ph52 Privacy Policy

ph52 (referred to herein as "ph52," "we," "us," or "our") is the data controller responsible for personal data collected through ph52.app and all associated services. ph52 operates as a PAGCOR-licensed online gaming platform under Philippine law. As data controller, ph52 determines the purposes and means of processing your personal data and is accountable for its lawful, fair, and transparent handling in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations.

ph52 has designated a Data Protection Officer ("DPO") as required by the National Privacy Commission ("NPC"). The ph52 DPO may be contacted via the ph52 support channel available at ph52.app. All data privacy enquiries and complaints should reference "Data Privacy" in the subject line for prompt routing to the DPO.

ph52 collects the following categories of personal data:

ph52 does not collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) except where expressly required by law or with your explicit consent.

ph52 collects your personal data through the following means:

• Direct collection: Data you provide when registering a ph52 account, completing KYC verification, making deposits or withdrawals, setting responsible gaming limits, contacting customer support, or participating in ph52 promotions.
• Automated collection: Technical data collected automatically when you access ph52.app, including via cookies, log files, and session tracking technologies described in Section 9 of this Policy.
• Third-party sources: Identity verification data from PAGCOR-accredited KYC service providers; payment verification data from e-wallet operators (GCash, Maya) and banking partners in connection with deposit and withdrawal processing; fraud screening data from authorised third-party security providers.

ph52 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to enter into or perform the contract between you and ph52 (i.e., your ph52 Account Agreement), including account creation, deposit processing, game provision, and withdrawal fulfilment.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) obligations, National Privacy Commission requirements, and other applicable Philippine law.
• Legitimate interests: Processing necessary for ph52's legitimate interests in fraud prevention, security monitoring, responsible gaming enforcement, and platform improvement, where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where ph52 has obtained your prior consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

ph52 uses your personal data for the following purposes:

• Creating, managing, and maintaining your ph52 account
• Verifying your identity and age (21+) as required by PAGCOR
• Processing deposits and withdrawals via GCash, Maya, and other accepted payment methods
• Providing, personalising, and improving ph52 gaming services (slots, live casino, sports betting, sabong, bingo)
• Detecting, investigating, and preventing fraud, money laundering, and other prohibited conduct
• Enforcing responsible gaming tools including deposit limits, self-exclusion, and session timers
• Providing customer support and resolving disputes
• Complying with PAGCOR reporting obligations and other legal requirements
• Sending account-related notifications (OTPs, transaction confirmations, security alerts)
• Sending promotional communications where you have opted in
• Conducting internal analytics to improve ph52 platform performance and user experience

ph52 does not sell, rent, or commercially trade your personal data. ph52 may share your personal data with the following categories of recipients:

• PAGCOR and Philippine regulators: As required by ph52's gaming licence, AMLA obligations, and applicable Philippine law, including mandatory reporting of suspicious transactions to the Anti-Money Laundering Council (AMLC).
• Payment processors: GCash (Mynt), Maya (Paymaya Philippines), BPI, BDO, Metrobank, and other payment service providers solely for the purpose of processing your transactions.
• KYC and identity verification providers: PAGCOR-accredited third-party providers engaged to verify your identity documents and conduct age verification.
• Game software providers: Licensed game providers (e.g., Pragmatic Play, PG Soft, Vivo Gaming) may receive limited technical data (session tokens, bet data) solely to operate their games within ph52.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud prevention vendors engaged by ph52 under strict data processing agreements consistent with DPA requirements.
• Law enforcement and courts: Where required by valid legal process, court order, or law enforcement request under Philippine law.

All third-party service providers engaged by ph52 are contractually bound to process personal data only as instructed by ph52 and in compliance with applicable data protection law.

Some ph52 service providers and game software licensors may be located outside the Philippines. Where ph52 transfers personal data outside the Philippines, ph52 ensures that such transfers are subject to appropriate safeguards consistent with the DPA and NPC guidelines, including standard contractual clauses, data processing agreements, or transfers to jurisdictions with adequate data protection laws as recognised by the NPC. ph52 will not transfer your personal data internationally without ensuring an equivalent level of protection is in place.

ph52 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of your ph52 account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• KYC and identity documents: Retained for a minimum of five (5) years after account closure or the last transaction, whichever is later, per AMLA obligations.
• Transaction records: Retained for a minimum of five (5) years as required by AMLA and PAGCOR regulations.
• Technical and log data: Retained for up to twelve (12) months for security and fraud detection purposes.
• Marketing consent records: Retained until consent is withdrawn plus a reasonable administrative period.

Upon expiry of applicable retention periods, ph52 will securely delete or anonymise personal data in accordance with NPC-approved destruction standards.

ph52.app uses cookies and similar tracking technologies to operate the platform and improve your experience. The following types of cookies are used:

• Strictly necessary cookies: Essential for ph52 to function, including authentication session management, security tokens, and fraud prevention signals. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game history, and responsible gaming limits. Disabling these may affect platform functionality.
• Analytics cookies: Used internally by ph52 to understand how players interact with ph52.app and to identify areas for improvement. ph52 uses privacy-respecting analytics tools and does not share raw analytics data with third parties for advertising purposes.

ph52 does not use third-party advertising or retargeting cookies. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will prevent ph52 from functioning correctly.

ph52 implements appropriate 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 on all ph52.app connections
• Two-factor authentication (2FA) available to all ph52 account holders
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Regular security audits, vulnerability assessments, and penetration testing
• Encrypted storage of sensitive data fields including KYC documents and financial information
• Incident response procedures consistent with NPC data breach notification requirements

In the event of a personal data breach that is likely to result in harm to affected individuals, ph52 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with NPC Circular 16-03 and the DPA.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ph52:

Right to Access: You may request a copy of the personal data ph52 holds about you, along with information on how it is used and with whom it is shared.

Right to Correction: You may request correction of inaccurate or incomplete personal data. Minor corrections (e.g., contact number updates) can be made via your ph52 account settings; KYC-related corrections require supporting documentation.

Right to Erasure / Right to be Forgotten: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph52's legal retention obligations under PAGCOR and AMLA requirements.

Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where you have compelling grounds.

Right to Data Portability: You may request a structured, machine-readable copy of personal data you have provided to ph52 for your own reuse.

To exercise any of these rights, contact ph52 via the live chat support channel at ph52.app, referencing "Data Privacy Request." ph52 will respond within thirty (30) days. Where requests are complex or numerous, ph52 may extend this period by a further sixty (60) days with notification. If you are dissatisfied with ph52's handling of a data rights request, you may lodge a complaint with the National Privacy Commission of the Philippines.

ph52 is strictly an adults-only platform. No person under twenty-one (21) years of age is permitted to register or use ph52 under PAGCOR regulations and Philippine gaming law. ph52 does not knowingly collect personal data from individuals under 21 years of age. In the event ph52 discovers that personal data has been collected from a person under 21, ph52 will immediately close the associated account, void any transactions, and securely delete the personal data without undue delay. If you believe a minor has registered at ph52, please contact ph52 support immediately.

ph52.app does not contain links to third-party websites except as expressly referenced in ph52's Terms & Conditions and this Privacy Policy. ph52 is not responsible for the privacy practices of any third-party websites or services. If you navigate to a third-party website from ph52.app (including payment providers' own portals), their separate privacy policies govern their data handling. ph52 recommends reviewing the privacy policy of any external website before providing personal data.

ph52 may update this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR regulatory requirements, or ph52's data processing practices. The effective date at the top of this Policy indicates the date of the most recent revision. ph52 will notify registered players of material changes to this Privacy Policy via the contact details associated with their ph52 account prior to the changes taking effect. Continued use of ph52 after notification of a policy update constitutes your acceptance of the revised Privacy Policy.

For questions, concerns, or requests relating to this Privacy Policy or ph52's handling of your personal data, please contact the ph52 Data Protection Officer via the live chat support available at ph52.app. Please include "Data Privacy" in your message for prompt routing. ph52's contact email for formal data privacy correspondence is displayed as plain text on ph52.app: support ph52.app. All data subject requests will be handled in accordance with the DPA and NPC regulations.

ph52's registered details and DPO registration information are on file with the National Privacy Commission of the Philippines in compliance with NPC registration requirements for personal information controllers.