ph33e Privacy Policy

This Privacy Policy applies to all personal data collected by ph33e in connection with the operation of the ph33e online casino and sports betting platform, accessible at ph33e.club and its associated mobile interfaces. It applies to all registered players, visitors to the ph33e website, and any individual who communicates with ph33e's support team.

By registering a ph33e account or using any ph33e service, 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 consent, you must not register for or use ph33e.

This Privacy Policy is to be read in conjunction with ph33e's Terms & Conditions. In the event of a conflict between the two documents regarding the handling of personal data, this Privacy Policy shall prevail.

ph33e is the data controller in respect of all personal data collected via the ph33e platform. As data controller, ph33e is responsible for determining the purposes and means by which your personal data is processed.

ph33e operates in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable PAGCOR regulations pertaining to player data management, anti-money laundering record-keeping, and responsible gaming requirements.

ph33e has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection law. The DPO may be contacted at the email address provided in Section 13 of this Policy.

ph33e collects personal data from you in the following categories:

Identity & Contact Data:

• Full legal name as appearing on your government-issued Philippine ID;
• Date of birth (used to verify the 21+ age requirement);
• Registered Philippine mobile number;
• Email address;
• Residential address (required for KYC verification at higher account tiers).

Verification & KYC Data:

• Copy of a valid Philippine government-issued ID (e.g., UMID, PhilSys, passport, driver's licence);
• Selfie or liveness check image for facial verification;
• Additional documentation requested during enhanced due diligence, such as proof of address or source of funds.

Financial Data:

• GCash account number linked to your ph33e account;
• PayMaya, BPI, BDO, or Metrobank account details used for deposit or withdrawal;
• Full deposit, withdrawal, and bet transaction history.

Technical & Usage Data:

• IP address and approximate geolocation at the time of login and gameplay;
• Device type, operating system, and browser information;
• Session logs including login times, game history, and navigation patterns;
• Cookies and similar tracking technologies (see Section 7).

Communications Data:

• Records of all communications with ph33e's live support team, including chat transcripts and email correspondence;
• Feedback, survey responses, and promotional participation records.

ph33e uses your personal data for the following purposes:

• Account Registration & Management: To create and maintain your ph33e account, verify your identity and age, and administer your player profile;
• Service Delivery: To provide access to ph33e games, process deposits and withdrawals, manage bonuses, and operate the platform;
• Regulatory Compliance: To fulfil ph33e's obligations under PAGCOR regulations and the Anti-Money Laundering Act, including player identification, transaction monitoring, and suspicious activity reporting;
• Payment Processing: To process financial transactions via GCash, PayMaya, BPI, BDO, Metrobank, and other permitted payment channels;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, account abuse, and security breaches;
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling and to enforce player-requested responsible gaming tools such as deposit limits and self-exclusion;
• Customer Support: To respond to your enquiries, resolve disputes, and improve support quality;
• Marketing & Promotions: To send you promotional communications about ph33e bonuses, new games, and offers — only with your consent, and subject to your opt-out rights;
• Platform Improvement: To analyse usage patterns, improve game performance, and enhance the ph33e user experience.

ph33e processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform ph33e's obligations under your account agreement and Terms & Conditions — including account creation, game access, and payment processing;
• Legal Obligation: Processing is required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act obligations, and other applicable Philippine law;
• Legitimate Interest: Processing is necessary for ph33e's legitimate interests in fraud prevention, platform security, and improving service quality, provided those interests do not override your rights;
• Consent: For marketing communications and non-essential cookies, ph33e relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

ph33e does not sell, rent, or trade your personal data to third-party marketing organisations. ph33e may share your personal data with the following categories of recipients, solely as necessary for the purposes described in this Policy:

• Game Providers: JILI, PG Soft, Evolution Gaming, Pragmatic Play, Fachai, SA Gaming, and other licensed game providers receive limited technical data (player ID, session tokens) necessary to operate game sessions. These providers do not receive your full personal profile;
• Payment Processors: GCash (G-Xchange, Inc.), PayMaya (Maya Philippines, Inc.), and Philippine banking institutions receive financial data necessary to execute deposits and withdrawals;
• KYC & Identity Verification Services: Third-party KYC providers used to verify your identity and age in accordance with PAGCOR requirements;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where disclosure is required by law or court order;
• IT & Security Service Providers: Cloud hosting, cybersecurity, and fraud detection partners operating under strict data processing agreements and bound to handle ph33e data confidentially;
• Professional Advisers: Legal counsel, auditors, and compliance consultants under professional confidentiality obligations.

Any third party that receives ph33e player data is contractually required to process it only for the specific purpose for which it was shared and to maintain appropriate security measures.

ph33e uses cookies and similar tracking technologies on the ph33e platform to ensure proper functionality, maintain your login session, prevent fraud, and analyse how the platform is used. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies and security tokens. You cannot opt out of these without preventing platform access;
• Functional Cookies: Remember your preferences such as language settings and game layout. These improve your experience but are not essential;
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate ph33e, which pages are most visited, and where errors occur. ph33e uses this data to improve the platform;
• Marketing Cookies: Used only with your prior consent to measure the effectiveness of ph33e's promotional campaigns.

You may manage cookie preferences via your browser settings. Disabling certain cookies may affect platform functionality. ph33e does not use cookies to build advertising profiles for external marketing networks.

ph33e retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following minimum retention periods apply:

• Account & KYC Data: Retained for a minimum of five years from the date of account closure, as required by PAGCOR licensing conditions and Anti-Money Laundering Act record-keeping obligations;
• Transaction Records: Retained for a minimum of five years from the date of each transaction;
• Support Communications: Retained for up to three years from the date of each interaction;
• Marketing Consent Records: Retained until consent is withdrawn, plus a reasonable period thereafter as evidence of consent.

Following expiry of the applicable retention period, ph33e will securely delete or anonymise your personal data in accordance with its internal data disposal procedures.

ph33e implements technical and organisational measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• TLS/HTTPS encryption for all data transmitted between your device and ph33e's servers;
• Encryption at rest for stored personal data and financial records;
• Role-based access controls limiting internal access to personal data to authorised personnel only;
• Multi-factor authentication for ph33e staff accessing production systems;
• Regular security audits and penetration testing by qualified third-party security firms;
• Incident response procedures for detecting, containing, and notifying affected parties of data breaches in accordance with applicable law.

No data transmission over the internet or electronic storage is completely secure. While ph33e takes all reasonable steps to protect your data, ph33e cannot guarantee absolute security. In the event of a breach affecting your rights, ph33e will notify you and the National Privacy Commission as required by the Data Privacy Act.

As a data subject under the Data Privacy Act of 2012, you have the following rights regarding your personal data held by ph33e:

• Right to be Informed: To be notified of how your data is collected, used, and shared — which this Privacy Policy fulfils;
• Right of Access: To request a copy of the personal data ph33e holds about you;
• Right to Rectification: To request correction of inaccurate or incomplete personal data;
• Right to Erasure: To request deletion of your personal data, subject to ph33e's legal retention obligations;
• Right to Object: To object to specific processing activities, including direct marketing;
• Right to Data Portability: To receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: To file a complaint with the National Privacy Commission (NPC) if you believe ph33e has violated your data privacy rights.

To exercise any of the above rights, contact ph33e's Data Protection Officer at [email protected] with the subject line "Data Rights Request". ph33e will respond within 15 business days. Identity verification will be required before processing any data access or deletion request.

ph33e's services are strictly intended for individuals aged 21 years and above. ph33e does not knowingly collect personal data from any person under the age of 21. If ph33e becomes aware that personal data from a minor has been collected — whether through a misrepresentation during registration or any other means — ph33e will immediately close the associated account, void all activity, and securely delete the relevant data.

If you are aware that a minor has accessed or registered for ph33e using false age information, please notify ph33e's support team immediately via live chat or at [email protected].

ph33e may update this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR regulatory requirements, or ph33e's data processing practices. Material changes will be communicated to registered players via email or an in-platform notification prior to taking effect.

The date of the most recent revision is displayed at the top of this Privacy Policy. Your continued use of ph33e following publication of a revised Privacy Policy constitutes acceptance of the updated terms. If you do not accept the revised Policy, you must cease using ph33e and may request account closure.

For any questions, concerns, or requests relating to this Privacy Policy or ph33e's data processing activities, please contact ph33e's Data Protection Officer:

• Email: [email protected] — subject line: "Privacy / DPO"
• Live Chat: Available 24/7 on the ph33e platform. Average response under 5 minutes during peak hours.

If you believe that ph33e has infringed your rights under the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about filing a complaint is available on the NPC's official website.