ph3653 Privacy Policy

1.1 The data controller responsible for the personal data collected through the ph3653 platform is ph3653, the operator of the gaming website accessible at ph3653.net, licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR).

1.2 ph3653 determines the purposes and means of processing personal data collected from players registered on the ph3653 platform. All data processing activities described in this Privacy Policy are carried out under ph3653's responsibility as data controller.

1.3 For the purposes of the Philippines Data Privacy Act of 2012 (RA 10173), ph3653 is a personal information controller as defined under Section 3(h) of the Act, and processes personal data with a lawful basis as further described in Section 4 of this Policy.

2.1 Registration Data. When you create a ph3653 account, we collect the following information:

• Full legal name (as it appears on your Philippine government-issued ID)
• Date of birth (to verify compliance with the 21+ age requirement)
• Email address
• Philippine mobile phone number
• Residential address in the Philippines
• Username and encrypted password

2.2 Identity Verification (KYC) Data. To comply with PAGCOR's Know Your Customer requirements and Philippine anti-money laundering laws, ph3653 collects:

• Copies of government-issued Philippine photo identification (PhilSys ID, passport, driver's license, UMID, PRC license, or voter's ID)
• Selfie photographs submitted for facial verification against identity documents
• Proof of residential address documents (utility bills, bank statements, or government correspondence)
• Payment method verification documents confirming ownership of GCash, PayMaya, or bank accounts used for transactions

2.3 Financial Transaction Data. ph3653 collects data relating to all financial transactions on the platform, including:

• Deposit amounts, dates, and payment methods used (GCash, PayMaya, BDO, BPI, Metrobank)
• Withdrawal requests, amounts, and destination payment account references
• Transaction history and wallet balance records
• Bonus claims and promotional activity records

2.4 Gaming Activity Data. ph3653 records your gaming activity on the platform, including game sessions, wagering history, wins and losses, and game category usage. This data is used for regulatory reporting, dispute resolution, and responsible gaming monitoring.

2.5 Device and Technical Data. When you access the ph3653 platform, we automatically collect certain technical information:

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookie and similar tracking technology data (see Section 9)

2.6 Communications Data. We retain records of communications between you and ph3653 support, including live chat transcripts, emails, and any documents or screenshots you submit in connection with a support request or dispute.

3.1 Directly from You. The majority of personal data ph3653 holds is provided directly by you during the account registration process, KYC verification, payment transactions, and interactions with ph3653 support. You choose what information to provide — however, failure to provide mandatory information (such as registration details or KYC documents) will prevent ph3653 from providing you with the full services of the platform.

3.2 Automatically from Platform Use. ph3653 collects technical and gaming activity data automatically when you access and use the ph3653 platform. This includes data collected through cookies, server logs, and platform analytics systems as described in Section 9.

3.3 From Third Parties. ph3653 may receive personal data about you from the following third-party sources:

• Identity verification service providers used to cross-reference KYC documents against official Philippine government databases
• Payment processors (such as GCash and PayMaya operators) confirming transaction completion
• Fraud detection and anti-money laundering screening services
• PAGCOR and other regulatory authorities, where data sharing is mandated by law

The following table describes the primary purposes for which ph3653 processes your personal data and the corresponding legal basis under RA 10173:

5.1 ph3653 does not sell your personal data. We share personal data only in the following circumstances and only to the extent necessary for each purpose:

5.2 Regulatory Authorities. ph3653 is required by law to share player data with PAGCOR and, where applicable, the Anti-Money Laundering Council (AMLC) of the Philippines. Such disclosures are mandatory and cannot be refused by ph3653 under Applicable Law. ph3653 will notify affected players of mandatory disclosures to the extent permitted by law.

5.3 Payment Service Providers. To process deposits and withdrawals, ph3653 shares transaction-relevant data with GCash (Mynt), PayMaya (PayMaya Philippines), BDO Unibank, Bank of the Philippine Islands (BPI), and Metrobank, as applicable to each transaction. These providers act as independent data controllers in respect of data processed for payment purposes.

5.4 Identity Verification Services. ph3653 uses third-party KYC service providers to verify identity documents submitted by players. These providers process personal data solely for the purpose of identity verification under data processing agreements that impose confidentiality and security obligations consistent with RA 10173.

5.5 Gaming Software Providers. Game content on the ph3653 platform is provided by third-party software developers. Technical session data may be shared with these providers for the purpose of game delivery and dispute resolution. No personally identifiable information beyond anonymized session identifiers is shared with game providers.

5.6 Professional Advisers. ph3653 may share data with legal, financial, or compliance advisers where necessary for ph3653 to obtain professional advice or defend legal proceedings, subject to appropriate confidentiality obligations.

5.7 Business Transfers. In the event of a merger, acquisition, or transfer of ph3653's operations, player data may be transferred as part of the business assets. ph3653 will notify affected players of any such transfer in advance where reasonably practicable.

6.1 ph3653 operates primarily within the Philippines, and the majority of data processing activities take place within Philippine jurisdiction. However, some third-party service providers (including gaming software providers and certain technical infrastructure providers) may process data outside the Philippines.

6.2 Where personal data is transferred outside the Philippines, ph3653 implements appropriate safeguards to ensure an equivalent level of data protection, including contractual clauses that require recipients to apply data protection standards consistent with RA 10173 and its Implementing Rules.

6.3 ph3653 does not transfer personal data to countries or entities that are known to lack adequate data protection standards without first implementing contractual or technical safeguards sufficient to protect the rights of Filipino data subjects.

7.1 ph3653 retains personal data only for as long as is necessary to fulfill the purpose for which it was collected, or as required by applicable legal and regulatory obligations, whichever is longer.

7.2 The following indicative retention periods apply to the categories of data ph3653 holds:

7.3 Upon expiry of the applicable retention period, ph3653 will securely delete or irreversibly anonymize the relevant personal data in accordance with ph3653's internal data disposal procedures. Anonymized data (from which individual players cannot be re-identified) may be retained beyond these periods for aggregated analytics purposes.

8.1 ph3653 implements technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between users' devices and the ph3653 platform
• Encryption of sensitive data at rest, including KYC document files and payment account details
• OTP-based two-factor authentication for player account login
• Role-based access controls limiting internal employee access to personal data on a need-to-know basis
• Regular security audits and vulnerability assessments of ph3653's platform infrastructure
• Monitoring systems for detecting unauthorized access attempts and suspicious activity patterns
• Employee data protection training and confidentiality obligations

8.2 Data Breach Notification. In the event of a personal data breach affecting your rights and freedoms, ph3653 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by RA 10173. Affected players will be notified within a reasonable period where the breach is likely to result in a significant risk of harm.

8.3 While ph3653 implements robust security measures, no system is completely immune to security risks. Players are responsible for maintaining the security of their own account credentials and for notifying ph3653 promptly if they suspect unauthorized access to their ph3653 account.

9.1 The ph3653 platform uses cookies and similar tracking technologies to ensure the platform functions correctly, to remember player preferences, and to analyze platform usage patterns. The following categories of cookies may be used:

9.2 You may manage optional cookie preferences through your browser settings. Please note that disabling cookies may affect the functionality of certain features of the ph3653 platform, including login state persistence and game loading performance.

9.3 ph3653 does not use cookies or tracking technologies for third-party advertising or behavioral profiling for marketing purposes beyond the ph3653 platform itself.

10.1 Under the Philippines Data Privacy Act of 2012, you have the following rights in relation to the personal data ph3653 holds about you:

• Right to be Informed: You have the right to know that your personal data is being processed, the purposes of such processing, and the identity of the data controller. This Privacy Policy fulfills this obligation.
• Right of Access: You may request a copy of the personal data ph3653 holds about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. You can update most account details directly through your ph3653 account dashboard; corrections to identity documents require a formal request to support.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to ph3653's legal retention obligations under PAGCOR and AMLA requirements.
• Right to Object: You may object to the processing of your personal data where ph3653 relies on legitimate interest as the legal basis, unless ph3653 can demonstrate compelling legitimate grounds that override your interests.
• Right to Data Portability: Where technically feasible and where processing is based on your consent or a contract with you, you may request your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe ph3653 has not handled your personal data in accordance with RA 10173.

10.2 Exercising Your Rights. To exercise any of the rights listed above, please contact ph3653's Data Protection Officer using the contact details set out in Section 14 of this Policy. ph3653 will respond to all data subject requests within fifteen (15) business days of receipt. In cases requiring additional verification or complex processing, ph3653 may extend this period by a further fifteen (15) business days, with notice to the requestor.

11.1 The ph3653 platform is strictly restricted to individuals aged 21 years and older, in accordance with PAGCOR's regulatory requirements for online gaming in the Philippines. ph3653 does not knowingly collect personal data from individuals under the age of 21.

11.2 Age is verified during the account registration process and confirmed through the KYC identity verification procedure. Any account found to be registered by or for an individual under 21 will be immediately closed, and any associated personal data will be deleted except where retention is required by law in connection with the investigation of the underage registration.

11.3 If you are a parent or guardian and believe that a minor in your care has registered an account or provided personal data to ph3653, please contact ph3653 support immediately at [email protected] so that the matter can be investigated and any personal data involved can be deleted.

12.1 The ph3653 platform may contain links to third-party websites or services — for example, payment provider portals such as GCash or PayMaya that open within a separate browser session during deposit or withdrawal processes. These third-party services have their own independent privacy policies, and ph3653 is not responsible for the data practices of third-party websites or services.

12.2 ph3653 encourages you to review the privacy policies of any third-party payment services or external platforms you interact with in connection with your ph3653 account, particularly in relation to the personal data those platforms collect independently of ph3653.

13.1 ph3653 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. All updates will be published on this page at ph3653.net/privacy-policy with an updated "Last Updated" date.

13.2 Where changes to this Privacy Policy are material — meaning they significantly affect your rights or the way ph3653 processes your personal data — ph3653 will notify registered players by email to their registered address before the changes take effect.

13.3 Your continued use of the ph3653 platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the updated policy. If you do not agree to a material change, you may close your ph3653 account in accordance with the account closure procedure described in the ph3653 Terms and Conditions.

14.1 ph3653 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Philippines Data Privacy Act of 2012. The DPO is the first point of contact for all data subject rights requests and privacy-related complaints.

14.2 To exercise your data subject rights, submit a privacy complaint, or seek clarification about how ph3653 processes your personal data, please contact ph3653's Data Protection Officer through the following channel:

Email: [email protected] (subject line: Privacy / DPO Request)

14.3 ph3653 support is available twenty-four (24) hours a day, seven (7) days a week. For data subject rights requests, please include your registered ph3653 username, the specific right you wish to exercise, and sufficient identifying information to allow ph3653 to verify your identity before processing the request.