ph2com Privacy Policy

1Introduction

ph2com ("we," "us," "our," or the "Company") operates the online gaming and sports betting platform accessible at ph2com.org and its associated sub-domains and mobile interfaces (the "Platform"). In the course of providing our services to players across the Philippines — from Manila to Cebu, Davao to Iloilo — we necessarily collect and process personal information about the individuals who register and interact with the Platform.

This Privacy Policy describes in detail what personal data ph2com collects, the purposes for which it is processed, how long it is retained, with whom it may be shared, and the rights that data subjects have under Philippine law. This policy applies to all personal data collected through the Platform, our customer support channels, our marketing communications, and any other interaction between you and ph2com.

By registering on ph2com, 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. If you do not consent to this policy, you should not register on or use the ph2com platform.

2Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, ph2com is the personal information controller responsible for the personal data processed through the Platform. ph2com has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data privacy obligations and serving as the point of contact for data subjects exercising their rights.

Correspondence addressed to the ph2com Data Protection Officer should be directed to: [email protected] (plain text — not a link), clearly marked "Attention: Data Protection Officer."

3Personal Data We Collect

ph2com collects personal data through multiple channels, including direct registration inputs, automated technical collection, and third-party verification providers. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name (as it appears on government-issued identification)
• Date of birth (for age verification — must be 21 years of age or older)
• Email address and mobile number
• Home address (province, city/municipality, barangay)
• Username and encrypted password
• Government-issued ID number (UMID, PhilHealth ID, Driver's License, Passport, or Postal ID)
• Selfie or photograph submitted for identity verification

3.2 Financial & Transaction Data

• GCash or Maya mobile wallet account identifiers (tokenized references only — ph2com does not store full wallet credentials)
• Bank account details (for bank transfer transactions via BPI, BDO, or Metrobank) — stored only in tokenized or masked form
• Deposit and withdrawal transaction history, amounts, timestamps, and reference numbers
• Bonus credit and wagering activity records

3.3 Gaming Activity Data

• Game session records (games played, bets placed, outcomes, duration)
• Bingo card purchases and draw participation records
• Sportsbook wager history (PBA, NBA, UFC, Premier League, sabong, etc.)
• Responsible gaming tool usage (deposit limit changes, self-exclusion requests, session reminders)

3.4 Technical & Device Data

• IP address and approximate geolocation (province/city level only)
• Device type, operating system, and browser version
• Device fingerprint identifiers (used for fraud detection and duplicate account prevention)
• Session tokens and login timestamps
• Cookie identifiers (see Section 7)

3.5 Communications Data

• Customer support chat and email correspondence records
• Survey responses and feedback submissions
• Marketing communication preferences and opt-in/opt-out records

4How ph2com Uses Your Personal Data

ph2com does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where such processing is required by law or explicitly consented to by you.

5Legal Basis for Processing

ph2com processes personal data under the following legal bases as recognized by RA 10173 and its Implementing Rules and Regulations:

• Consent: Processing activities where you have given explicit consent, including marketing communications and optional platform features.
• Contract Performance: Processing necessary to perform our obligations under the Terms & Conditions you accepted upon registration — including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulatory requirements, the Anti-Money Laundering Act (AMLA), and RA 10173 itself.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and business analytics, where these interests are balanced against your rights and do not override them.

6Data Sharing & Disclosure

ph2com does not sell your personal data to any third party. 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 agreements:

• Game Content Providers: Licensed game software providers (e.g., JILI, PG Soft, Pragmatic Play) receive limited session and transaction data necessary to facilitate gameplay and resolve game disputes.
• Payment Processors: GCash (Mynt), Maya (Paymaya Philippines), and banking partners receive transactional data necessary to process deposits and withdrawals securely.
• KYC & Identity Verification Providers: Third-party identity verification services receive identity document data solely for the purpose of confirming your age and identity during the KYC process.
• Fraud Detection Services: Specialist fraud prevention providers receive device and behavioral data to identify suspicious activity and protect the platform and its players.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies may receive data as required by law or regulatory directive.
• Legal and Professional Advisors: In connection with legal proceedings, compliance audits, or regulatory investigations, ph2com's legal counsel and external auditors may have access to relevant data under strict confidentiality obligations.

All third parties with whom ph2com shares personal data are contractually required to process such data only for the specified purpose, to implement appropriate security measures, and to comply with RA 10173.

7Cookies & Tracking Technologies

ph2com uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for core platform functionality — maintaining your logged-in session, securing your account, and ensuring the platform loads correctly. These cannot be disabled without impairing Platform use.
• Functional Cookies: Remember your preferences such as language, display settings, and game lobby filters.
• Analytics Cookies: Collect anonymized data on how players navigate the Platform, which games are most popular, and where technical errors occur — used to improve the player experience.
• Fraud Prevention Tokens: Short-lived session tokens used to detect and prevent account takeover, duplicate registrations, and automated bot activity.

ph2com does not use third-party advertising or behavioral tracking cookies. You may configure your browser to refuse cookies, though this may affect certain Platform features. By continuing to use the ph2com Platform, you consent to the use of essential and functional cookies as described above.

8Data Retention

ph2com retains your personal data for the period necessary to fulfill the purposes described in this Privacy Policy and to comply with our legal obligations. Specific retention periods are as follows:

• Account and identity data: Retained for the duration of your active account plus five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the AMLA.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, or longer if required by AMLC regulations.
• Gaming activity records: Retained for three (3) years following the game session date.
• Customer support communications: Retained for two (2) years from the date of the last interaction in a given ticket or thread.
• Marketing consent records: Retained for the duration of your consent or until withdrawn, plus three (3) years thereafter as evidence of consent.

Upon expiry of applicable retention periods, personal data is securely deleted or permanently anonymized in a manner that prevents re-identification.

9Data Security

ph2com implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph2com servers
• At-rest encryption for sensitive personal and financial data stored in ph2com databases
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Multi-factor authentication for all ph2com administrative system access
• Regular penetration testing and third-party security audits of the Platform infrastructure
• Tokenization of payment instrument details — ph2com does not store raw GCash numbers or bank account credentials
• 24/7 intrusion detection and real-time security monitoring

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph2com will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach and will notify affected data subjects without undue delay, in accordance with RA 10173.

10Your Rights as a Data Subject

Under the Philippine Data Privacy Act (RA 10173), you have the following rights with respect to your personal data held by ph2com:

To exercise any of the above rights, submit a written request to ph2com's Data Protection Officer at [email protected] (plain text — not a link), clearly stating the right you wish to exercise and your account details. ph2com will respond within fifteen (15) business days. Identity verification may be required before your request is processed.

11Children's Privacy and Underage Access

The ph2com platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with PAGCOR regulations. ph2com does not knowingly collect personal data from individuals under the age of 21. If ph2com becomes aware that personal data has been collected from an individual under the age of 21, that data will be deleted immediately and the associated account will be permanently closed.

If you are a parent or guardian and believe that a minor in your care has registered on ph2com or provided personal information to the Platform, please contact our customer support team immediately at [email protected] (plain text — not a link).

12Cross-Border Data Transfers

Some of ph2com's third-party service providers — including international game content providers and cloud infrastructure partners — may process personal data outside the Republic of the Philippines. Where such transfers occur, ph2com ensures that the receiving entity provides a level of data protection at least equivalent to that required by RA 10173, through contractual clauses, adequacy assessments, or other lawful transfer mechanisms approved by the National Privacy Commission.

ph2com does not transfer personal data to countries or territories that do not provide adequate protection for personal data without implementing appropriate safeguards.

13Updates to This Privacy Policy

ph2com reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or the services we offer. Material changes to this policy will be notified to registered players via email or in-platform notification at least seven (7) days before the updated policy takes effect. The "Last updated" date at the top of this policy will always reflect the date of the most recent revision.

Your continued use of the ph2com platform following the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this policy periodically to stay informed about how ph2com protects your personal data.

14Contact & Complaints

If you have questions, concerns, or complaints about how ph2com handles your personal data, or if you wish to exercise your data subject rights, please contact us through the following channels:

• Email (Data Privacy matters): [email protected] — marked "Attention: Data Protection Officer" (plain text — not a link)
• Live Chat: Available 24/7 on ph2com.org for general account and privacy queries

If you are not satisfied with ph2com's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the regulatory authority responsible for enforcing RA 10173.