ph2 Privacy Policy

1. Introduction

ph2 ("ph2," "we," "us," or "our") operates the online gaming platform accessible at ph2.app and is committed to protecting the privacy and personal data of all users ("Player," "you," or "your"). This Privacy Policy describes how ph2 collects, uses, stores, shares, and protects your personal information in connection with your use of the ph2 Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. By registering an account on ph2 or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Privacy Policy should be read together with ph2's Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference.

2. Personal Data We Collect

ph2 collects personal data that is necessary for the operation of the Platform, compliance with legal obligations, and delivery of a safe and personalized gaming experience. The categories of personal data we collect include:

Registration and Identity Data:

• Full legal name as it appears on a government-issued ID
• Date of birth (for age verification – players must be 21 or older)
• Email address and mobile number
• Residential address (city, province, postal code)
• Username and encrypted password
• Government-issued ID details (for KYC verification)

Financial Data:

• GCash or PayMaya account details (mobile number only; ph2 does not store full wallet credentials)
• Bank account details for BPI, BDO, or Metrobank withdrawals (account name and number)
• Transaction history including deposits, withdrawals, and wager records

Technical and Usage Data:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session logs, login timestamps, and activity records
• Game play history and betting patterns
• Cookie and tracking data (see Section 7)

Communications Data: Records of your communications with ph2 support, including live chat transcripts and email correspondence, are retained for quality assurance and dispute resolution purposes.

3. How We Use Your Personal Data

ph2 processes your personal data only for lawful purposes and only to the extent necessary for those purposes. The specific purposes for which we use your data include:

• Account Management: To create, maintain, and manage your ph2 account, including authentication and account security.
• Age and Identity Verification: To verify that you meet the minimum age requirement of 21 years and to confirm your identity in compliance with applicable regulations.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods in Philippine Peso (₱).
• Gaming Services: To provide access to ph2's game library, record wagers and outcomes, and calculate and credit winnings.
• Legal Compliance: To comply with anti-money laundering (AML) obligations, know-your-customer (KYC) requirements, and other applicable Philippine laws and regulations.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cool-off periods, and self-exclusion.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze usage patterns and improve the performance, security, and features of the ph2 Platform.
• Marketing Communications: To send you promotional offers and updates about ph2, where you have provided consent. You may opt out of marketing communications at any time.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized access, and other security incidents.

4. Legal Basis for Processing

ph2 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and ph2 (i.e., the Terms & Conditions), including account management, payment processing, and game delivery.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, KYC requirements, and gaming regulations.
• Legitimate Interests: Processing is necessary for ph2's legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided such interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Sharing Your Personal Data

ph2 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your financial transactions.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance.
• Game Software Providers: Licensed game developers and studios whose games are hosted on the ph2 Platform, to the extent necessary for game delivery and fairness auditing.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and fraud detection providers engaged to support the technical operation of the Platform.
• Regulatory Authorities: Philippine government agencies and regulators, including the National Privacy Commission, where disclosure is required by law or court order.
• Professional Advisors: Legal, accounting, and auditing firms engaged by ph2, subject to professional confidentiality obligations.

All third-party service providers engaged by ph2 are contractually required to process personal data only in accordance with ph2's instructions and applicable data protection laws. ph2 does not transfer personal data outside the Philippines except where necessary and subject to appropriate safeguards.

6. Data Retention

ph2 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support Communications: Retained for two (2) years from the date of the communication, unless a longer period is required for dispute resolution.
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period thereafter for compliance documentation.

Upon expiry of the applicable retention period, ph2 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

7. Cookies and Tracking Technologies

ph2 uses cookies and similar tracking technologies on the Platform to enhance your experience and support the operation of the site. The types of cookies we use include:

• Essential Cookies: Strictly necessary for the Platform to function, including session management, authentication, and security. These cannot be disabled.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping ph2 identify areas for improvement. These are only set with your consent.
• Preference Cookies: Used to remember your settings and preferences, such as language and display options.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. ph2 does not use third-party advertising cookies or cross-site tracking technologies.

8. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph2:

• Right to be Informed: You have the right to be informed of how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right to Access: You may request a copy of the personal data ph2 holds about you at any time.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph2's legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to ph2's overriding legal or operational requirements.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe ph2 has not handled your personal data in accordance with the DPA.

To exercise any of these rights, please contact ph2's Data Protection Officer at the email address below. ph2 will respond to all verified requests within thirty (30) days of receipt.

9. Data Security

ph2 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• TLS encryption for all data transmitted between your device and ph2 servers.
• AES-256 encryption for sensitive data stored at rest, including financial information and identity documents.
• Multi-factor authentication options for player accounts.
• Regular security audits and penetration testing by independent cybersecurity professionals.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Incident response procedures, including notification to affected players and the NPC within 72 hours of discovering a personal data breach.

While ph2 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying ph2 immediately if you suspect unauthorized access to your account.

10. Changes to This Privacy Policy

ph2 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When we make material changes, we will notify you by posting the updated Privacy Policy on ph2.app and, where appropriate, by sending a notification to your registered email address.

The date of the most recent revision is displayed at the top of this page. Your continued use of the ph2 Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how ph2 protects your personal data.

This Privacy Policy was last updated on January 1, 2026 and supersedes all prior versions.