ph2 Privacy Policy

1 Data Controller & Data Protection Officer

ph2 ("the Company", "we", "us", "our"), operator of the online gaming platform accessible at ph2.bio, is the Data Controller responsible for the personal data of its registered players and platform visitors in accordance with the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations.

ph2 has designated a Data Protection Officer (DPO) responsible for overseeing the Company's compliance with RA 10173, the National Privacy Commission (NPC) issuances, and this Policy. Inquiries or concerns regarding the processing of your personal data may be directed to the DPO via the contact details provided in Section 15 of this Policy.

2 Personal Data We Collect

ph2 collects the following categories of personal data in connection with the registration and operation of player accounts:

Identity Data:

• Full legal name as it appears on a government-issued Philippine identification document
• Date of birth (for age verification — players must be 21 years of age or older)
• Gender
• Nationality and citizenship
• Government-issued ID number (e.g., Philippine National ID, UMID, passport, driver's license)

Contact Data:

• Residential address including barangay, city/municipality, province, and postal code
• Primary email address
• Philippine mobile number

Financial Data:

• GCash mobile number and account reference identifiers (ph2 does not store full GCash credentials)
• PayMaya account reference identifiers
• Bank account names, account numbers, and bank names (BDO, BPI, Metrobank, and others) where provided for withdrawal processing
• Cryptocurrency wallet addresses where applicable
• Deposit and withdrawal transaction history

Gaming Activity Data:

• Game session records including games played, wagers placed, outcomes, and timestamps
• Account balance history
• Bonus and promotion participation records
• Responsible gaming tool activations (deposit limits, self-exclusion periods, cooling-off periods)

Technical & Usage Data:

• IP addresses and approximate geolocation data derived from IP
• Device type, operating system, browser type and version
• Session duration and page interaction data
• Login timestamps and access logs

Communication Data:

• Customer support chat transcripts and support ticket records
• Email correspondence with ph2
• Survey or feedback responses where voluntarily submitted

3 How We Collect Personal Data

ph2 collects personal data through the following channels:

• Direct collection: Information you provide during account registration, KYC verification, deposit and withdrawal requests, customer support interactions, or promotional form submissions.
• Automated collection: Technical and usage data collected automatically through cookies, session tracking technologies, server logs, and device fingerprinting when you access the ph2 platform.
• Third-party collection: Identity verification and AML screening data received from KYC service providers, payment processors, and fraud detection services operating under data sharing agreements with ph2.

4 Purposes of Processing

ph2 processes personal data for the following specific and legitimate purposes:

• Account Registration and Management: Creating, maintaining, and administering your ph2 account, including authentication and account security.
• Age Verification and KYC Compliance: Verifying that you meet the PAGCOR-mandated minimum age of 21 years and conducting identity verification as required by applicable Philippine law.
• Payment Processing: Facilitating deposits and withdrawals via GCash, PayMaya, Philippine banks, and cryptocurrency networks.
• Anti-Money Laundering (AML) Compliance: Screening transactions and account activity against AML risk frameworks as required by Philippine law.
• Fraud Prevention and Platform Security: Detecting, investigating, and preventing fraudulent activity, bonus abuse, multi-accounting, and unauthorized access.
• Regulatory Reporting: Providing data to PAGCOR and other competent Philippine authorities in accordance with gaming regulatory requirements.
• Customer Support: Responding to account inquiries, resolving disputes, and providing technical assistance.
• Responsible Gaming: Monitoring gameplay patterns to identify potential problem gambling indicators and administering player-requested responsible gaming tools.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to marketing communications.
• Platform Improvement: Analyzing aggregated and anonymized usage data to improve the ph2 platform's performance, game catalog, and user experience.

5 Legal Basis for Processing

ph2 processes personal data on the following legal bases as recognized under RA 10173:

• Contractual necessity: Processing required to perform the ph2 User Agreement, including account management, payment processing, and gameplay facilitation.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AML requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and the detection of prohibited conduct, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where your explicit opt-in consent has been obtained and may be withdrawn at any time.

6 Cookies & Tracking Technologies

ph2 uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for core platform functionality including authentication session management, security tokens, and load balancing. These cannot be disabled without affecting platform usability.
• Functional cookies: Used to remember your preferences such as language settings and game lobby configuration. Disabling these may reduce your experience quality.
• Analytics cookies: Used to collect aggregated, anonymized data on platform usage to inform product improvements. These are subject to your consent.
• Marketing cookies: Used to deliver relevant promotional communications based on your activity. These are subject to your explicit consent and may be withdrawn.

You may manage cookie preferences through your browser settings or the ph2 cookie preference interface. Withdrawal of consent for non-essential cookies does not affect the lawfulness of processing carried out before withdrawal.

7 Data Sharing & Third-Party Disclosure

ph2 does not sell your personal data. Personal data is shared only in the following circumstances and only to the extent necessary:

• Game providers: JILI, PG Soft, Pragmatic Play, and other licensed game providers receive limited gameplay session data necessary to deliver game functionality. These providers operate under confidentiality agreements.
• Payment processors: GCash, PayMaya, BDO, BPI, Metrobank, and cryptocurrency network operators receive financial data necessary to process your transactions. ph2 does not store full credentials for these services.
• KYC and AML service providers: Identity verification and AML screening providers receive identity data for regulatory compliance purposes under data processing agreements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government bodies may receive data as required by applicable law.
• Legal and professional advisors: Legal counsel, auditors, and other professional advisors may access personal data in connection with legitimate legal, compliance, or audit requirements under strict confidentiality obligations.

8 International Data Transfers

Some of ph2's service providers — including game software providers and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred internationally, ph2 ensures that appropriate safeguards are in place in accordance with RA 10173 and NPC guidelines, including contractual data protection clauses requiring the recipient to maintain data protection standards equivalent to Philippine law requirements.

9 Data Retention

ph2 retains personal data for the periods set out below, or for as long as required by applicable Philippine law, whichever is longer:

• Account data and KYC records: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR record-keeping requirements and AML obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction in compliance with the Anti-Money Laundering Act (AMLA) and its implementing regulations.
• Gaming activity records: Retained for three (3) years from the date of each session to support dispute resolution and regulatory reporting.
• Customer support records: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained until consent is withdrawn plus one (1) year for compliance audit purposes.

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

10 Security Measures

ph2 implements the following technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between player devices and ph2 servers
• Encryption of sensitive data fields (including financial identifiers) at rest using AES-256 or equivalent standards
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Two-factor authentication requirements for all ph2 staff accessing production systems containing personal data
• Regular penetration testing and vulnerability assessments by independent security professionals
• Incident response procedures enabling prompt detection, containment, and notification of personal data breaches in accordance with NPC notification requirements

In the event of a personal data breach that is likely to result in harm to affected data subjects, ph2 will notify the National Privacy Commission and affected players in accordance with NPC Circular No. 16-03 and applicable breach notification requirements.

11 Your Data Subject Rights

As a data subject under RA 10173, you hold the following enforceable rights with respect to the personal data ph2 holds about you. Requests to exercise these rights may be submitted to the ph2 DPO via the contact details in Section 15.

ph2 will respond to verified data subject requests within fifteen (15) calendar days of receipt. Complex requests may require up to thirty (30) days with notification of the extended timeline. Identity verification will be required before processing any data subject request to protect against unauthorized disclosure.

12 Children's Privacy and Age Restriction

The ph2 platform is strictly prohibited for individuals under the age of twenty-one (21) years. ph2 does not knowingly collect personal data from individuals under 21. The minimum gambling age in the Philippines is enforced through mandatory KYC age verification prior to withdrawal processing.

If ph2 discovers that personal data has been collected from an individual under 21, the account will be immediately suspended, the personal data will be deleted (subject to any legal retention requirements), and any deposited funds will be returned to the originating payment method following investigation.

If you are a parent or guardian and believe your child has created a ph2 account, please contact the ph2 DPO immediately via the contact details in Section 15.

13 Marketing Communications

ph2 may send promotional communications — including bonus offers, new game announcements, and platform updates — to players who have provided explicit opt-in consent during registration or account management. Marketing communications are delivered via registered email address and/or registered Philippine mobile number.

You may withdraw consent for marketing communications at any time by: (a) using the unsubscribe link included in all ph2 marketing emails; (b) adjusting communication preferences in your ph2 account dashboard; or (c) contacting ph2 customer support. Withdrawal of marketing consent does not affect the delivery of transactional communications (account notifications, security alerts, payment confirmations) which are necessary for account operation.

14 Amendments to this Policy

ph2 reserves the right to update this Privacy Policy at any time to reflect changes in processing activities, applicable law, or NPC guidance. Material changes will be communicated to registered players via the registered email address or through a notification displayed upon login with reasonable advance notice.

The current version of this Policy is always available at ph2.bio/privacy-policy. The "Last Updated" date at the top of this page indicates when the most recent revision was made. Continued use of the ph2 platform following notification of amendments constitutes acceptance of the revised Policy.

15 Contact, DPO & Complaints

For all data privacy inquiries, data subject rights requests, or concerns about ph2's processing of your personal data, please contact the ph2 Data Protection Officer:

• DPO Contact Email: [email protected] (plain text — not a clickable link) — reference "Data Privacy" in your subject line
• Live Support: Available 24/7 via the ph2 platform — ask to be escalated to the DPO for privacy matters

ph2 aims to resolve all data privacy inquiries within fifteen (15) calendar days. If you are not satisfied with ph2's response, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines: