ph352 Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") is issued by ph352 ("ph352," "we," "us," "our") and applies to all personal data collected, processed, used, stored, and shared in connection with the ph352 online gaming platform accessible at ph352.club, including any associated mobile interfaces and related services.

ph352 is a PAGCOR-licensed online gaming operator. Our operations and data handling practices are governed by the Republic of the Philippines, including specifically Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

This Policy applies to all individuals who interact with ph352 in any capacity, including registered Players, visitors to ph352.club, individuals who contact our customer support, and applicants for any programs or promotions offered on the Platform.

By using the ph352 Platform, you acknowledge that you have read this Policy and understand how your personal data is handled. If you do not agree with any aspect of this Policy, you must discontinue use of the Platform and contact us to close your account.

2. Data Controller Identity

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, ph352 is the Personal Information Controller ("PIC") in respect of all personal data collected from Players and website visitors.

ph352 is a PAGCOR-licensed online gaming platform operating under Philippine law. Our Data Protection Officer ("DPO") can be contacted at [email protected] with the subject line "Data Privacy — DPO Request." Our DPO is responsible for overseeing compliance with this Policy and with the DPA across all ph352 data processing activities.

3. Personal Data We Collect

ph352 collects the following categories of personal data:

3.1 Identity and Registration Data

• Full legal name as it appears on a government-issued Philippine ID
• Date of birth (for age verification — players must be 21 years of age or older)
• Gender
• Philippine residential address
• Nationality and citizenship
• Government-issued ID type and number (Passport, UMID, Driver's License, PhilSys ID, or equivalent)

3.2 Contact Data

• Email address
• Philippine mobile number

3.3 Financial and Payment Data

• GCash registered mobile number and account name (not your GCash PIN)
• Maya / PayMaya account details
• Bank account name, account number, and branch (for bank transfer methods)
• Transaction history including deposits, withdrawals, and wagers
• Source of funds declarations where required by PAGCOR AML regulations

3.4 Gaming and Account Activity Data

• Account login history including dates, times, and IP addresses
• Game play history including games played, bet amounts, outcomes, and session duration
• Bonus and promotion participation history
• Responsible gaming tool settings and self-exclusion status
• Communication records with ph352 customer support

3.5 Technical and Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser type
• Session cookies and session tokens
• Pages visited on ph352.club and interaction patterns

4. How We Collect Your Data

ph352 collects personal data through the following means:

• Direct provision: Information you provide during account registration, KYC verification, payment setup, support interactions, or promotional sign-ups.
• Automated collection: Technical and device data collected automatically when you access and use the ph352 Platform, including through cookies and server logs.
• Payment processors: Transaction confirmation data received from GCash, Maya, BPI, BDO, and other payment providers when you make deposits or withdrawals.
• Game providers: Game session data transmitted from licensed third-party game providers (such as Ezugi) to facilitate real-time gameplay and outcome recording.
• Fraud detection systems: Risk assessment data generated by ph352's fraud prevention systems based on your Platform activity patterns.

5. Purposes and Legal Basis for Processing

ph352 processes your personal data on the following legal bases and for the following purposes:

6. Disclosure of Data to Third Parties

ph352 does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data with the following categories of recipients, strictly to the extent necessary for the stated purpose:

• PAGCOR and Philippine Regulatory Authorities: ph352 is legally obligated to report specified player data and transaction information to PAGCOR under the terms of our gaming license. We also comply with lawful requests from the Anti-Money Laundering Council (AMLC), National Privacy Commission, and other competent Philippine government authorities.
• Payment Processors: Personal and financial data is shared with GCash, Maya, BPI, BDO, and other payment service providers solely to process your deposits and withdrawals. These providers are independent data processors bound by their own privacy policies and applicable Philippine law.
• Game Providers: Limited account and session data is transmitted to licensed game providers (such as Ezugi) to enable gameplay, record outcomes, and manage game wallets. Game providers receive only the minimum data necessary for these technical functions.
• KYC and Identity Verification Services: Identity documents submitted for KYC verification may be processed by contracted third-party identity verification service providers operating under data processing agreements with ph352.
• Fraud Prevention and Security Services: Aggregated or pseudonymized data may be shared with contracted security service providers for fraud detection and platform security purposes.
• Professional Advisors: Legal counsel, auditors, and compliance advisors may access personal data on a strictly need-to-know basis in connection with their professional services to ph352, subject to confidentiality obligations.

7. International Data Transfers

ph352's primary data processing infrastructure is located within the Philippines. However, certain third-party service providers — including game engine providers and cloud infrastructure vendors — may process data in other countries. Where personal data is transferred outside the Philippines, ph352 ensures such transfers comply with the Data Privacy Act of 2012 and NPC issuances, including through the use of data processing agreements that impose equivalent data protection standards.

ph352 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual safeguards.

8. Data Retention

ph352 retains personal data for as long as necessary to fulfil the purpose for which it was collected, subject to the following minimum retention periods imposed by Philippine law and PAGCOR regulations:

• KYC and identity documents: Minimum five (5) years from the date of account closure, as required by the Anti-Money Laundering Act (RA 9160) and PAGCOR compliance requirements.
• Financial transaction records: Minimum five (5) years from the date of each transaction, in accordance with AMLA and BIR record-keeping obligations.
• Gaming activity logs: Minimum three (3) years from the date of each gaming session, for PAGCOR audit and dispute resolution purposes.
• Customer support records: Three (3) years from the date of the last support interaction.
• Marketing consent records: Until consent is withdrawn, plus three (3) years thereafter for proof-of-consent purposes.

Following the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents reconstruction of the original data subject's identity.

9. Security Measures

ph352 implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• TLS/SSL encryption for all data transmitted between your device and ph352 servers;
• Encryption at rest for sensitive data including identity documents and financial records;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication requirements for staff accessing production systems;
• Regular security vulnerability assessments and penetration testing;
• Audit logs of all access to personal data by ph352 staff;
• Physical security controls for data centre and server infrastructure; and
• Staff training on data privacy obligations and security practices.

While ph352 takes reasonable measures to protect your data, no internet transmission or electronic storage system is 100% secure. Players are responsible for maintaining the security of their own Account credentials and should notify ph352 immediately upon suspecting any unauthorized access.

10. Cookies & Tracking Technologies

ph352 uses cookies and similar tracking technologies on ph352.club for the following purposes:

• Strictly Necessary Cookies: Essential for platform operation, including session management, login authentication, and security functions. These cannot be disabled without preventing use of the Platform.
• Functional Cookies: Enable enhanced platform features such as remembering your preferred language, game display settings, and responsible gaming preferences.
• Analytics Cookies: Allow ph352 to understand how the Platform is used in aggregate, which pages are most visited, and how to improve user experience. Analytics data is aggregated and does not identify individual users.
• Fraud Prevention Cookies: Used to identify unusual activity patterns and protect against fraudulent access attempts.

ph352 does not use advertising tracking cookies and does not integrate third-party advertising networks on the Platform. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will affect Platform functionality.

11. Marketing Communications

ph352 may send promotional emails, SMS messages, and in-platform notifications to Players who have provided consent to receive marketing communications during registration or subsequently through Account settings.

You may withdraw your consent to receive marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email from ph352;
• Updating your notification preferences in your ph352 Account settings; or
• Contacting ph352 customer support at [email protected] with a written opt-out request.

Withdrawal of marketing consent does not affect ph352's right to send service-related communications necessary for account management, security alerts, KYC requests, and PAGCOR compliance notifications — these communications are sent on the basis of contractual necessity and legal obligation, not consent.

12. Minors & Age Restriction

ph352 is strictly an adult gaming platform. We do not knowingly collect personal data from individuals under the age of 21. The minimum age for gaming on ph352 is 21 years, in compliance with PAGCOR's minimum age requirements for casino-style gaming in the Philippines.

If ph352 discovers that personal data has been collected from a player who is under 21 years of age, we will immediately suspend the associated Account, void all gaming activity, and delete or securely retain the data in accordance with applicable law pending investigation and any required regulatory reporting.

Parents and guardians are responsible for preventing minors from accessing ph352 and should use appropriate parental control software where shared devices may be used by persons under 21.

13. Your Data Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by ph352:

• Right to be Informed: The right to be notified of the personal data being collected, the purposes of processing, and the period of retention — which this Policy fulfils.
• Right to Access: The right to request a copy of the personal data ph352 holds about you, including information on how it has been processed.
• Right to Correction: The right to dispute and request correction of inaccurate, incomplete, outdated, or misleading personal data. Changes to core identity data are subject to re-verification.
• Right to Erasure or Blocking: The right to request suspension of processing or deletion of your personal data where it is no longer necessary for the purpose it was collected, or where processing is unlawful — subject to overriding legal obligations including PAGCOR and AMLA retention requirements.
• Right to Object: The right to object to processing of your personal data for specific purposes, including direct marketing. Objecting to processing required for contractual performance or legal compliance may affect your ability to use the Platform.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller where technically feasible.
• Right to Damages: The right to claim compensation for actual damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your privacy rights have been violated.

To exercise any of these rights, submit a written request to ph352's Data Protection Officer at [email protected] with the subject line "Data Privacy Request — [Right Being Exercised]." ph352 will acknowledge receipt within 5 business days and respond substantively within 15 business days as required by the NPC.

14. Data Breach Procedures

In the event of a personal data breach that is likely to result in harm to affected individuals, ph352 is committed to complying with the mandatory breach notification requirements under the Data Privacy Act of 2012 and NPC Circular No. 16-03, including:

• Notifying the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with NPC notification requirements;
• Notifying affected Players without undue delay where the breach poses a high risk to their rights and freedoms;
• Providing affected Players with information about the nature of the breach, the categories of data affected, the likely consequences, and the measures taken to address the breach; and
• Maintaining an internal data breach register documenting all breaches, regardless of whether they meet the notification threshold.

15. Amendments to This Policy

ph352 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in Philippine law or NPC issuances, or changes in PAGCOR regulatory requirements. We will provide notice of material changes by posting the updated Policy on ph352.club with a revised "Last Updated" date and, where practicable, by notifying Players by email.

Continued use of the ph352 Platform after the effective date of any amendments constitutes acceptance of the revised Privacy Policy. If you do not accept the amended Policy, you must cease using the Platform and contact ph352 to close your account.

16. Contact Information & Data Protection Officer

For any questions about this Privacy Policy, to exercise your data rights, or to contact ph352's Data Protection Officer, please use the following contact details:

• Email (DPO): [email protected] — Subject: "Data Privacy — DPO Request"
• Live Chat: Available 24/7 within the ph352 Platform for general privacy inquiries (English and Tagalog supported)
• Response Time: Acknowledgement within 5 business days; substantive response within 15 business days

If you are not satisfied with ph352's response to a privacy concern, you may lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.