitive personal information (as defined under RA 10173) beyond what is strictly required for the purposes described in this Policy. Where the collection of sensitive data is necessary — for example, national ID number for KYC — such data is afforded a higher level of protection and is subject to additional access controls.

4 How We Collect Your Data

ph334 collects personal data through the following means:

Direct Collection

4.1 You provide personal data directly to ph334 when you: register an account on the Platform; complete identity verification (KYC); make a deposit or withdrawal; contact ph334 customer support; respond to a survey or promotion; or submit a complaint or dispute.

Automated Collection

4.2 ph334's Platform automatically collects certain technical data when you access and use the service. This includes data collected through cookies, web beacons, server logs, device fingerprinting technology, and similar tracking tools. This automated data is primarily used for security, fraud prevention, and Platform performance optimization. See Section 8 for detailed information on our use of cookies.

Third-Party Sources

4.3 ph334 may receive personal data about you from third-party sources, including identity verification services, fraud prevention databases, payment processors, and publicly available sources, where permitted under applicable law. ph334 uses this data solely to supplement information already held on your account for the purposes of verification, fraud detection, and regulatory compliance.

5 How We Use Your Personal Data

5.1 ph334 uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and administering your ph334 player account;
• Service Delivery: Providing access to games, processing transactions, and delivering all Platform services;
• Identity Verification: Conducting KYC checks to verify your identity and age (21+) as required by Philippine law;
• Payment Processing: Processing GCash, Maya, bank transfer, and other deposits and withdrawals in Philippine Pesos (PHP);
• Regulatory Compliance: Meeting obligations under Philippine anti-money laundering laws (AMLA), PAGCOR requirements, the Data Privacy Act, and other applicable regulations;
• Security & Fraud Prevention: Detecting, investigating, and preventing fraud, unauthorized account access, and other prohibited activities;
• Responsible Gaming: Monitoring gaming patterns to identify potentially problematic behavior and providing responsible gaming tools;
• Customer Support: Responding to your inquiries, complaints, and disputes;
• Marketing (with consent): Sending promotional offers, bonus notifications, and Platform updates — only where you have consented and subject to your right to opt out at any time;
• Platform Improvement: Analyzing usage data in aggregate to improve the Platform's performance, design, and game offering.

5.2 ph334 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required for fraud prevention or regulatory compliance purposes.

6 Legal Basis for Processing

6.1 ph334 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Consent: For marketing communications and optional data processing activities where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contract Performance: Processing necessary to perform the ph334 Terms & Conditions contract with you — including account administration, payment processing, and game provision.
• Legal Obligation: Processing required to comply with Philippine law, including KYC verification under AMLA, age verification requirements, and regulatory reporting obligations.
• Legitimate Interests: Processing necessary for ph334's legitimate business interests, including fraud prevention, Platform security, and responsible gaming monitoring — provided such interests are not overridden by your privacy rights.

7 Data Sharing & Third Parties

7.1 ph334 does not sell your personal data to third parties. We share your personal data only in the circumstances described in this section.

7.2 Service Providers (Personal Information Processors)

ph334 shares personal data with third-party service providers that process data on our behalf, including: payment processors (GCash/Maya/bank integrations), identity verification and KYC service providers, game software providers (limited to data necessary for game operation and fairness certification), cloud hosting and infrastructure providers, and customer support platform providers. All such providers are bound by data processing agreements and are prohibited from using your data for any purpose other than the services they provide to ph334.

7.3 Regulatory and Legal Disclosures

7.4 ph334 may disclose your personal data to Philippine government agencies, regulatory bodies (including PAGCOR and the Anti-Money Laundering Council), law enforcement agencies, and courts where required to do so by applicable law, court order, or where we reasonably believe such disclosure is necessary to protect the rights, property, or safety of ph334, our Players, or the public.

8 Cookies & Tracking Technologies

8.1 ph334 uses cookies and similar tracking technologies on the Platform to enhance functionality, maintain session security, analyze traffic patterns, and support fraud detection. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled and include session management cookies, security tokens, and login authentication cookies.
• Functional Cookies: Remember your preferences such as language settings, game lobby layout, and notification preferences. Disabling these cookies may affect your Platform experience.
• Analytics Cookies: Used in aggregate, anonymized form to understand how Players use the Platform and to identify areas for improvement. ph334 uses analytics data only internally and does not share raw analytics data with third parties for their own use.
• Security & Fraud Detection Cookies: Support ph334's fraud detection and account security systems by tracking device and session patterns.

8.2 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent the ph334 Platform from functioning correctly. ph334 does not use third-party advertising cookies or cross-site tracking cookies.

9 Data Retention

9.1 ph334 retains your personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with applicable legal and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with Philippine AML record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of five (5) years from account closure or the date of the last transaction, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years as required under the Anti-Money Laundering Act.
• Customer Support Records: Retained for three (3) years from the date of last interaction.
• Technical and Log Data: Retained for a maximum of one (1) year unless required for longer by a specific security investigation or legal proceeding.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years to demonstrate compliance with consent requirements.

9.2 Upon expiry of the applicable retention period, ph334 will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless a longer retention period is required by law or a specific legal claim.

10 Data Security

10.1 ph334 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph334's servers;
• Encryption of sensitive data at rest, including identity documents and financial reference data;
• Multi-factor authentication requirements for access to systems containing personal data;
• Role-based access controls ensuring staff can access only the data necessary for their specific function;
• Regular security audits, vulnerability assessments, and penetration testing;
• Intrusion detection and real-time monitoring systems;
• Secure data centres with physical access controls.

10.2 While ph334 takes all reasonable measures to protect your data, no internet-based system is completely immune to security risks. ph334 cannot guarantee absolute security but will notify you and the National Privacy Commission promptly in the event of a data breach that poses a risk to your rights and freedoms, as required under the Data Privacy Act.

11 Your Rights Under the Data Privacy Act

11.1 As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph334:

11.2 To exercise any of the rights described in clause 11.1, please contact ph334's Data Protection Officer through the in-platform live chat or via the email address displayed in the footer of this page. ph334 will respond to all verified data subject requests within thirty (30) calendar days of receipt, in accordance with the requirements of the Data Privacy Act.

11.3 ph334 may request proof of identity before processing a data subject request to prevent unauthorized disclosure of personal data to third parties.

12 Children's Privacy

12.1 The ph334 Platform is strictly restricted to persons aged 21 years and above in accordance with PAGCOR requirements for online gaming in the Philippines. ph334 does not knowingly collect or process the personal data of any person under the age of 21.

12.2 If ph334 discovers that it has inadvertently collected personal data from a person under the age of 21, it will delete such data immediately and close the associated account. Any winnings accumulated by an underage account will be forfeited.

12.3 If you have reason to believe that a person under the age of 21 has registered with ph334, please contact our support team immediately so that appropriate action can be taken.

13 Cross-Border Data Transfers

13.1 Some of ph334's service providers — including game software providers and certain cloud infrastructure partners — may be located outside the Philippines. Where your personal data is transferred to recipients in other countries, ph334 ensures that appropriate safeguards are in place, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law.

13.2 ph334 does not transfer personal data to countries or territories identified by the National Privacy Commission as offering inadequate levels of data protection without implementing additional compensating safeguards.

14 Updates to This Privacy Policy

14.1 ph334 may update this Privacy Policy from time to time to reflect changes in applicable law, our business practices, or the technology we use. The "Effective Date" at the top of this Policy indicates when the current version took effect.

14.2 Where changes to this Policy are material — meaning they significantly affect your privacy rights or how ph334 processes your data — ph334 will notify you by email to your registered email address and through a prominent notice on the Platform at least fourteen (14) days before the updated Policy takes effect.

14.3 Your continued use of the ph334 Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated Policy, you should cease using the Platform and may request account closure in accordance with the Terms & Conditions.

15 Contact & Data Protection Officer

15.1 For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph334, please contact our Data Protection Officer. The ph334 DPO can be reached through the in-platform live chat available 24 hours a day, 7 days a week, by selecting "Privacy & Data" from the support topic options.

15.2 You may also contact the ph334 support team via the email address displayed in the footer of every page on ph334.club. When contacting us about a privacy matter, please mark your message clearly as a "Data Privacy Request" so that it can be directed to the DPO without delay.

15.3 If you are not satisfied with ph334's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for enforcing the Data Privacy Act. More information about filing a complaint with the NPC is available through the NPC's official government channels.