ph11t Privacy Policy

ph11t ("we," "us," or "our") operates the online gaming platform accessible at ph11t.club. This Privacy Policy explains how ph11t, acting as the personal information controller, collects, processes, stores, and discloses personal data relating to registered players, prospective players, and website visitors (collectively, "you" or "data subjects").

This Policy applies to all personal data processed in connection with: registration and use of a ph11t account; access to games, promotions, and bonuses on the ph11t platform; payment transactions and account funding; customer support interactions; and use of the ph11t website, including any cookies or tracking technologies deployed on ph11t.club.

ph11t is committed to collecting, processing, and protecting personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its implementing rules and regulations, and relevant issuances of the National Privacy Commission of the Philippines. Where ph11t processes data of individuals located in other jurisdictions, ph11t applies the higher applicable standard of data protection.

ph11t collects the following categories of personal data, depending on your interaction with the platform:

ph11t does not collect or process sensitive personal information as defined under Section 3(l) of the DPA 2012 (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless it is strictly necessary for a specific regulatory purpose and with your explicit consent.

ph11t collects personal data through the following means:

3.1 Direct Collection

Information you provide directly to ph11t when you: create a ph11t account; complete identity verification (KYC); make a deposit or request a withdrawal; contact ph11t customer support; respond to a survey or promotion; or update your account profile and preferences.

3.2 Automated Collection

When you access ph11t.club or use the ph11t gaming platform, certain technical and usage data is collected automatically through cookies, web beacons, pixel tags, and similar technologies. This includes your device IP address, browser characteristics, session timestamps, and pages visited. For full details, see Section 8 (Cookies & Tracking).

3.3 Third-Party Sources

ph11t may receive personal data about you from the following third-party sources, where permitted by applicable law:

• Payment service providers: GCash, Maya, BDO, BPI, Metrobank, and others — to confirm transaction details and verify account ownership;
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and check against regulatory watchlists;
• Fraud prevention services: Industry fraud detection databases and shared intelligence networks operated under applicable data sharing agreements;
• Regulatory authorities: PAGCOR and other competent Philippine government agencies, where required for licensing compliance.

ph11t processes personal data on one or more of the following lawful bases as prescribed by the DPA 2012 and its implementing rules:

• Contractual necessity: Processing required to perform the contract between you and ph11t — i.e., to provide you with a gaming account, process your bets, and pay out winnings;
• Legal obligation: Processing necessary to comply with ph11t's legal obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the DPA 2012;
• Legitimate interests: Processing for ph11t's legitimate business interests, including fraud prevention, security monitoring, and improving the platform — provided these interests are not overridden by your rights and freedoms;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — for example, in connection with optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

ph11t uses the personal data it collects for the following purposes:

5.1 Account and Service Delivery

To create and maintain your ph11t player account; to authenticate your identity at login; to process deposits and withdrawals through GCash, Maya, BDO, BPI, Metrobank, and other supported payment methods; to deliver the gaming services you request; and to send you service-related communications such as account confirmation, transaction receipts, and security alerts.

5.2 Regulatory Compliance and Legal Obligations

To verify that you meet ph11t's age requirement of 21 years or above, as mandated by PAGCOR regulations; to conduct AML and fraud screening as required by the Anti-Money Laundering Act and related regulations; to maintain records required by PAGCOR and other regulatory authorities; and to cooperate with lawful requests from competent Philippine government authorities.

5.3 Responsible Gaming

To monitor gaming activity for indicators of problem gambling behavior; to apply deposit limits, loss limits, and other responsible gaming controls you have activated; to enforce self-exclusion and cool-off periods; and to contact you if your gaming patterns suggest a need for responsible gaming support.

5.4 Security and Fraud Prevention

To detect, investigate, and prevent fraudulent transactions, account takeover attempts, collusion, money laundering, and other prohibited activities on the ph11t platform; to monitor for suspicious login activity; and to verify the integrity of financial transactions.

5.5 Platform Improvement

To analyse usage data and gaming activity in aggregate and anonymised form to improve the ph11t platform, develop new features, optimise performance on Philippine mobile networks, and personalise the gaming experience where you have consented to this.

5.6 Marketing Communications

To send you promotions, bonuses, and marketing communications about ph11t services where you have provided consent to receive such communications. You may opt out of marketing communications at any time by contacting ph11t support or using the unsubscribe mechanism in any marketing email.

ph11t does not sell, rent, or trade your personal data. ph11t may share your personal data with third parties only in the following circumstances:

• Service providers and data processors: Third-party companies engaged by ph11t to provide specific services — including payment processing (GCash, Maya, banks), identity verification, KYC/AML screening, fraud detection, IT infrastructure, and customer support technology — are granted access to only the personal data necessary to perform their contracted function and are bound by data processing agreements requiring them to protect your data in accordance with the DPA 2012;
• Game providers: The providers of games available on the ph11t platform (including RNG and live dealer game studios) may receive limited technical data necessary for game delivery and fair play verification, but do not receive personal identity information;
• Regulatory and government authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other competent Philippine authorities, where disclosure is required by law or a valid legal process;
• Law enforcement: Philippine law enforcement agencies, where ph11t is required or permitted to disclose information in connection with a criminal investigation, court order, or other lawful authority;
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of ph11t's business assets, personal data may be transferred to the successor entity, provided that the successor is bound by privacy obligations consistent with this Policy;
• With your consent: In any other circumstance where you have given your explicit prior consent to the disclosure.

ph11t retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention principles apply:

• Active account data: Personal data associated with an active ph11t account is retained for the duration of the account relationship and for a minimum period after account closure as required by PAGCOR regulations and AML record-keeping requirements;
• KYC and AML records: Identity verification documents and AML screening records are retained for a minimum period of five (5) years following the end of the account relationship, in compliance with the Anti-Money Laundering Act;
• Transaction records: Financial transaction records are retained for a minimum of five (5) years following the transaction date, in compliance with applicable financial record-keeping obligations;
• Customer support communications: Records of customer support interactions are retained for a period sufficient to resolve any related disputes and comply with complaint-handling obligations;
• Cookies and technical data: Session cookies expire when you close your browser. Persistent cookies are retained for the period specified in ph11t's cookie settings, not exceeding twelve (12) months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with ph11t's data disposal procedures. Anonymised data — which no longer identifies any individual — may be retained indefinitely for statistical and research purposes.

ph11t uses cookies and similar tracking technologies on ph11t.club to operate the platform, ensure security, and improve the user experience for Filipino players across all devices and networks.

8.1 Types of Cookies Used by ph11t

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will impair your ability to log in and use core ph11t features. ph11t does not use third-party advertising or retargeting cookies.

ph11t implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your device and ph11t's servers is encrypted using 256-bit SSL/TLS protocols;
• Encryption at rest: Sensitive data stored in ph11t's systems, including KYC documents and financial records, is encrypted at rest using industry-standard encryption algorithms;
• Access controls: Access to personal data is restricted to ph11t employees and authorised contractors who have a legitimate need to process it. Access is governed by role-based access controls and audited regularly;
• Two-factor authentication: ph11t supports and encourages 2FA for all player accounts, and enforces 2FA for internal staff access to systems containing personal data;
• Security monitoring: ph11t operates continuous security monitoring of its platform for intrusion attempts, anomalous activity, and data breach indicators;
• Penetration testing: ph11t's platform undergoes regular security assessments and penetration testing by qualified information security professionals;
• Staff training: ph11t employees who handle personal data are trained in data protection obligations and security practices.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph11t. ph11t will respond to all valid requests within the timeframes prescribed by NPC regulations:

To exercise any of these rights, please contact ph11t's Data Protection Officer via email at [email protected], clearly stating your request and including sufficient information to verify your identity. ph11t may request identity verification before processing any data subject rights request.

If you are not satisfied with ph11t's response to your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

The ph11t platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR regulations governing online gaming in the Philippines. ph11t does not knowingly collect personal data from individuals below the age of 21.

ph11t employs age verification procedures during account registration to enforce this requirement. Where ph11t discovers or is notified that personal data has been collected from an individual who does not meet the minimum age requirement, ph11t will promptly close the associated account, delete the personal data so collected, and return any funds in the account to their source in accordance with applicable procedures.

If you are a parent or guardian and believe that a minor has registered a ph11t account or provided personal data to ph11t without your knowledge, please contact ph11t support immediately via live chat or at [email protected].

ph11t may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or operational requirements. When material changes are made, ph11t will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players by email or in-platform notification prior to the changes taking effect.

ph11t recommends that you review this Privacy Policy periodically. Your continued use of the ph11t platform following the posting of an updated Policy constitutes your acknowledgment of the revised terms.

ph11t has designated a Data Protection Officer (DPO) as required under the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or ph11t's handling of your personal data, you may contact the DPO through the following channels:

• Email: [email protected] — please mark your subject line as "Data Privacy Request" or "Attention: DPO" to ensure prompt routing to the correct team;
• Live chat: Available 24 hours a day, 7 days a week via the live chat function on ph11t.club. For data privacy matters, please identify your enquiry as a privacy request at the outset of the conversation.

ph11t aims to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within the timeframes stipulated by the NPC. For complex data subject rights requests, ph11t will provide a response or update within thirty (30) calendar days of receipt of a complete and verifiable request.

If you are not satisfied with how ph11t has handled your privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines, which can be reached through its official website at privacy.gov.ph.