ph635 Privacy Policy —
How We Collect, Use & Protect Your Data

Introduction & Scope

This Privacy Policy ("Policy") is issued by ph635, the operator of the online gaming platform accessible at https://ph635.cam ("Platform"). It describes how ph635 collects, uses, stores, shares, and protects personal data belonging to users ("Players," "you," or "your") who access or use the Platform, including through any associated mobile applications or communication channels.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission ("NPC") of the Philippines. It is also consistent with PAGCOR's data governance requirements applicable to PAGCOR-licensed online gaming operators.

By accessing or using the ph635 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy is incorporated by reference into ph635's Terms & Conditions and forms part of the binding agreement between you and ph635.

Data Controller Information

The personal data controller responsible for your data under this Policy is:

• Platform Name: ph635
• Website: https://ph635.cam
• Registered Jurisdiction: Republic of the Philippines
• Regulatory Authority: Philippine Amusement and Gaming Corporation (PAGCOR)
• PAGCOR License: PAGCOR-EGLF-2024-0635
• Data Protection Officer (DPO) Contact: [email protected] (plain text — not clickable)

ph635 has designated a Data Protection Officer (DPO) in accordance with Section 21 of the DPA and NPC Circular No. 16-01. The DPO is responsible for ensuring ph635's compliance with the DPA, this Policy, and all NPC issuances. Players may contact the DPO directly for any data privacy-related concern, complaint, or request to exercise a data subject right.

Personal Data We Collect

ph635 collects the following categories of personal data in the course of operating the Platform and fulfilling our legal obligations as a PAGCOR-licensed operator:

3.1 Identity and Registration Data

• Full legal name as appearing on your government-issued Philippine identification
• Date of birth (used to verify the mandatory 21+ age requirement)
• Gender (optional, collected for responsible gaming profiling purposes)
• Philippine mobile number and/or email address
• Username and encrypted account password

3.2 Identity Verification (KYC) Data

• Scanned or photographed copies of government-issued Philippine ID documents
• Selfie or live photo for biometric identity matching (where required by PAGCOR KYC standards)
• Proof of address documentation (utility bill, bank statement, or equivalent)
• Source of funds documentation (for high-value accounts as required by AMLC regulations)

3.3 Financial Transaction Data

• GCash or PayMaya account references (mobile number only — ph635 does not store full wallet credentials)
• Bank account details for BPI, BDO, and Metrobank transfers (account name and number only)
• Deposit and withdrawal transaction history including amounts, timestamps, and payment method used
• Bonus and promotional transaction records

3.4 Gaming Activity Data

• Game session logs including game title, session duration, bet amounts, and outcomes
• Sports betting selections and outcomes
• Responsible gaming tool usage and self-imposed limit settings
• Bonus and promotion eligibility and redemption records

3.5 Technical and Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Session timestamps and login history
• Platform interaction logs and error reports

3.6 Communications Data

• Customer support chat transcripts and email correspondence
• Records of any formal complaints or dispute submissions
• Marketing preference settings and communication opt-in/opt-out records

How We Collect Your Data

ph635 collects personal data through the following channels and mechanisms:

• Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, contact customer support, or interact with any feature of the Platform.
• Automatically: Through server logs, cookies, and session tracking technologies when you access the Platform. This includes IP address capture, device fingerprinting for security purposes, and session activity logging.
• From payment service providers: ph635 receives transaction confirmation data from GCash, PayMaya, and partner banks following payment processing. ph635 does not receive or store full payment credentials — only transaction reference data.
• From identity verification services: For enhanced KYC, ph635 may use PAGCOR-accredited identity verification platforms that cross-reference your submitted documents against Philippine government records.
• From PAGCOR's regulatory systems: ph635 may receive information from PAGCOR's Exclusion Registry, Suspicious Transaction Reporting system, and other regulatory databases as required for compliance purposes.

Legal Basis for Processing

ph635 processes your personal data on the following legal bases as provided under the Data Privacy Act of 2012:

• Contractual Necessity (Section 12(b), DPA): Processing necessary to fulfill ph635's obligations under the account agreement, including account management, game delivery, payment processing, and customer support.
• Legal Obligation (Section 12(c), DPA): Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (R.A. 9160), the Data Privacy Act itself, and all other applicable Philippine laws.
• Legitimate Interest (Section 12(f), DPA): Processing for fraud prevention, security monitoring, platform integrity, responsible gaming monitoring, and service improvement, where such interests do not override your rights and freedoms.
• Consent (Section 12(a), DPA): For optional processing activities such as marketing communications and analytics profiling, where you have provided explicit and informed consent that can be withdrawn at any time.

How We Use Your Data

ph635 uses your personal data for the following specific purposes:

6.1 Account Operations

To create, maintain, verify, and manage your ph635 account; to authenticate your identity on each login; to communicate with you regarding account activity, security alerts, and platform updates.

6.2 Regulatory Compliance

To fulfill all PAGCOR licensing obligations including KYC verification, age verification, player activity reporting, and Exclusion Registry checks; to comply with AMLC transaction monitoring and suspicious transaction reporting obligations under R.A. 9160; and to respond to lawful requests from PAGCOR, the NPC, or other competent Philippine regulatory authorities.

6.3 Payment Processing

To process deposits and withdrawals through your registered Philippine payment methods; to verify ownership of payment accounts as required by PAGCOR's AML compliance framework; and to maintain accurate financial records as required by Philippine accounting and gaming regulations.

6.4 Responsible Gaming

To monitor gaming activity for indicators of problem gambling behavior; to administer the deposit limits, session alerts, cooling-off periods, and self-exclusion tools you configure; to fulfill mandatory PAGCOR responsible gaming monitoring and reporting requirements.

6.5 Security and Fraud Prevention

To detect, investigate, and prevent unauthorized access, fraud, cheating, collusion, and other prohibited conduct; to maintain platform security and integrity; to identify and address technical vulnerabilities or suspicious patterns in account activity.

6.6 Marketing Communications (Consent-Based Only)

With your explicit consent, to send you promotional offers, bonus notifications, and ph635 service updates via your registered mobile number or email address. You may withdraw consent for marketing communications at any time through your account settings or by contacting support.

Data Sharing & Disclosure

ph635 does not sell, rent, or trade your personal data to any third party for commercial purposes. ph635 shares personal data only in the following limited and controlled circumstances:

• PAGCOR and Regulatory Authorities: As required by ph635's PAGCOR license, we share player identity, activity, and transaction data with PAGCOR and other competent Philippine regulatory authorities as directed by law or regulatory mandate.
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports and covered transaction reports are filed with the AMLC as required under R.A. 9160 and PAGCOR's AML compliance framework.
• Payment Service Providers: Transaction-specific data is shared with GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard solely for the purpose of processing your specific deposit or withdrawal transaction.
• Identity Verification Providers: KYC document data is shared with PAGCOR-accredited identity verification services solely for the purpose of verifying your identity and age as required by PAGCOR regulations.
• Technology Infrastructure Providers: Cloud hosting, platform software, and security service providers who process data on ph635's behalf under binding data processing agreements that comply with DPA requirements.
• Law Enforcement: Personal data may be disclosed to Philippine law enforcement agencies upon receipt of a lawful, duly issued subpoena, court order, or written directive from a competent authority.

Cookies & Tracking Technologies

ph635 uses cookies and similar tracking technologies to operate and secure the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for Platform functionality, including session authentication, security tokens, and load balancing. These cannot be disabled without breaking Platform functionality.
• Security Cookies: Used for fraud detection, bot prevention, and anomalous activity monitoring. These are a security requirement for a PAGCOR-licensed gaming platform and cannot be disabled.
• Performance and Analytics Cookies: Used to analyze Platform usage patterns and improve service quality. These are activated only with your consent and can be disabled through your browser settings or the ph635 cookie preference center.
• Marketing Cookies: Used to deliver relevant promotional content within the Platform. Activated only with your explicit consent and can be withdrawn at any time.

You may manage your cookie preferences through your browser settings. Disabling strictly necessary or security cookies will impair your ability to access and use the Platform securely.

Data Retention

ph635 retains your personal data for the periods specified below, after which data is securely deleted or anonymized in accordance with NPC-approved data disposal procedures:

Data Security

ph635 implements the following technical and organizational security measures to protect your personal data against unauthorized access, loss, alteration, and disclosure:

• 256-bit TLS/SSL encryption for all data in transit between your device and ph635 servers
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records
• Multi-factor authentication options for player accounts and mandatory MFA for all ph635 administrative access
• Strict role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity professionals
• Automated intrusion detection and real-time security monitoring
• Physical security controls for all data center facilities
• Regular staff training on data privacy obligations and security best practices

In the event of a personal data breach that is likely to result in a real risk to your rights and freedoms, ph635 will notify the NPC within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects as soon as practicable, in compliance with Section 20(f) of the DPA and NPC Circular No. 16-03.

Your Rights Under the Data Privacy Act

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 ph635. To exercise any of these rights, submit a written request to [email protected] or through the live chat support channel.

Children & Minors

The ph635 Platform is strictly restricted to individuals who are at least twenty-one (21) years of age, in compliance with Philippine gaming law as administered by PAGCOR. ph635 does not knowingly collect personal data from any person under the age of 21.

Every ph635 account is subject to mandatory KYC age verification using government-issued Philippine identification. Any account found to belong to a person under the age of 21 will be immediately and permanently suspended, with the matter reported to PAGCOR as required by law. All data associated with a confirmed underage account will be handled in accordance with PAGCOR's underage account protocols, which may include mandatory retention for regulatory reporting purposes.

If you have reason to believe that a person under the age of 21 has accessed ph635, please contact our support team immediately at [email protected].

Cross-Border Data Transfers

ph635 primarily processes and stores personal data within the Republic of the Philippines using Philippine-based or Philippine-compliant data infrastructure. Where the use of technology service providers necessitates transfer of personal data outside the Philippines (for example, to cloud infrastructure providers with servers in other jurisdictions), ph635 ensures that such transfers comply with Section 21 of the DPA and NPC Circular No. 16-01, specifically:

• The receiving party provides a level of data protection at least equivalent to the DPA's standards;
• Binding contractual obligations consistent with DPA requirements are in place; and
• PAGCOR's requirements regarding data sovereignty and player data security are observed.

ph635 does not transfer your personal data to any jurisdiction for the purpose of circumventing Philippine privacy law or reducing the protections afforded to you under the DPA.

Changes to This Policy

ph635 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or PAGCOR regulatory requirements. Material changes to this Policy will be communicated to registered players via notification to their registered mobile number or email address at least fourteen (14) days before the revised Policy takes effect, unless a shorter notice period is required by law or NPC directive.

The current version of this Policy is always accessible at https://ph635.cam/privacy-policy. The "Last Revised" date at the top of this document reflects the date of the most recent update. Continued use of the ph635 Platform after the effective date of a revised Policy constitutes your acceptance of the revised terms.

Where a proposed change materially reduces your rights or significantly expands the scope of data processing, ph635 will seek fresh consent from affected players before the change takes effect, as required by the DPA.

Contact & DPO Details

For any question, concern, or request relating to this Privacy Policy or your personal data rights under the DPA, contact ph635 through the following channels:

• Data Protection Officer (DPO): [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 through the ph635 Platform
• Registered Address: Metro Manila, Republic of the Philippines

ph635 will acknowledge all DPA-related requests within three (3) business days and will respond substantively within fifteen (15) business days, or within such other period as may be required by applicable NPC rules.

If you are not satisfied with ph635's response to a data privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines. The NPC's complaint procedures are available through official Philippine government channels.