Privacy Policy – 63phl Gaming Platform

1. Who We Are

63phl ("we," "us," or "our") operates the online gaming platform accessible at https://63phl.app (the "Platform"). We are committed to protecting the privacy and personal data of all users who access or register on our Platform. This Privacy Policy applies to all personal data collected through the Platform, including through account registration, gameplay, financial transactions, customer support interactions, and any other means by which you interact with 63phl.

As a platform serving Filipino users, 63phl operates in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines.

2. Information We Collect

2.1 Information You Provide Directly

When you register for an account, make a deposit or withdrawal, contact customer support, or otherwise interact with the 63phl Platform, we may collect the following categories of personal information:

• Identity Information: Full name, date of birth, nationality, and government-issued identification documents (e.g., Philippine National ID, passport, driver's license, SSS/GSIS ID);
• Contact Information: Email address, mobile number, and residential address (including city, province, and postal code);
• Financial Information: Bank account details, e-wallet information (such as GCash or PayMaya account numbers), transaction history, and source of funds declarations;
• Account Credentials: Username and encrypted password;
• Communications: Records of your correspondence with our customer support team, including live chat transcripts and email exchanges.

2.2 Information Collected Automatically

When you access the 63phl Platform, we automatically collect certain technical and usage information, including:

• Device Information: IP address, device type, operating system, browser type and version, and unique device identifiers;
• Usage Data: Pages visited, games played, session duration, click patterns, and other interaction data;
• Location Data: General geographic location derived from your IP address, used to verify that you are accessing the Platform from a permitted jurisdiction;
• Cookies and Tracking Data: Information collected through cookies, web beacons, and similar technologies as described in Section 6 of this Policy.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including payment processors, identity verification service providers, fraud prevention agencies, and publicly available databases. This information is used to verify your identity, process transactions, and comply with our legal and regulatory obligations.

3. How We Use Your Information

63phl uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your 63phl account, including processing your registration, verifying your identity, and enabling you to access our services;
• Service Delivery: To provide you with access to our gaming products, process deposits and withdrawals, and deliver the features and functionality of the Platform;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Legal and Regulatory Compliance: To comply with applicable laws and regulations, including anti-money laundering (AML) requirements, know-your-customer (KYC) obligations, and responsible gaming mandates;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized access, and other security threats;
• Personalization: To tailor your experience on the Platform, including displaying relevant game recommendations and promotional offers based on your activity;
• Marketing Communications: To send you promotional materials, bonus offers, and updates about 63phl services, subject to your communication preferences;
• Analytics and Improvement: To analyze usage patterns, monitor Platform performance, and improve our products and services;
• Responsible Gaming: To monitor gaming behavior and implement responsible gaming measures, including enforcing deposit limits, cooling-off periods, and self-exclusion requests.

4. Legal Basis for Processing

63phl processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its IRR:

• Contractual Necessity: Processing is necessary to perform our contract with you, including providing access to the Platform and processing financial transactions;
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including AML, KYC, and tax reporting obligations;
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security, and improving our services, provided these interests are not overridden by your rights and freedoms;
• Consent: Where required by law, we will obtain your explicit consent before processing your personal data for specific purposes, such as sending marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Sharing Your Information

5.1 Service Providers

We may share your personal data with trusted third-party service providers who assist us in operating the 63phl Platform and delivering our services. These include payment processors (such as banks and e-wallet providers), identity verification services, cloud hosting providers, customer support platforms, and analytics providers. All service providers are contractually obligated to process your data only on our instructions and in accordance with applicable data protection laws.

5.2 Legal and Regulatory Authorities

We may disclose your personal data to government authorities, law enforcement agencies, regulatory bodies, or courts when required to do so by law, court order, or other legal process. This includes disclosures required under AML regulations and disclosures to the National Privacy Commission in connection with data breach notifications or regulatory inquiries.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business assets, your personal data may be transferred to the acquiring entity as part of the transaction. We will notify you of any such transfer and any changes to this Privacy Policy that may result from it.

5.4 No Sale of Personal Data

63phl does not sell, rent, or trade your personal information to third parties for their own marketing or commercial purposes. Any sharing of your data is limited to what is necessary to operate the Platform and comply with our legal obligations.

6. Cookies and Tracking Technologies

6.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 63phl Platform. They help us recognize your device, remember your preferences, and improve your overall experience. We also use similar technologies such as web beacons, pixel tags, and local storage objects.

6.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function properly, including session management, authentication, and security features. These cannot be disabled;
• Performance Cookies: Collect anonymous information about how visitors use the Platform, helping us identify areas for improvement;
• Functionality Cookies: Remember your preferences and settings, such as language and display options, to provide a more personalized experience;
• Analytics Cookies: Used to understand user behavior and measure the effectiveness of our Platform features and marketing campaigns.

6.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a cookie is set. Please note that disabling certain cookies may affect the functionality of the 63phl Platform and your ability to access certain features.

7. Data Retention

63phl retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. Specifically:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and KYC regulatory requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations;
• Customer Support Records: Retained for two (2) years from the date of your last interaction with our support team;
• Marketing Data: Retained until you withdraw your consent or opt out of marketing communications, after which it will be deleted or anonymized within thirty (30) days.

When your personal data is no longer required, 63phl will securely delete or anonymize it in accordance with our data disposal procedures.

8. Data Security

63phl 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 our servers;
• Encrypted storage of sensitive data, including passwords and financial information;
• Strict access controls limiting data access to authorized personnel on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication options for account access;
• Continuous monitoring of our systems for suspicious activity and potential security threats.

While we take every reasonable precaution to protect your data, no method of transmission over the internet or electronic storage is completely secure. In the unlikely event of a data breach that affects your rights and freedoms, 63phl will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 63phl:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy;
• Right to Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure: You have 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 our legal retention obligations;
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller where technically feasible;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) calendar days, or within such extended period as permitted by applicable law.

10. Children's Privacy

The 63phl Platform is strictly intended for users who are at least twenty-one (21) years of age. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on our Platform, please contact us immediately at the details provided in Section 13.

11. International Data Transfers

In the course of operating the 63phl Platform, your personal data may be transferred to and processed in countries other than the Philippines, including countries where our service providers and technology partners are located. Where such transfers occur, 63phl ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012 and its IRR. These safeguards may include contractual clauses, data processing agreements, and other legally recognized transfer mechanisms.

12. Changes to This Policy

63phl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this Policy, we will notify you by posting a prominent notice on the Platform and, where appropriate, by sending you an email notification. The updated Policy will take effect on the date indicated at the top of this page. Your continued use of the Platform following the effective date of any changes constitutes your acceptance of the revised Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 63phl handles your personal data, please reach out to our Data Protection Officer through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 from your account dashboard on the Platform
• Mailing Address: Data Protection Officer, 63phl Gaming Platform, Metro Manila, Philippines

We are committed to resolving all privacy-related inquiries promptly and transparently. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.