ph35com Privacy Policy

1 Scope and Controller Identity

This Privacy Policy applies to all personal data collected, processed, stored, and used by ph35com in connection with your use of the ph35com website located at https://ph35com.app, its associated mobile-optimized interfaces, and all related gaming and betting services offered through the ph35com Platform (collectively, the "Platform").

ph35com acts as the Personal Information Controller (PIC) as defined under the Data Privacy Act of 2012 (Republic Act No. 10173) with respect to the personal data you provide or that is automatically collected when you access or use the Platform. As a Personal Information Controller, ph35com determines the purposes and means by which your personal data is processed and is responsible for ensuring that such processing is lawful, fair, and transparent.

This Privacy Policy covers data collected from all users, including registered Players, visitors who browse the Platform without registering, and individuals who contact ph35com through its support channels. It applies regardless of whether you access the Platform from Metro Manila, Cebu City, Davao, Quezon City, Makati, or any other location in the Philippines or abroad.

2 Data We Collect

ph35com collects only the personal data that is necessary and proportionate to the purposes described in this Privacy Policy. The categories of personal data we collect are outlined in the table below:

3 How We Collect Your Data

3.1 Data You Provide Directly

The majority of personal data ph35com holds about you is data you provide to us voluntarily at different points in your relationship with the Platform:

• Account Registration: When you create a ph35com Account, you provide your name, date of birth, email address, Philippine mobile number, and residential address.
• KYC Verification: When identity verification is triggered, you submit government-issued identification documents and may provide proof of address and source of funds documentation.
• Payment Transactions: When you make deposits or request withdrawals via GCash, Maya, BPI, BDO, Metrobank, QR Ph, or GrabPay, transaction reference data is generated and linked to your Account.
• Customer Support: When you contact our support team via live chat or email, the content of your communications is recorded and stored to facilitate resolution and for quality assurance purposes.
• Responsible Gaming Requests: When you submit a self-exclusion, cooling-off period, or limit-setting request, we record the details of your request and any documentation provided.

3.2 Data Collected Automatically

When you access the ph35com Platform, certain technical data is collected automatically through server logs, cookies, and similar technologies, including your IP address, approximate geographic location derived from your IP, device identifiers, browser type and version, operating system, pages visited, session duration, and referral URL. See Section 7 for further detail on cookies and tracking technologies.

3.3 Data from Third Parties

ph35com may receive personal data about you from third-party sources in limited circumstances, including: identity verification service providers engaged to assist with KYC processing; payment processors who communicate transaction confirmation data; and fraud detection and anti-money laundering screening services. Data received from these third parties is used solely in accordance with this Privacy Policy and the specific purpose for which it was obtained.

4 Legal Basis for Processing

ph35com processes your personal data on one or more of the following lawful bases, as defined under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary for the performance of our contract with you — specifically, to create and manage your Account, process your deposits and withdrawals, and provide you with access to ph35com's gaming and betting services.
• Legal Obligation: Processing is required to comply with ph35com's obligations under PAGCOR regulatory requirements, the Anti-Money Laundering Act of the Philippines (RA 9160, as amended by RA 10167 and RA 10365), the Anti-Terrorism Financing provisions, and applicable tax laws.
• Legitimate Interests: ph35com processes certain data on the basis of its legitimate interests in preventing fraud, ensuring Platform security, improving service quality, and conducting analytics — where such interests are not overridden by your rights and freedoms.
• Consent: Where ph35com relies on your consent as the legal basis for processing — for example, for optional marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Consent withdrawal requests may be submitted to our support team.

5 How We Use Your Information

ph35com uses the personal data we collect for the following specific purposes:

• Account Management: To create, verify, maintain, and secure your ph35com Account, including processing login requests, resetting passwords, and managing Account settings.
• Identity and Age Verification: To verify that you meet the minimum age requirement of 21 years as required under Philippine law and PAGCOR regulations, and to confirm your identity in accordance with KYC obligations.
• Transaction Processing: To process deposits, withdrawals, and bonus credits accurately and in a timely manner through your chosen Philippine payment method.
• Regulatory Compliance: To fulfil ph35com's obligations under PAGCOR licensing requirements, anti-money laundering regulations, and other applicable Philippine laws, including filing mandatory regulatory reports where required.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming patterns that may indicate problem gambling behavior, to enforce self-exclusion and limit-setting requests, and to provide targeted responsible gaming support where appropriate.
• Customer Support: To respond to your queries, complaints, and account-related requests through our 24/7 live chat and email support channels.
• Platform Improvement: To analyze aggregated and anonymized usage data to understand how Players interact with the Platform, identify technical issues, and improve game offerings, user interface design, and overall Platform performance.
• Marketing Communications: Where you have provided consent, to send you information about ph35com promotions, new game launches, and offers that may be relevant to your interests. You may opt out of marketing communications at any time.

6 Sharing and Disclosure

ph35com does not sell, rent, or trade your personal information to any third party. We share personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

6.1 Service Providers

ph35com engages carefully selected third-party service providers who process personal data on our behalf under written data processing agreements that require them to maintain confidentiality and apply appropriate security measures. These providers include identity verification and KYC processing services, payment gateway operators (including GCash, Maya, BPI, BDO, Metrobank, QR Ph, and GrabPay infrastructure providers), fraud detection and AML screening services, cloud infrastructure and hosting providers, and customer support platform operators.

6.2 Regulatory and Law Enforcement Authorities

ph35com will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), or other Philippine government authorities when required to do so by applicable law, court order, or lawful regulatory demand. ph35com will not voluntarily disclose your data to law enforcement without a valid legal basis.

6.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of ph35com's business assets, personal data held by ph35com may be transferred to the acquiring entity as part of that transaction, subject to the acquiring entity agreeing to be bound by data protection obligations equivalent to those in this Privacy Policy. Players will be notified of any such transfer and of any material change to data processing arrangements that results from it.

7 Cookies and Tracking Technologies

ph35com uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, and analyze how the Platform is used. A cookie is a small text file placed on your device by the ph35com web server when you visit the Platform.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential to the operation of the ph35com Platform. They enable core functionality such as maintaining your login session, preserving your Account settings during navigation, and ensuring secure transmission of your activity. These cookies cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: These cookies allow ph35com to remember choices you make — such as your preferred language, region display settings, and responsible gaming tool configurations — to provide a more personalized experience.
• Analytics Cookies: ph35com uses analytics cookies to collect aggregated, anonymized data about how Players navigate and use the Platform. This data helps us identify popular game categories, optimize page performance, and improve the overall user experience for Filipino players.
• Security Cookies: These cookies support ph35com's fraud detection and account security systems by identifying unusual login patterns, detecting suspicious IP activity, and flagging potential session hijacking attempts.

7.2 Cookie Management

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies will impair the functionality of the ph35com Platform and may prevent you from logging in or accessing your Account. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.

8 Data Security Measures

ph35com implements a comprehensive set of technical, organizational, and physical security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Key security measures include:

• Transport Layer Security (TLS 1.3): All data transmitted between your device and ph35com servers is encrypted in transit using TLS 1.3, the current industry standard for secure web communications.
• Data Encryption at Rest: Sensitive personal data, including identity document scans and financial account references, is encrypted at rest using AES-256 encryption on ph35com's server infrastructure.
• Access Controls: Access to personal data within ph35com is restricted on a strict need-to-know basis. Staff members are granted only the minimum level of data access required to perform their legitimate job functions, and all data access is logged and audited.
• Two-Factor Authentication (2FA): ph35com offers and strongly recommends SMS OTP-based two-factor authentication for all player Accounts. Internal staff systems require 2FA as a mandatory access control measure.
• Vulnerability Management: ph35com conducts regular security vulnerability assessments and penetration testing of its Platform infrastructure to identify and remediate potential security weaknesses proactively.
• Incident Response: ph35com maintains a documented personal data breach response procedure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, ph35com will notify the National Privacy Commission and affected Players in accordance with the timelines prescribed by the Data Privacy Act of 2012 and NPC regulations.

9 Data Retention

ph35com retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable Philippine law or PAGCOR regulations. The following general retention periods apply:

• Account and Identity Data: Retained for a minimum of five (5) years following the closure or termination of your ph35com Account, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by AMLC regulations and BIR record-keeping obligations.
• Gaming Activity Logs: Retained for a minimum of three (3) years, used for dispute resolution, responsible gaming monitoring, and regulatory audit purposes.
• Customer Support Communications: Retained for two (2) years from the date of the last interaction, for quality assurance, dispute resolution, and staff training purposes.
• Marketing Consent Records: Retained for as long as your consent remains active, plus one (1) year following withdrawal of consent, to maintain evidence of compliance.

Upon expiry of the applicable retention period, ph35com will securely delete, anonymize, or pseudonymize your personal data in accordance with its internal data lifecycle management procedures. Where data is anonymized rather than deleted, the resulting anonymized dataset no longer constitutes personal data and may be retained indefinitely for statistical analysis purposes.

10 Your Rights as a Data Subject

As a data subject under the Data Privacy Act of 2012 of the Philippines, you are entitled to the following rights with respect to the personal data ph35com holds about you. ph35com is committed to facilitating the exercise of these rights promptly and without unnecessary barriers:

To exercise any of the above rights, please submit your request in writing to the ph35com Data Protection Officer via email at [email protected] with the subject line "Data Subject Rights Request." ph35com will acknowledge your request within three (3) Philippine business days and will respond substantively within thirty (30) days, or within such shorter period as may be required by applicable NPC guidelines.

11 International Data Transfers

ph35com's primary operations and data processing infrastructure are based in the Philippines. However, some of the third-party service providers engaged by ph35com — including certain cloud infrastructure providers and KYC processing services — may process personal data outside the Philippines.

Where personal data is transferred to a jurisdiction outside the Philippines, ph35com ensures that appropriate safeguards are in place to protect the data in a manner consistent with the requirements of the Data Privacy Act of 2012 and applicable NPC cross-border data transfer regulations. Such safeguards may include contractual clauses approved by the NPC, certification under recognized international data protection frameworks, or processing in jurisdictions that the NPC has recognized as providing an adequate level of data protection.

You may request further information about the specific safeguards applicable to any international data transfer by contacting ph35com's Data Protection Officer at the contact details provided in Section 15.

12 Children and Minors

If ph35com discovers or is notified that an Account has been registered by or on behalf of a person under 21 years of age, we will immediately suspend the Account, investigate the matter, and delete the personal data associated with the minor's Account from our systems, except where retention is required for regulatory reporting purposes related to the underage access incident.

Parents and guardians who believe that a minor under their care may have accessed ph35com are urged to contact our support team immediately at [email protected]. We will treat such reports as urgent and respond within 24 hours.

13 Third-Party Links

The ph35com Platform does not contain links to external third-party websites. All navigation links on ph35com point exclusively to internal pages within the ph35com domain. Accordingly, this Privacy Policy governs all data processing activities within the ph35com Platform comprehensively, and you are not exposed to third-party privacy practices through navigation on ph35com.

Should ph35com introduce any third-party integrations in the future, this Privacy Policy will be updated to reflect the implications for data processing, and Players will be notified in accordance with Section 14.

14 Changes to This Policy

ph35com reviews this Privacy Policy on a regular basis and will update it to reflect changes in our data processing practices, changes in applicable Philippine law or NPC regulations, changes in the services we offer, or recommendations from our Data Protection Officer. The effective date and last updated date at the top of this document will be revised with each update.

When ph35com makes material changes to this Privacy Policy — meaning changes that significantly affect how we process your personal data or the rights available to you — we will provide advance notice to registered Players via in-Platform notification or email to your registered address, at least seven (7) days before the changes take effect where practicable. For non-material clarifications or corrections, we may update the document without advance notice.

Your continued use of the ph35com Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the changes. If you disagree with any material change, you retain the right to request Account closure in accordance with the Terms and Conditions.

15 Contact and DPO Details

ph35com has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact us through any of the following channels:

• Data Protection Officer Email: [email protected] (please use subject line: "Privacy / DPO Inquiry")
• Live Chat Support: Available 24/7 directly on the ph35com Platform — accessible from any page on the site
• Response Language: English and Filipino (Tagalog)
• Target Response Time: Within 3 Philippine business days for acknowledgement; within 30 days for substantive response

If you are not satisfied with ph35com's response to your privacy concern or data subject rights request, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent government authority responsible for enforcing the Data Privacy Act of 2012.