ph47 Privacy Policy

This Privacy Policy ("Policy") describes how ph47 ("ph47," "we," "our," or "the Company") collects, uses, stores, shares, and protects the personal information of individuals ("you," "Data Subject," or "Player") who access the ph47 online gaming platform at https://ph47.vip (the "Platform") or who communicate with ph47 through any channel.

ph47 has served Filipino players since 2017 and takes its responsibilities as a personal information controller under Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), very seriously. We process your personal data lawfully, fairly, and transparently, and only for purposes that are legitimate, specific, and clearly defined.

By creating an account on ph47, accessing the Platform, or otherwise providing your personal information to ph47, you acknowledge that you have read this Privacy Policy and that you consent to the processing of your personal data as described herein. This Policy should be read alongside ph47's Terms & Conditions.

ph47 is the personal information controller responsible for your personal data collected through the ph47 Platform. ph47 operates under the PAGCOR regulatory framework and is registered in accordance with applicable Philippine law.

ph47 has designated a Data Privacy Officer (DPO) in accordance with the requirements of the DPA and its IRR. The DPO is responsible for ensuring ph47's compliance with applicable data privacy laws and serves as the primary point of contact for Data Subject requests and privacy-related inquiries. The DPO may be reached at:

ph47 collects personal information from you through several means, depending on how you interact with the Platform. The categories of personal information we collect are described below.

ph47 does not collect sensitive personal information (as defined by the DPA, including religious beliefs, health data, or sexual orientation) unless it is directly and necessarily relevant to regulatory compliance obligations — for example, information relating to self-exclusion requests made under ph47's Responsible Gaming program.

ph47 uses your personal information for the following purposes:

• Account Registration and Management: To create and maintain your ph47 player account, verify your identity, and manage your account settings and preferences.
• Identity Verification (KYC): To verify that you meet ph47's eligibility requirements, including the 21+ age requirement and Philippine residency requirement, in compliance with PAGCOR regulations and the Anti-Money Laundering Act (AMLA).
• Payment Processing: To process your deposits and withdrawals through GCash, PayMaya, banks, and other approved Philippine payment methods; to record and reconcile financial transactions; and to detect and prevent payment fraud.
• Game Operation: To operate and provide all gaming services on the Platform, record game results, and resolve gaming disputes using certified game logs.
• Regulatory Compliance: To comply with ph47's obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act (DPA), and other applicable Philippine laws, including mandatory reporting to the Anti-Money Laundering Council (AMLC).
• Customer Support: To respond to your inquiries, resolve complaints, and provide assistance through live chat, email, and other support channels.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling behavior, to administer self-exclusion, deposit limit, and session limit requests, and to fulfill ph47's PAGCOR responsible gaming obligations.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, account abuse, multi-accounting, and other prohibited behavior on the Platform.
• Platform Improvement: To analyze usage patterns and technical data in aggregate to improve Platform performance, game offerings, and user experience.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided consent or where ph47 has a legitimate interest in doing so, and subject to your right to opt out at any time.

Under the Data Privacy Act of 2012 and its IRR, ph47 processes your personal information on the following legal bases:

• Contractual Necessity: Processing necessary to perform the ph47 Terms & Conditions contract with you — including account creation, payment processing, and game operation.
• Legal Obligation: Processing required to comply with ph47's obligations under Philippine law, including PAGCOR regulations, AMLA reporting requirements, and DPA compliance obligations.
• Legitimate Interests: Processing necessary for ph47's legitimate business interests, including fraud prevention, Platform security, and aggregate analytics — provided these interests are not overridden by your rights and interests as a Data Subject.
• Consent: Processing carried out on the basis of your freely given, specific, informed consent — primarily for marketing communications. Consent-based processing can be withdrawn at any time without affecting the lawfulness of prior processing.

ph47 does not sell, rent, or trade your personal information to any third party. ph47 may share your personal data with third parties only in the following limited circumstances:

• Payment Service Providers: GCash (Mynt), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, UnionBank, and other approved payment processors, solely to facilitate your deposit and withdrawal transactions. These providers are bound by their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Services: Third-party KYC and identity verification providers engaged by ph47 to assist in validating government-issued Philippine identification documents. These providers operate under strict confidentiality agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law, court order, or regulatory direction.
• Gaming Technology Providers: Licensed game studios and platform technology providers who supply the games and systems that power the ph47 Platform. These providers have access only to the minimum data necessary to operate their services and are bound by data processing agreements.
• Fraud Prevention Services: Third-party fraud detection and security analytics providers engaged to help ph47 identify and prevent fraudulent activity on the Platform.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations, where disclosure is necessary for ph47 to obtain professional advice.

The ph47 Platform uses cookies and similar tracking technologies to operate certain essential Platform functions, to remember your preferences, and to analyze usage patterns. The types of cookies ph47 uses are described below:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and cookies that maintain your login state. These cookies cannot be disabled without preventing you from using core Platform features.
• Functional Cookies: Used to remember your preferences (such as language settings, game preferences, and responsible gaming settings) so you do not need to re-configure them each session.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform — which pages are most visited, how long sessions last, and where users encounter difficulties. This data is used to improve the Platform. ph47 uses analytics cookies only with your consent.
• Security Cookies: Used to detect and prevent fraudulent activity, identify bot traffic, and protect the integrity of the Platform and its users.

You may control non-essential cookies through your browser settings. Most browsers allow you to refuse cookies or to delete cookies already stored on your device. Please note that disabling cookies may affect certain Platform features and your gaming experience. ph47 does not use third-party advertising cookies or behavioral tracking cookies for the purpose of serving targeted advertisements on external websites.

ph47 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, and to comply with applicable Philippine legal and regulatory retention requirements. The general retention principles ph47 applies are as follows:

• Account and Identity Data: Retained for the duration of your active ph47 account, and for a minimum of five (5) years following permanent account closure, in compliance with PAGCOR record-keeping requirements and Philippine anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years following each transaction, as required by PAGCOR regulations and the AMLA Implementing Rules and Regulations.
• Gaming Records: Game logs, betting history, and win/loss records are retained for a minimum of three (3) years to support dispute resolution and regulatory audits.
• KYC Documents: Identity verification documents (government ID images, selfie verification) are retained for the duration of the account relationship and for a minimum of five (5) years following account closure.
• Customer Support Communications: Live chat transcripts and email correspondence are retained for a minimum of two (2) years to support complaint resolution and service improvement.
• Marketing Data: Marketing preference records and consent records are retained for as long as the account is active and for a reasonable period thereafter, or until a withdrawal of consent is exercised.

When personal data is no longer required for its stated purpose and no legal retention obligation applies, ph47 will securely delete or irreversibly anonymize that data in accordance with the NPC's guidelines on personal data disposal.

ph47 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and ph47's servers.
• AES-256 encryption for sensitive data fields (including financial data) stored in ph47's databases.
• Role-based access control (RBAC) ensuring that ph47 employees can access only the categories of player data required for their specific job function.
• Multi-factor authentication required for all ph47 internal systems that store or process personal data.
• Regular penetration testing and security audits conducted by independent third-party security firms.
• 24/7 security monitoring with automated anomaly detection and incident response protocols.
• Segregated storage of personal data and financial data in separate, independently access-controlled systems.
• Regular data backup procedures with encrypted offsite storage.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by ph47:

• Right to Information: The right to be informed of how your personal data is being or will be processed by ph47, including the purposes, legal bases, and retention periods applicable to your data.
• Right of Access: The right to obtain a copy of your personal data held by ph47, along with information about how it is being processed.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or completed without undue delay.
• Right to Erasure ("Right to be Forgotten"): The right to request the deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where the processing is unlawful — subject to ph47's legal retention obligations under PAGCOR and AMLA regulations, which may require ph47 to retain certain data notwithstanding such a request.
• Right to Object: The right to object to the processing of your personal data on grounds of legitimate interest, including processing for direct marketing purposes. ph47 will cease direct marketing processing immediately upon receipt of a valid objection.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to File a Complaint: The right to file a complaint with the National Privacy Commission (NPC) at https://www.privacy.gov.ph if you believe ph47 has processed your personal data in violation of the DPA.

To exercise any of the above rights, please contact ph47's Data Privacy Officer via live chat on the Platform or by email at [email protected]. ph47 will respond to all Data Subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

With your consent, ph47 may send you promotional communications by SMS, email, or push notification, including information about bonuses, new games, platform updates, and special events. ph47 will not send marketing communications if you have not provided consent, or after you have withdrawn consent.

You may withdraw your consent to marketing communications at any time by:

• Updating your notification preferences in Account Settings → Marketing Preferences on the ph47 Platform.
• Clicking the "Unsubscribe" link included in any ph47 email marketing communication.
• Contacting ph47 customer support via live chat or at [email protected] and requesting removal from all marketing lists.

Withdrawal of consent to marketing communications will be processed within five (5) business days. Withdrawal of marketing consent will not affect your ability to use the ph47 Platform or receive transactional communications necessary for your account (such as deposit confirmations, withdrawal notifications, and security alerts).

ph47 uses identity verification and age verification procedures to prevent minors from accessing the Platform. If you are a parent or guardian and you believe that your child under 21 has registered on ph47 or provided personal data to ph47, please contact us immediately via live chat or at [email protected], and we will take prompt action.

ph47 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made to this Policy, ph47 will notify registered players via email to their registered address and/or via a prominent notice on the ph47 Platform, at least seven (7) days before the amended Policy takes effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent amendment. Minor clarifications or updates that do not materially change Data Subjects' rights or ph47's processing practices may be made without advance notice. Your continued use of the ph47 Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

ph47 encourages you to review this Privacy Policy periodically so that you remain informed about how we protect your personal information.

If you have questions about this Privacy Policy, wish to exercise your Data Subject rights, or have a concern about how ph47 has processed your personal information, please contact ph47's Data Privacy Officer through the following channels:

• Live Chat: Available 24/7 directly on the ph47 Platform — for urgent privacy-related matters, this is the fastest channel.
• Email: [email protected] — for formal Data Subject requests, complaints, and written correspondence. Please include "Privacy Request" or "Data Subject Rights" in the subject line so your message is routed to the DPO team promptly.

ph47 is committed to resolving all privacy-related complaints fairly and promptly. If you are not satisfied with ph47's response to your privacy complaint, you have the right to escalate the matter to the National Privacy Commission (NPC), the independent Philippine government authority responsible for enforcing the Data Privacy Act. Information on filing a complaint with the NPC is available at the NPC's official website.