ph2com Privacy Policy

1. Introduction

ph2com ("we," "us," or "our") is committed to protecting the privacy and personal data of all players who use the ph2com online gaming platform ("Platform"). This Privacy Policy describes how ph2com collects, uses, stores, shares, and protects your personal information when you access or use our services at ph2com.com.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC"). By registering an account or using the ph2com Platform, 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.

This Privacy Policy should be read together with ph2com's Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Privacy Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

ph2com is the data controller responsible for your personal data collected through the Platform. As data controller, ph2com determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 and all applicable Philippine data protection regulations.

ph2com has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact the DPO at any time using the contact details provided in Section 15 of this Privacy Policy.

3. Personal Data We Collect

ph2com collects the following categories of personal data from players:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Government-issued ID number (e.g., PhilSys ID, passport, driver's license, SSS, GSIS, or TIN)
• Username and encrypted password

3.2 Contact Data

• Email address
• Mobile phone number (Philippine mobile number)
• Residential address (barangay, city/municipality, province)

3.3 Financial & Payment Data

• GCash or PayMaya account number or registered mobile number
• Bank account details for BPI, BDO, or Metrobank withdrawals (account name and number only)
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Source of funds declarations where required by anti-money laundering regulations

3.4 Gaming & Activity Data

• Game history, including games played, wagers placed, and outcomes
• Bonus and promotion usage history
• Session duration and login timestamps
• Responsible gaming tool usage (deposit limits, session limits, self-exclusion records)

3.5 Technical & Device Data

• IP address and approximate geolocation (province/city level)
• Device type, operating system, and browser type
• Unique device identifiers
• Cookie identifiers and session tokens

3.6 Communications Data

• Records of your communications with ph2com's customer support team, including live chat transcripts and email correspondence
• Survey responses and feedback submitted through the Platform

4. How We Collect Your Data

ph2com collects your personal data through the following means:

• Direct collection: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and device data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and risk data from payment processors; and publicly available information used to verify your identity or comply with anti-money laundering obligations.
• Payment providers: Transaction confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank when you make deposits or withdrawals.

5. How We Use Your Personal Data

ph2com uses your personal data for the following purposes:

ph2com will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.

6. Legal Basis for Processing

ph2com processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including operating your Account, processing transactions, and providing gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Legitimate interests: Processing necessary for ph2com's legitimate business interests, including fraud prevention, platform security, and improving our services, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing & Disclosure

ph2com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

7.1 Service Providers

ph2com engages trusted third-party service providers to assist in operating the Platform, including KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), cloud hosting providers, fraud detection services, and customer support platforms. These providers are contractually bound to process your data only on ph2com's instructions and in accordance with applicable data protection law.

7.2 Regulatory and Law Enforcement Authorities

ph2com may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or other Philippine government authorities where required by law, court order, or regulatory directive. ph2com will notify you of such disclosures where legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of ph2com's assets, your personal data may be transferred to the acquiring entity as part of that transaction. ph2com will notify you prior to your personal data being transferred and becoming subject to a different privacy policy.

7.4 With Your Consent

ph2com may share your personal data with other third parties where you have provided your explicit prior consent to such sharing.

8. Cookies & Tracking Technologies

ph2com uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit ph2com.com. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function, including session management, login authentication, and security. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and game lobby layout, to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the Platform, including pages visited and session duration, to help ph2com improve its services.
• Marketing cookies: Used to deliver relevant promotional content to you based on your gaming activity and preferences, where you have consented to receive marketing communications.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph2com Platform. ph2com does not use cookies to track your activity on third-party websites.

9. Data Retention

ph2com retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• 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 PAGCOR licensing requirements and the Anti-Money Laundering Act.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and BIR regulations.
• Gaming activity data: Retained for three (3) years from the date of the relevant gaming session.
• Customer support communications: Retained for two (2) years from the date of the last communication.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, ph2com will securely delete or anonymize your personal data in accordance with its data disposal procedures.

10. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph2com Platform.
• Encryption of sensitive data at rest, including payment details and government ID numbers.
• Role-based access controls ensuring that ph2com staff can only access personal data necessary for their specific job functions.
• Regular security audits and penetration testing conducted by independent third-party security firms.
• Multi-factor authentication for all ph2com staff accessing systems that contain personal data.
• Continuous monitoring of the Platform for suspicious activity, unauthorized access attempts, and potential data breaches.
• Formal data breach response procedures, including notification to the National Privacy Commission and affected players within the timeframes required by the Data Privacy Act of 2012.

While ph2com takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. ph2com cannot guarantee the absolute security of your data and encourages you to use a strong, unique password for your ph2com Account and to keep your login credentials confidential.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by ph2com:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data ph2com holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data ph2com holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph2com's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on ph2com's legitimate interests.
• 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.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph2com has violated your data privacy rights.

To exercise any of the above rights, please contact ph2com's Data Protection Officer using the contact details in Section 15. ph2com will respond to all data subject requests within fifteen (15) calendar days of receipt, or within such extended period as permitted by the DPA where the request is complex or numerous.

12. Children's Privacy

ph2com's Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. ph2com does not knowingly collect personal data from individuals under the age of 21.

If ph2com becomes aware that it has inadvertently collected personal data from a person under 21 years of age, it will take immediate steps to delete that data and close the associated Account. If you are a parent or guardian and believe that your child has registered on ph2com, please contact our support team immediately using the details in Section 15.

ph2com employs age verification procedures at registration and at the point of first withdrawal to enforce this requirement. Any Account found to belong to a person under 21 years of age will be suspended and all associated funds handled in accordance with applicable Philippine law.

13. Third-Party Links

The ph2com Platform may contain links to third-party websites or services, including payment provider portals. ph2com is not responsible for the privacy practices of any third-party website or service. This Privacy Policy applies solely to personal data collected by ph2com through the ph2com Platform.

ph2com encourages you to review the privacy policies of any third-party websites you visit through links on the Platform. ph2com has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

14. Changes to This Privacy Policy

ph2com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. Where changes are material, ph2com will notify you by email or by posting a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent changes were made. Your continued use of the ph2com Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised Privacy Policy, you must cease using the Platform and may request Account closure.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or ph2com's data processing practices, please contact our Data Protection Officer:

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 of the Philippines through their official channels.