ph52 Privacy Policy

ph52 is committed to protecting the privacy and personal data of all players who use the ph52 online gaming platform. We understand that trust is earned, and that Filipino players entrust us with sensitive personal and financial information when they register and play on ph52. This Policy sets out the complete picture of how that data is handled — plainly and honestly.

This Policy should be read in conjunction with the ph52 Terms & Conditions, which govern your use of the platform. Where any conflict arises between this Policy and the Terms & Conditions, the Terms & Conditions shall prevail with respect to gaming matters, and this Policy shall prevail with respect to data privacy matters.

For the purposes of the Data Privacy Act of 2012, ph52 acts as the Personal Information Controller (PIC) with respect to the personal data of all registered players and platform users. ph52 determines the purposes and means of processing your personal data in connection with the operation of the ph52 online gaming platform.

ph52 has appointed a Data Protection Officer (DPO) who is responsible for overseeing the platform's data protection compliance, managing data subject requests, and serving as the point of contact for the National Privacy Commission. To contact the ph52 DPO regarding any data privacy matter, use the contact information in Section 14 of this Policy.

ph52 collects the following categories of personal data from players:

ph52 collects personal data through the following methods:

• Direct collection: Data you voluntarily provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automatic collection: Technical data collected automatically when you access the ph52 platform, including your IP address, device and browser information, and session data collected via cookies and similar tracking technologies (see Section 9).
• Third-party sources: Identity verification data provided by KYC service providers; fraud screening data from anti-fraud service providers; payment data from GCash, PayMaya, and other payment service providers involved in processing your transactions.
• Public sources: In limited circumstances related to fraud prevention or regulatory compliance, ph52 may supplement account data with information obtained from publicly available sources.

ph52 processes your personal data only for specified, legitimate purposes. The table below outlines the primary processing purposes and the data categories involved:

ph52 does not use personal data for any purpose beyond those listed above without first obtaining your explicit consent or establishing a new lawful basis under the Data Privacy Act.

ph52 processes your personal data on the following legal bases as provided under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Consent: Where you have given clear consent to processing for a specific purpose, such as receiving ph52 promotional communications. You may withdraw consent at any time.
• Contractual necessity: Processing necessary to perform our obligations under the ph52 Terms & Conditions, including account creation, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for the legitimate interests of ph52, including fraud prevention, platform security, and improving platform performance, provided such interests are not overridden by your data privacy rights.

ph52 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors involved in your deposit and withdrawal transactions. Sharing is limited to the data necessary to process the specific transaction.
• KYC and identity verification providers: Third-party services that assist ph52 in verifying player identities and conducting age verification, as required by PAGCOR compliance standards.
• Fraud prevention and AML screening services: Providers of fraud detection and anti-money laundering screening services used to protect the ph52 platform and its players.
• 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 or regulatory directive.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid legal process, court order, or government request.
• Technology and cloud service providers: Providers of infrastructure, hosting, and software services used to operate the ph52 platform, subject to strict contractual data processing agreements.

ph52 does not sell, rent, or disclose your personal data to third-party advertisers, data brokers, or any party for their independent commercial use. All third parties with whom ph52 shares data are contractually bound to process it only for the specified purpose and to maintain appropriate security measures.

ph52 retains personal data only for as long as is necessary for the purposes for which it was collected, subject to the following retention considerations:

• Account and identity data: Retained for the duration of your active ph52 account, plus a minimum period of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act (AMLA).
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLC and PAGCOR reporting obligations.
• Gaming and session data: Retained for a minimum of two (2) years to support dispute resolution and responsible gaming monitoring.
• Communications data: Customer support records are retained for three (3) years from the date of the interaction.
• Technical and cookie data: Session data is deleted at session end; analytics data is anonymized after twelve (12) months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ph52's data deletion procedures.

ph52 uses cookies and similar tracking technologies on the ph52 platform for the following purposes:

• Strictly necessary cookies: Essential for the platform to function correctly, including maintaining your login session, securing transactions, and enabling core gameplay features. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming limits, to provide a personalized platform experience.
• Analytical cookies: Collect anonymized or aggregated data about how players interact with the ph52 platform, helping us identify areas for improvement. No individual player is identified through these cookies.
• Security cookies: Used in fraud detection and bot prevention to protect your account and the integrity of the platform.

ph52 does not use third-party advertising or retargeting cookies on the platform. You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may impair platform functionality.

ph52 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• TLS 1.3 encryption for all data transmitted between your device and ph52 servers.
• Encryption of sensitive data at rest using industry-standard encryption protocols.
• Two-factor authentication (2FA) support for player account login.
• Access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments and penetration testing of platform infrastructure.
• Monitoring systems for detection of unauthorized access attempts, anomalous account activity, and potential data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph52 will notify affected players and report to the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act and NPC regulations.

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph52:

• Right to be Informed: The right to be told how ph52 collects and uses your personal data — which is fulfilled by this Privacy Policy.
• Right to Access: The right to request a copy of the personal data ph52 holds about you and information about how it is being processed.
• Right to Correction: The right to request correction of inaccurate, outdated, or incomplete personal data. Many corrections can be made directly in your ph52 account profile.
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where it is incomplete, outdated, false, unlawfully obtained, or no longer necessary for the purpose it was collected, subject to ph52's legal retention obligations.
• Right to Object: The right to object to processing of your personal data, in particular for direct marketing purposes. You may opt out of ph52 promotional communications at any time.
• Right to Data Portability: The right to receive your personal data in a structured, machine-readable format.
• Right to Damages: The right to compensation for damages suffered as a result of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data, where ph52 is found to be at fault.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph52 has violated your data privacy rights.

To exercise any of your data subject rights, contact the ph52 Data Protection Officer using the details in Section 14. ph52 will respond to verified data subject requests within fifteen (15) business days.

The ph52 platform is strictly intended for adults who are at least 21 years of age, in compliance with PAGCOR regulations governing online gaming in the Philippines. ph52 does not knowingly collect personal data from individuals under 21 years of age.

ph52 employs age verification procedures during account registration and KYC review to confirm that all players meet the minimum age requirement. If ph52 determines that personal data has been collected from an individual under 21 years of age, that data will be deleted and the associated account will be closed immediately.

Parents and guardians who believe that a minor has registered an account on ph52 are encouraged to contact ph52 support immediately so that appropriate action can be taken.

ph52 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The effective date at the top of this Policy will be updated whenever a material change is made.

For material changes — those that significantly affect your data privacy rights or how ph52 uses your personal data — ph52 will provide advance notification via your registered email address or via a prominent notice on the ph52 platform, prior to the change taking effect. For non-material changes (such as corrections of typographical errors or minor clarifications), notification may not be provided separately.

Your continued use of the ph52 platform after the posting of an updated Privacy Policy constitutes your acceptance of the changes. It is your responsibility to review this Policy periodically. The current version is always available at ph52.org/privacy-policy.

For any questions, concerns, or requests related to this Privacy Policy or your personal data, including the exercise of your data subject rights under the Data Privacy Act of 2012, please contact the ph52 Data Protection Officer:

This Privacy Policy was last updated on 1 January 2026 and supersedes all previous versions.