Privacy Policy
— ph997 Player Data Charter

1 Introduction & Scope

ph997 is an online casino and sports betting platform operating in the Philippines under the ph997.vip domain. As the personal information controller for the data of its registered users, ph997 takes seriously its obligations under the Data Privacy Act of 2012 and all other applicable Philippine privacy regulations.

This Policy applies to all personal data collected through the ph997 Platform, including data collected during account registration, gameplay sessions, deposit and withdrawal transactions, customer support interactions, promotional participation, and any other interaction between you and ph997 through the website or any associated communication channel.

This Policy does not apply to the data practices of third-party game providers, payment processors, or external websites that may be linked from the ph997 Platform. ph997 encourages Players to review the privacy policies of third parties they interact with independently of ph997.

2 Definitions

• "Personal Data" — Any information from which the identity of an individual can be directly or reasonably and certainly ascertained, whether alone or when combined with other information.
• "Sensitive Personal Data" — Personal data about an individual's race, ethnic origin, marital status, age, color, and religious, philosophical, or political affiliations; health, education, genetic or sexual life; court proceedings; and government-issued identification numbers.
• "Processing" — Any operation performed on personal data including collection, recording, organization, storage, updating, retrieval, use, disclosure, or destruction.
• "Personal Information Controller" — The entity that controls the collection, holding, processing, and use of personal data. For ph997 users, ph997 is the personal information controller.
• "Data Subject" — The individual whose personal data is processed. In the context of this Policy, the data subject is the ph997 Player.
• "Consent" — Any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they agree to the processing of their personal data.

3 Personal Data We Collect

ph997 collects the following categories of personal data when you use the Platform. We apply the principle of data minimization — we collect only what is necessary for the stated purposes.

4 How ph997 Uses Your Personal Data

ph997 processes your personal data for the following specific, legitimate purposes:

• Creating and maintaining your ph997 Account, including authentication, password recovery, and security management.
• Processing your deposits and withdrawal requests and maintaining accurate wallet records.
• Providing access to all game categories, sports betting, and bingo services on the Platform.
• Administering promotions, bonuses, and loyalty rewards where you have participated.

• Verifying player identity and age (KYC) as required under Philippine gaming and anti-money laundering regulations.
• Screening transactions for suspicious activity in compliance with the Anti-Money Laundering Act (AMLA) of the Philippines and its amendments.
• Responding to lawful requests from Philippine government agencies, law enforcement, and regulatory bodies including PAGCOR and the AMLC.
• Maintaining transaction and account records for the periods mandated by Philippine law.

• Detecting and investigating unauthorized Account access, fraudulent transactions, bonus abuse, and other prohibited conduct.
• Monitoring for multiple account creation, identity fraud, and patterns consistent with organized gaming fraud or collusion.
• Enforcing ph997's Terms and Conditions, including self-exclusion requests and age restriction enforcement.

ph997 uses gaming activity data — including wager frequency, session duration, deposit amounts, and win/loss patterns — to support responsible gaming monitoring functions. This includes triggering responsible gaming interventions, delivering reality check notifications, and enforcing deposit limits set by the Player or applied by ph997's responsible gaming team. This processing is conducted in the legitimate interest of player welfare.

Aggregated, anonymized analytics derived from player behavior data are used to improve the ph997 Platform — including game performance optimization, mobile interface refinement, and payment flow improvement. ph997 does not use individual player profiles for Platform improvement; only anonymized aggregate data is used for this purpose.

Where a Player has explicitly opted in to marketing communications, ph997 may send promotional notifications via SMS or email regarding new games, seasonal promotions, bonus offers, and platform updates. Marketing communications are sent only to Players who have consented and may be unsubscribed at any time via Account Settings or by contacting support.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, ph997 relies on the following legal bases for processing personal data:

1. Contract Performance: Processing necessary for the performance of the gaming services contract — including account creation, deposits, withdrawals, and gameplay access.
2. Legal Obligation: Processing required to comply with Philippine law — including KYC identity verification, AML transaction monitoring, and regulatory record-keeping.
3. Legitimate Interest: Processing for fraud prevention, platform security, technical data for performance optimization, and responsible gaming monitoring — where these interests are not overridden by the Player's privacy rights.
4. Consent: Processing for marketing communications and optional tracking features — where the Player has freely and unambiguously indicated their agreement. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

ph997 does not sell, trade, or commercially transfer your personal data to third parties. ph997 shares personal data only in the following defined circumstances and with the following categories of recipients:

ph997 engages third-party service providers who process personal data on ph997's behalf and under ph997's instruction, including:

• Payment processors and e-wallet providers (GCash, Maya, BPI, BDO, UnionBank, Coins.ph) — for deposit and withdrawal processing. These providers receive only the transactional data required for payment execution.
• KYC and identity verification technology providers — for document authentication and age verification.
• Game software providers (JILI Games, PG Soft, Pragmatic Play, and others) — game session data is shared with the provider of the game being played to determine outcomes. Providers receive session data only, not financial or full identity data.
• Cloud infrastructure and hosting providers — for data storage and platform availability. These providers act as data processors and are contractually bound to process data only as directed by ph997.

ph997 may disclose personal data to Philippine government agencies, law enforcement bodies, courts, PAGCOR, or the Anti-Money Laundering Council (AMLC) where required to do so by law, court order, or lawful regulatory directive. ph997 will notify affected Players of such disclosures unless legally prohibited from doing so.

In the event of a merger, acquisition, or sale of all or substantially all of ph997's assets, personal data held by ph997 may be transferred to the acquiring entity as part of the transaction. Players will be notified of any such transfer and the Privacy Policy of the acquiring entity prior to any change in data processing practices taking effect.

7 Cookies & Tracking Technologies

ph997 uses cookies and similar tracking technologies on the Platform to support essential functionality and, with your consent, to analyze Platform usage. The following categories of cookies are used:

These cookies are required for the Platform to function. They maintain your login session, remember your security settings, and enable secure navigation of the Platform. These cookies cannot be disabled without impairing Platform functionality. No consent is required for strictly necessary cookies under the DPA 2012 framework.

Functional cookies remember your preferences — such as your selected language, preferred game categories, and whether you have dismissed informational banners. These cookies improve your ph997 experience but are not essential to core Platform function.

With your consent, ph997 uses analytics cookies to understand aggregate patterns of Platform usage — which game categories are most popular, which pages have the highest exit rates, and how Filipino players navigate the Platform on mobile devices. This data is used in anonymized aggregate form to improve the ph997 experience. Individual player behavior is not tracked for analytics purposes.

Players may manage cookie preferences through the cookie consent banner displayed on first visit to the Platform, or through their browser settings. Note that disabling certain cookies may affect Platform functionality.

8 Data Security Measures

ph997 implements technical and organizational security measures appropriate to the risk of processing personal data in an online gaming environment. These measures include, but are not limited to:

• Transport Layer Security (TLS) 1.3 encryption for all data in transit between Player devices and ph997 servers.
• AES-256 encryption for all sensitive personal data stored at rest, including KYC documents, payment method identifiers, and account credentials.
• Multi-factor authentication options available to all Players, including SMS OTP two-factor authentication for account login.
• Role-based access controls limiting internal employee access to personal data to only those with a legitimate operational need.
• Regular security assessments, penetration testing, and vulnerability management protocols for ph997's infrastructure.
• Incident response procedures compliant with NPC Circular 16-03 for mandatory reporting of personal data breaches within 72 hours of discovery.
• Employee data privacy training and confidentiality agreements for all personnel with access to personal data.

9 Data Retention Periods

ph997 retains personal data for no longer than necessary for the purpose for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Active Account Data: Retained for the life of your ph997 account, plus five (5) years following permanent account closure, as required for gaming regulatory compliance and AML record-keeping.
• Financial Transaction Records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act, as amended by Republic Act No. 11521.
• KYC Identity Documents: Retained for the account lifetime plus five (5) years, with enhanced security during the full retention period.
• Customer Support Communications: Retained for two (2) years from the date of last interaction, or for the life of the account if the communication relates to an unresolved dispute.
• Marketing Consent Records: Retained for three (3) years from the date of consent, or until consent is withdrawn, whichever occurs first.
• Technical/Log Data: Retained for twelve (12) months in operational logs, and up to five (5) years in security audit archives.

Upon expiry of the applicable retention period, ph997 will securely delete or irreversibly anonymize personal data in accordance with NPC-recognized data disposal standards.

10 Your Data Protection Rights

As a data subject under the Data Privacy Act of 2012, every ph997 player has the following rights with respect to their personal data:

1. Right to be Informed: The right to know the details of how ph997 processes your personal data — covered comprehensively in this Policy.
2. Right of Access: The right to request a copy of the personal data ph997 holds about you, and information about how it is processed.
3. Right to Rectification: The right to request correction of inaccurate or incomplete personal data. For most data fields, corrections can be made directly in Account Settings.
4. Right to Erasure: The right to request deletion of your personal data where retention is no longer legally required. Note that data subject to mandatory retention periods under AML or gaming regulation cannot be deleted during those periods.
5. Right to Object: The right to object to specific processing activities — particularly marketing communications and processing based on legitimate interest — where your privacy interests outweigh ph997's operational justification.
6. Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used machine-readable format for transmission to another controller, where technically feasible.
7. Right to Complain: The right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph if you believe ph997 has processed your data in violation of the DPA 2012.

11 Children & Minors

If ph997 discovers that personal data has been collected from a person under the age of 21, that data will be immediately and permanently deleted, the associated Account will be permanently closed, and the matter may be referred to relevant Philippine authorities where required.

If you are a parent or guardian and believe your child under the age of 21 has provided personal data to ph997, please contact ph997 support immediately through the live chat system. ph997 will take immediate action to investigate and, where confirmed, remove the data without delay.

12 International Data Transfers

ph997 may, in the course of normal Platform operations, transfer personal data to service providers whose infrastructure is located outside the Philippines — including cloud hosting providers and international game software providers. Such transfers are made only where:

• The recipient country has been recognized by the NPC as providing adequate data protection standards, or
• ph997 has implemented appropriate safeguards — such as data processing agreements with standard contractual clauses — that ensure the receiving entity provides a level of data protection equivalent to the DPA 2012, or
• The transfer is necessary for the performance of the service contract with the Player.

ph997 does not transfer Philippine players' KYC identity documents or financial data outside jurisdictions with comparable data protection frameworks without implementing enhanced contractual safeguards. Players may request information about the specific international transfer safeguards applicable to their data by contacting ph997 support.

13 Marketing Communications

ph997 sends marketing communications — including promotional SMS messages and emails about new games, seasonal ph997 bonuses, and platform updates — only to Players who have explicitly opted in to receive them at the time of account registration or subsequently through Account Settings.

Marketing messages from ph997 will always identify ph997 as the sender. ph997 does not send marketing messages on behalf of third parties. Promotional messages will always contain a clear opt-out mechanism.

Players may withdraw their marketing consent at any time by:

• Accessing Account Settings and updating marketing preferences, or
• Contacting ph997 support via live chat and requesting removal from marketing communications, or
• Using the unsubscribe link contained in any ph997 marketing email.

Withdrawal of marketing consent does not affect the lawfulness of communications sent prior to withdrawal, and does not affect ph997's ability to send transactional communications related to your Account — such as deposit confirmations, withdrawal notifications, security alerts, and policy update notices. Transactional communications are not marketing and cannot be opted out of while your Account is active.

14 Changes to This Privacy Policy

ph997 reviews and updates this Privacy Policy periodically to reflect changes in Platform operations, legal requirements, or NPC guidance. When material changes are made to this Policy, ph997 will update the "Effective Date" field at the top of this page and may notify active Players via Account notification or email.

Your continued use of the ph997 Platform after the effective date of an updated Policy constitutes your acknowledgement of the changes. Where changes involve a new or expanded purpose for processing your personal data that requires your consent, ph997 will seek fresh consent before processing your data for that new purpose.

ph997 recommends that Players review this Policy periodically — particularly before participating in new promotional features or submitting new categories of personal data to the Platform.

15 Contact & Complaints

ph997 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Policy. Players may contact the ph997 DPO for privacy-related inquiries, rights requests, and data breach notifications through the following channels: