Privacy Policy

• "ph265," "we," "us," "our" — the ph265 platform and its operating entity.
• "Personal Data" — any information that identifies or could reasonably identify a natural person, including name, mobile number, email address, IP address, device identifiers, financial account details, and behavioral data linked to an identifiable individual.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, and deletion.
• "Data Subject" — the natural person to whom Personal Data relates; in the context of ph265, this primarily refers to registered players and platform visitors.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. ph265 is the Data Controller for Personal Data collected through the ph265 platform.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller, pursuant to a written data processing agreement.
• "NPC" — the National Privacy Commission of the Philippines, the regulatory authority responsible for enforcing the Data Privacy Act of 2012.
• "RA 10173" — Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines, and its implementing rules and regulations.
• "KYC" — Know Your Customer; the identity verification process required by ph265 for regulatory compliance purposes.

ph265 is the Data Controller for all Personal Data collected through the ph265 platform (ph265.org). ph265 operates within the PAGCOR regulatory context governing online gambling services accessible to Philippine residents.

ph265 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and this Privacy Policy. The DPO may be contacted using the contact details provided in Section 15 of this Policy.

ph265 collects the following categories of Personal Data:

ph265 does not collect sensitive personal information (as defined under RA 10173 Section 3(l)) unless specifically required for regulatory compliance purposes, in which case such collection will be disclosed at the point of collection and processed with heightened protective measures.

ph265 collects Personal Data through the following methods:

1. Direct Collection. Information you provide during registration, KYC verification, deposit and withdrawal requests, support communications, or when you update your Account settings on the ph265 platform.
2. Automated Collection. Technical and behavioral data collected automatically when you access the ph265 platform, including via cookies, server logs, and analytics tools. See Section 8 for the ph265 cookie policy.
3. Third-Party Sources. Identity and financial data provided by payment processors (GCash, Maya, BPI, BDO, Metrobank) in connection with transaction processing, and data from fraud detection service providers where ph265 uses such services for account security purposes.
4. KYC Verification Providers. Where ph265 uses third-party KYC verification services to verify identity documents, ph265 receives a verification result and may receive structured data extracted from submitted documents by the provider.

ph265 uses Personal Data for the following purposes:

• Account management: Creating, maintaining, and securing your ph265 account; processing login, OTP verification, and password recovery.
• Service delivery: Processing deposits and withdrawals, providing access to games, crediting bonuses, and managing VIP program participation.
• Identity and age verification: Confirming that you meet the 21+ age requirement and that your identity matches the payment accounts used on ph265, as required by PAGCOR regulatory context.
• Fraud prevention and security: Detecting and preventing unauthorized account access, payment fraud, money laundering, and platform abuse using automated monitoring systems.
• Regulatory compliance: Meeting anti-money laundering (AML), counter-terrorism financing (CTF), and other obligations applicable to online gambling operators in the Philippines.
• Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance via Live Chat and other support channels.
• Responsible gaming: Monitoring for indicators of problematic gambling behavior and applying deposit limits, session restrictions, or other responsible gaming interventions as appropriate.
• Platform improvement: Analyzing aggregated and anonymized behavioral data to improve ph265's game selection, navigation, payment flows, and overall user experience.
• Marketing communications: Sending you promotional offers, bonus notifications, and product updates via SMS or other agreed channels — subject to your communication preferences and applicable opt-out rights.

Under RA 10173, ph265 relies on the following legal bases for processing Personal Data:

1. Contractual necessity: Processing required to perform the contract between ph265 and you — including account creation, transaction processing, game access, and withdrawal fulfillment.
2. Legal obligation: Processing required for compliance with Philippine law, including PAGCOR regulatory requirements, AML/CTF obligations, and tax reporting requirements.
3. Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and product improvement — provided these interests are not overridden by your privacy rights.
4. Consent: Processing for marketing communications, optional analytics participation, and any other processing for which ph265 has obtained your express consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

ph265 shares Personal Data only in the following circumstances:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, USDT infrastructure providers, and Coins.ph receive transaction-related Personal Data necessary to process your deposits and withdrawals. These parties act as independent data controllers for their own payment services.
• Game providers: Third-party game studios (JILI, Pragmatic Play, PG Soft, Evolution Gaming, etc.) receive a session token and anonymized player ID necessary to initialize game sessions. ph265 does not share your full identity data with game providers.
• KYC and fraud detection providers: ph265 uses third-party services for identity document verification and fraud scoring. These providers act as Data Processors under written data processing agreements that comply with RA 10173.
• Regulatory authorities: ph265 discloses Personal Data to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities where required by law or valid legal process.
• Professional advisers: Lawyers, auditors, and other professional advisers retained by ph265 may receive Personal Data under strict confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all assets of ph265, Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

8.1 ph265 uses cookies and similar tracking technologies (including web beacons and local storage) to operate the platform and improve your experience. Cookies are small text files stored on your device by your browser when you access ph265.org.

8.2 ph265 uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function — including authentication session cookies, security tokens, and anti-CSRF tokens. These cannot be disabled without affecting platform functionality.
• Functional cookies: Store your preferences such as language, game lobby filter settings, and responsible gaming configurations across sessions.
• Analytics cookies: Collect anonymized data about how players navigate the ph265 platform, enabling ph265 to identify usability issues and optimize the player experience. ph265 uses privacy-conscious analytics configurations that anonymize IP addresses.
• Security cookies: Used by ph265's fraud detection systems to identify anomalous session behavior, bot activity, and account takeover attempts.

8.3 ph265 does not use third-party advertising cookies or permit advertising networks to track your behavior across the ph265 platform for ad targeting purposes.

8.4 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to or using core features of the ph265 platform.

ph265 retains Personal Data for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to the following retention parameters:

Upon expiry of applicable retention periods, ph265 will securely delete or anonymize Personal Data in accordance with its data disposal procedures.

ph265 implements organizational and technical security measures appropriate to the risk associated with processing player Personal Data in an online gambling context, including:

• Encryption: TLS 1.3 for all data in transit between your device and ph265 servers; AES-256 encryption for sensitive data fields at rest.
• Access controls: Strict role-based access controls limiting employee access to Personal Data on a need-to-know basis, with multi-factor authentication required for all administrative access.
• Intrusion detection: Continuous automated monitoring for unauthorized access attempts, anomalous data access patterns, and known attack signatures.
• Penetration testing: Regular third-party security assessments of the ph265 platform infrastructure.
• Data breach response: ph265 maintains an incident response plan for personal data breaches, including notification procedures to the NPC within 72 hours of breach discovery where required, and notification to affected Data Subjects without undue delay where there is high risk of harm.

Under RA 10173, you have the following enforceable rights with respect to your Personal Data held by ph265:

To exercise any of these rights, contact ph265's Data Protection Officer using the details in Section 15. ph265 will respond to all valid Data Subject rights requests within 30 calendar days of receipt. Complex requests may be extended by a further 30 days with notice. Identity verification will be required before ph265 fulfills any Data Subject rights request.

If you believe ph265 has not handled your Personal Data in accordance with RA 10173, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

If you have reason to believe that a person under 21 has registered on the ph265 platform, please notify ph265 immediately via Live Chat or the contact details in Section 15.

ph265 may transfer Personal Data to third-party service providers located outside the Philippines — including cloud infrastructure providers, KYC verification services, and game studios with data centers in other jurisdictions. Where such transfers occur, ph265 implements appropriate safeguards consistent with RA 10173, including:

• Contractual clauses that impose equivalent data protection obligations on the receiving party;
• Transfer only to jurisdictions or entities that provide an adequate level of protection as determined by the NPC or through contractual mechanisms;
• Limitation of transferred data to the minimum necessary for the specific operational purpose.

You may request information about cross-border transfer safeguards applicable to your Personal Data by contacting ph265's Data Protection Officer.

ph265 may update this Privacy Policy periodically to reflect changes in data practices, legal requirements, or platform features. The "Last Updated" date at the top of this Policy will reflect the most recent revision.

ph265 will provide notice of material changes to this Privacy Policy via a prominent notification on the ph265 platform and, where appropriate, via SMS to your registered Philippine mobile number. Your continued use of the ph265 platform after a revised Privacy Policy is published constitutes your acknowledgment of the changes.

If the changes materially alter the legal basis or scope of processing in a way that requires fresh consent, ph265 will request your consent before the new processing begins.

For all privacy-related inquiries, Data Subject rights requests, or complaints relating to ph265's handling of your Personal Data, contact the ph265 Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Subject line: "Privacy / Data Subject Request" for fastest routing to the DPO team
• Live Chat: Available 24/7 via the ph265 Platform after login. State "Privacy Request" at the start of your chat to be routed to the compliance team.
• Response time: ph265 aims to acknowledge all privacy inquiries within 2 business days and resolve valid Data Subject rights requests within 30 calendar days.