ph1vip Privacy Policy

ph1vip ("ph1vip", "we", "us", "our") operates an online casino and sportsbook platform accessible at ph1vip.app, serving Filipino players across the Philippines. In the course of providing our gaming services, we collect and process personal data about our registered players and site visitors. We take our data protection responsibilities seriously and are committed to handling your personal information with care, transparency, and respect.

This Privacy Policy explains in clear terms what personal data ph1vip collects, the purposes for which it is used, the legal bases that justify that use, how long we keep it, and your rights in relation to it under Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines.

This Policy applies to all personal data collected through the ph1vip website, mobile platform, customer support channels, and any other interaction you have with ph1vip as a player or prospective player. It should be read together with our Terms & Conditions.

ph1vip is the data controller responsible for your personal data collected through the ph1vip platform. As data controller, ph1vip determines the purposes and means of processing your personal information and is accountable for ensuring that processing is carried out lawfully, fairly, and transparently in accordance with the Data Privacy Act of 2012 and its implementing rules and regulations.

ph1vip operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and maintains a designated Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws. The DPO can be contacted through the support channels listed in Section 14 of this Policy.

ph1vip collects personal data at various points of your interaction with our platform. The categories of personal data we collect include:

ph1vip does not collect sensitive personal information beyond what is strictly required for age and identity verification. We do not collect biometric data beyond what is required for liveness checks during the KYC process, and we do not retain raw biometric templates.

If you choose not to provide certain personal data — particularly the information required for KYC verification — ph1vip may be unable to activate real-money gaming on your account as required by PAGCOR regulations.

ph1vip processes your personal data for the following specific purposes:

• Account Management: To create, maintain, and administer your ph1vip player account, including authentication, account recovery, and security monitoring.
• Identity & Age Verification (KYC): To verify that you meet the minimum age requirement of 21 years and to confirm your identity as required by PAGCOR and Philippine AML laws before enabling real-money play.
• Payment Processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported payment methods, and to maintain transaction records as required by law.
• Gaming Operations: To provide, personalise, and improve the games, sportsbook markets, and other features available on the ph1vip platform.
• Regulatory Compliance: To fulfil ph1vip's legal obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine legislation.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, prohibited conduct, money laundering, and unauthorised account access.
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling, to administer self-exclusion and deposit limit requests, and to ensure compliance with responsible gaming obligations.
• Customer Support: To respond to your enquiries, complaints, and requests submitted via live chat or email.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided your consent to receive such communications. You may withdraw consent at any time.
• Analytics & Platform Improvement: To analyse aggregated, anonymised usage data to understand how players interact with ph1vip and to improve our platform's features and performance.

ph1vip does not use your personal data for automated decision-making that produces legal or similarly significant effects on you, beyond automated screening tools used for AML and fraud detection as required by law.

Under the Data Privacy Act of 2012, ph1vip relies on the following legal bases to justify processing your personal data:

• Contractual Necessity: Processing that is necessary to perform the contract between you and ph1vip — i.e., to operate your player account, process your bets, and manage your funds. Without this processing, ph1vip cannot provide its services to you.
• Legal Obligation: Processing required to comply with ph1vip's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act, the National Internal Revenue Code, and other applicable Philippine laws and regulations.
• Legitimate Interests: Processing carried out for ph1vip's legitimate business interests — including fraud prevention, platform security, and internal analytics — where those interests are not overridden by your privacy rights.
• Consent: For specific processing activities, particularly direct marketing communications, ph1vip relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Where ph1vip relies on legitimate interests as its legal basis, we carry out a balancing assessment to confirm that our interests do not override your fundamental privacy rights. If you wish to request details of any such assessment, please contact our Data Protection Officer through the channels in Section 14.

ph1vip does not sell, rent, or trade your personal data to any third party. We share your data only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• Game Providers: Licensed third-party game studios and live dealer providers whose games are available on ph1vip may receive limited technical data (such as session tokens) to facilitate gameplay. These providers are contractually required to handle data in accordance with the Data Privacy Act.
• Payment Processors: When you make a deposit or withdrawal, the relevant payment provider (e.g., GCash, Maya, BPI, BDO, Metrobank) receives the transaction data necessary to complete the payment. ph1vip does not store full payment credentials.
• KYC Verification Partners: ph1vip may use licensed third-party identity verification services to assist with KYC and liveness checks. These services process your identity documents under strict data processing agreements.
• Regulatory Authorities: ph1vip is obligated to share player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other competent Philippine government authorities when required by law, court order, or regulatory direction.
• IT & Infrastructure Providers: ph1vip uses trusted cloud hosting and security service providers to operate the platform. These providers act as data processors under our direction and are bound by data processing agreements that prohibit independent use of your data.
• Professional Advisers: ph1vip's lawyers, auditors, and compliance consultants may access data on a confidential, need-to-know basis when advising ph1vip on its legal and regulatory obligations.

ph1vip uses cookies and similar tracking technologies on the ph1vip.app website to enhance your experience, maintain session security, and understand how the platform is used. The types of cookies we use include:

• Strictly Necessary Cookies: Essential to the operation of the ph1vip platform. These include session cookies that keep you logged in during a gaming session and security cookies that protect against cross-site request forgery. These cannot be disabled without affecting core platform functionality.
• Functional Cookies: Remember your preferences — such as language settings and display options — to personalise your ph1vip experience between sessions.
• Analytics Cookies: Allow ph1vip to collect aggregated, anonymised data about how players navigate and use the platform, enabling us to identify areas for improvement. No personally identifiable information is included in analytics reports.
• Security & Fraud Detection Cookies: Help ph1vip identify and prevent fraudulent login attempts, bot activity, and suspicious behaviour on the platform.

ph1vip does not use third-party advertising or retargeting cookies. Your browsing activity on ph1vip is not shared with advertising networks.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair platform functionality. For full details on how to manage cookies in your browser, refer to your browser's help documentation.

ph1vip implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and ph1vip's servers is encrypted using 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive personal data stored in ph1vip's databases — including KYC documents and financial records — is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within ph1vip is restricted on a strict need-to-know basis. Staff members can only access the data required to perform their specific job functions, and all access is logged and audited.
• Two-Factor Authentication: Internal systems containing player data require two-factor authentication for staff access.
• Penetration Testing & Security Audits: ph1vip conducts regular penetration testing and security reviews of its platform infrastructure to identify and remediate vulnerabilities.
• Incident Response: ph1vip maintains a documented data breach response plan. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, ph1vip will notify the National Privacy Commission (NPC) and affected players in accordance with the Data Privacy Act's breach notification requirements.

While ph1vip takes all reasonable precautions, no online platform can guarantee absolute security. You also play a role in keeping your account safe — please review Section 4 of our Terms & Conditions for guidance on protecting your login credentials.

ph1vip retains your personal data for the periods set out below, after which data is securely deleted or irreversibly anonymised:

Where legal proceedings or regulatory investigations are ongoing, ph1vip may retain relevant data for longer than the periods above until the matter is fully resolved. Once retention periods expire, data is deleted in accordance with ph1vip's secure data disposal procedures.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to the personal data ph1vip holds about you:

To exercise any of these rights, please contact ph1vip's support team via live chat on the platform. We will respond to all valid requests within 30 calendar days. In complex cases, we may extend this period by a further 30 days and will notify you accordingly.

Please note that some rights are subject to limitations under the Data Privacy Act — for example, we cannot delete data we are legally required to retain under PAGCOR or AMLA obligations. In such cases, we will explain the reason we are unable to fully comply with your request.

ph1vip's platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming law and PAGCOR regulations. ph1vip does not knowingly collect personal data from individuals under the age of 21.

Age verification is a mandatory step in the ph1vip registration and KYC process. Any account found to belong to an individual under 21 will be immediately suspended, all associated balances and winnings will be forfeited, and the matter may be reported to PAGCOR.

Parents and guardians are encouraged to use parental control software on shared devices to prevent minors from accessing online gaming platforms, including ph1vip. If you believe a minor has registered on ph1vip, please contact our support team immediately via live chat so we can investigate and take appropriate action.

ph1vip's primary data processing infrastructure is based in the Philippines. Some of our licensed game providers, technology partners, and cloud infrastructure providers may be located in other countries, which may result in your personal data being transferred outside the Philippines.

Whenever ph1vip transfers personal data outside the Philippines, we take the following steps to ensure your data remains protected:

• We enter into data processing agreements with all international recipients that include obligations equivalent to those required by the Data Privacy Act and the National Privacy Commission's guidelines on cross-border data flows.
• We conduct due diligence to confirm that recipient countries or organisations provide an adequate level of data protection.
• Where required, we implement standard contractual clauses or other approved transfer mechanisms.

By using the ph1vip platform, you acknowledge that your personal data may be transferred to and processed in countries other than the Philippines, subject to the safeguards described in this section.

ph1vip reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made, we will notify registered players by:

• Posting a prominent notice on the ph1vip platform upon your next login, and/or
• Sending a notification to the email address registered on your Account, with at least seven (7) days' notice before the updated Policy takes effect.

The most current version of this Privacy Policy is always available at ph1vip.app/privacy-policy, along with the date of the most recent update. We encourage you to review this page periodically. Your continued use of the ph1vip platform after an updated Privacy Policy takes effect constitutes your acknowledgement of the revised terms.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how ph1vip handles your personal data, please contact our Data Protection Officer through the following channels:

• Live Chat: Available 24/7 directly on the ph1vip platform. Select "Privacy / Data Request" when initiating your chat for faster routing to our DPO team.
• Email: [email protected] — please include "Data Privacy Request" in the subject line.
• Response Time: ph1vip aims to acknowledge all data privacy enquiries within 3 business days and to fully respond within 30 calendar days.

If you are not satisfied with ph1vip's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent authority responsible for enforcing the Data Privacy Act of 2012 and can be reached through its official government channels.