ph35.com Privacy Policy

ph35.com is committed to protecting the privacy and personal data of every Filipino player who uses our platform. We understand that trust is the foundation of any good relationship — and that trust starts with being transparent about how we handle your information.

This Policy has been prepared in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations issued by the National Privacy Commission ("NPC"). It also reflects the data protection obligations imposed on ph35.com as a PAGCOR-regulated online gaming operator.

As the personal information controller, ph35.com determines the purposes and means of processing your personal data. We process your data only for legitimate, specified, and explicit purposes, and only to the extent necessary to fulfil those purposes. We do not sell your personal data to third parties for marketing purposes.

If you have any questions about this Policy or about how ph35.com handles your personal data, please contact our Data Protection Officer (DPO) using the details provided in Section 14 of this Policy.

ph35.com collects the following categories of personal data from registered players and, in some cases, from visitors to the platform:

ph35.com does not intentionally collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) unless specifically required for regulatory compliance purposes, such as responsible gaming assessments.

ph35.com collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting our support team, or participating in promotions;
• Automated collection: Technical and usage data collected automatically when you access and use the ph35.com platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; fraud and risk data from anti-money laundering screening services; payment data from GCash, PayMaya, and banking partners in connection with your transactions;
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with licensing, compliance, or enforcement activities.

ph35.com processes your personal data for the following specific, legitimate purposes:

• Account registration and management: To create and maintain your ph35.com account, verify your identity, and manage your account preferences;
• Service delivery: To provide you with access to ph35.com's games, sports betting markets, promotions, and all other platform features;
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card, and to maintain accurate financial records;
• Identity verification and KYC: To verify your age (21+), identity, and source of funds in compliance with PAGCOR's Know Your Customer requirements and the Anti-Money Laundering Act;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform;
• Responsible gaming: To monitor gameplay patterns, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling;
• Customer support: To respond to your enquiries, resolve complaints, and provide technical assistance;
• Legal and regulatory compliance: To comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, the DPA, and all other applicable Philippine laws and regulations;
• Platform improvement: To analyse usage patterns and improve the performance, features, and user experience of the ph35.com platform;
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may withdraw your consent at any time via your account settings.

Under the Philippine Data Privacy Act of 2012, ph35.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you (i.e., to provide the ph35.com service), including account management, payment processing, and service delivery;
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and NPC regulations;
• Legitimate interests: Processing necessary for ph35.com's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

ph35.com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances and only to the extent necessary:

• Payment processors: GCash, PayMaya, and banking partners receive the financial data necessary to process your deposits and withdrawals;
• KYC and identity verification providers: Third-party KYC service providers receive identity and verification data to assist with age and identity verification;
• Fraud and AML screening services: Anti-money laundering and fraud detection providers receive transaction and identity data to assist with compliance screening;
• Game software providers: Licensed game providers may receive anonymised or pseudonymised usage data for game performance and fairness auditing purposes;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine regulatory and law enforcement authorities may receive your data where required by law or regulatory obligation;
• Professional advisers: Legal, accounting, and auditing firms engaged by ph35.com may access your data on a confidential, need-to-know basis;
• Business transfers: In the event of a merger, acquisition, or sale of ph35.com's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

ph35.com retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing conditions and the Anti-Money Laundering Act;
• Financial and transaction data: Retained for a minimum of five (5) years following the date of each transaction, in compliance with the Anti-Money Laundering Act and PAGCOR requirements;
• KYC and verification documents: Retained for a minimum of five (5) years following account closure;
• Communications data: Support tickets and live chat transcripts are retained for two (2) years from the date of the communication;
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer periods for fraud investigation or legal proceedings;
• Marketing consent records: Retained for the duration of your account and for one (1) year following account closure.

Upon expiry of the applicable retention period, ph35.com will securely delete or anonymise your personal data in accordance with its data disposal procedures.

ph35.com implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the ph35.com platform;
• Encryption at rest for all sensitive personal data stored on ph35.com's servers, including financial data and KYC documents;
• Access controls limiting access to personal data to authorised ph35.com personnel and service providers on a strict need-to-know basis;
• Multi-factor authentication for internal systems that process personal data;
• Regular security audits and penetration testing conducted by independent third-party security firms;
• Intrusion detection and prevention systems monitoring the ph35.com platform for suspicious activity in real time;
• Staff training on data protection obligations and secure data handling practices.

While ph35.com takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your ph35.com account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

ph35.com uses cookies and similar tracking technologies to enhance your experience on the platform, to maintain your session, and to collect technical and usage data as described in this Policy. A cookie is a small text file placed on your device when you visit the ph35.com platform.

ph35.com uses the following categories of cookies:

• Strictly necessary cookies: Essential for the operation of the ph35.com platform, including session management, login authentication, and security functions. These cookies cannot be disabled without affecting platform functionality;
• Performance cookies: Collect anonymised data about how players use the platform, including pages visited and errors encountered, to help us improve platform performance;
• Functional cookies: Remember your preferences, such as language settings and responsible gaming limits, to provide a more personalised experience;
• Analytics cookies: Used to analyse aggregate usage patterns and measure the effectiveness of platform features and promotions.

You can manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of the ph35.com platform. Strictly necessary cookies cannot be disabled as they are essential for the platform to operate.

ph35.com does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph35.com:

• Right to be informed: The right to be informed of how your personal data is collected, used, stored, and shared, as set out in this Policy;
• Right of access: The right to request a copy of the personal data ph35.com holds about you, and information about how it is being processed;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data ph35.com holds about you;
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph35.com's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible;
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe ph35.com has processed your personal data in violation of the Data Privacy Act of 2012.

ph35.com employs age verification procedures at the point of registration and during KYC verification to prevent underage access to the platform. If you are a parent or guardian and believe that your child has registered an account on ph35.com, please contact our Data Protection Officer immediately using the details in Section 14 so that we can take appropriate action.

ph35.com complies with PAGCOR's requirements regarding the protection of minors and supports the national responsible gaming programme. Gambling is addictive. Know when to stop.

ph35.com primarily processes and stores personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, where ph35.com uses cloud infrastructure or KYC verification services with international operations.

Where personal data is transferred outside the Philippines, ph35.com ensures that appropriate safeguards are in place to protect your data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission;
• Implementing contractual clauses in data processing agreements with international service providers that require them to protect your data to a standard equivalent to the Philippine Data Privacy Act of 2012;
• Conducting due diligence on international service providers to verify their data protection practices before engaging them.

ph35.com will not transfer your personal data to international third parties for purposes other than those described in this Policy.

ph35.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, ph35.com will notify registered players via email or a prominent notice on the platform prior to the changes taking effect.

The date on which this Policy was last updated is displayed at the top of this page. We encourage you to review this Policy periodically. Your continued use of the ph35.com platform following any update to this Policy constitutes your acknowledgement of the revised Policy.

If you do not agree with any changes to this Policy, you may request account closure in accordance with the Terms & Conditions. Your data will be retained following closure only to the extent required by ph35.com's legal retention obligations.

If you have any questions, concerns, or requests relating to this Privacy Policy or to ph35.com's processing of your personal data, please contact our Data Protection Officer. ph35.com has appointed a dedicated DPO in compliance with the requirements of the National Privacy Commission.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that ph35.com has processed your personal data in a manner that violates the Data Privacy Act of 2012. The NPC can be reached through its official website at privacy.gov.ph.