ph11e Privacy Policy

ph11e ("ph11e," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the ph11e online gaming platform. This Privacy Policy describes our practices regarding the collection, use, storage, sharing, and protection of personal data in connection with the ph11e platform and services.

ph11e operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines. ph11e has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with applicable data privacy laws.

This Privacy Policy should be read together with ph11e's Terms and Conditions, which govern your use of the ph11e platform. Capitalized terms not defined in this Privacy Policy have the meanings given to them in the Terms and Conditions.

ph11e collects the following categories of personal data from players and platform visitors:

ph11e does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

ph11e collects personal data through the following means:

• Direct collection: Information you provide when registering for a ph11e account, completing KYC verification, making deposits or withdrawals, contacting ph11e support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the ph11e platform, including through cookies, web beacons, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment data from GCash, PayMaya, and banking partners.

ph11e uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your ph11e account, including processing your registration and verifying your identity.
• Service delivery: To provide access to ph11e games, process deposits and withdrawals, award bonuses, and deliver customer support.
• Legal and regulatory compliance: To comply with Philippine anti-money laundering laws (AMLA), PAGCOR regulatory requirements, tax obligations, and other applicable legal requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the ph11e platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform improvement: To analyze usage patterns, troubleshoot technical issues, and improve the ph11e platform's performance and user experience.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.

ph11e will not use your personal data for any purpose that is incompatible with the purposes described in this Privacy Policy without first obtaining your consent or as otherwise permitted by applicable law.

ph11e processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your ph11e account and deliver gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AMLA, PAGCOR regulations, and tax laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

ph11e does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist ph11e in verifying player identities and conducting AML screening.
• Game software providers: Licensed game developers whose games are hosted on the ph11e platform, to the extent necessary to deliver game services.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities, where required by law or regulatory obligation.
• IT and security service providers: Cloud hosting, cybersecurity, and platform infrastructure providers operating under strict data processing agreements with ph11e.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third parties with whom ph11e shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and ph11e's data protection standards. ph11e does not transfer personal data outside the Philippines except where necessary and in compliance with the DPA's cross-border transfer requirements.

ph11e retains your personal data for as long as your ph11e account is active and for such additional period as is required by applicable law or necessary for legitimate business purposes. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AMLA record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• Gaming history: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes.
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period thereafter for compliance documentation.
• Technical and log data: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, ph11e will securely delete or anonymize your personal data in accordance with our data disposal procedures.

ph11e implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the ph11e platform.
• Encryption of sensitive data at rest, including financial account details and identity documents.
• Role-based access controls limiting ph11e staff access to personal data on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of ph11e systems.
• Multi-factor authentication requirements for ph11e staff accessing systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

ph11e uses cookies and similar tracking technologies on the ph11e platform. Cookies are small text files stored on your device that help ph11e recognize you, remember your preferences, and analyze platform usage. ph11e uses the following types of cookies:

• Strictly necessary cookies: Essential for the ph11e platform to function, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login status to improve your ph11e experience.
• Analytics cookies: Collect anonymized data about how players use the ph11e platform to help us improve performance and content. Used only with your consent.
• Marketing cookies: Used to deliver relevant promotional content about ph11e offers. Used only with your explicit consent.

You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the ph11e platform. For strictly necessary cookies, no consent is required as they are essential to platform operation.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph11e:

To exercise any of these rights, please contact ph11e's Data Protection Officer at the contact details provided in Section 14 of this Privacy Policy. ph11e will respond to all verified data privacy requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

The ph11e platform is strictly intended for individuals who are 21 years of age or older. ph11e does not knowingly collect personal data from persons under the age of 21. If ph11e becomes aware that personal data has been collected from a person under 21, such data will be immediately deleted and the associated account will be suspended.

If you are a parent or guardian and believe that a minor has registered for a ph11e account, please contact ph11e support immediately at the contact details in Section 14 so that we can take appropriate action.

The ph11e platform may contain links to third-party websites or services, such as payment provider portals. ph11e is not responsible for the privacy practices of such third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to data collected by ph11e through the ph11e platform.

ph11e reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform services. When material changes are made, ph11e will notify registered players via email or a prominent notice on the ph11e platform prior to the changes taking effect. The "Last Updated" date at the top of this page will be revised accordingly.

Your continued use of the ph11e platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated Privacy Policy, you should discontinue use of ph11e and may request account closure by contacting ph11e support.

For any questions, concerns, or requests relating to this Privacy Policy or ph11e's data privacy practices, please contact ph11e's Data Protection Officer:

You also have the right to lodge a complaint directly with the Philippine National Privacy Commission (NPC) if you believe your data privacy rights have been violated. Information about the NPC complaints process is available through official Philippine government channels.