ph385 Privacy Policy

1 Introduction

1.1 This Privacy Policy ("Policy") describes how ph385 ("ph385", "we", "us", or "our") collects, uses, stores, discloses, and otherwise processes the personal data of individuals ("data subjects", "you", or "your") who interact with the ph385 online casino and sports betting platform accessible at ph385.cam (the "Platform").

1.2 This Policy applies to all personal data collected through the Platform — including through the account registration process, the ph385 Login interface, deposits and withdrawals via GCash and other Philippine payment channels, gameplay activity, live chat and email communications with ph385 support, and any other interaction with the Platform or ph385's services.

1.3 ph385 is committed to protecting the privacy and personal data of all individuals who use the Platform, in compliance with Republic Act No. 10173, known as the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission of the Philippines ("NPC").

1.4 By accessing the Platform or registering an account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform.

2 Who We Are

2.1 ph385 is a PAGCOR-licensed online casino and sports betting operator serving the Philippine market. The Platform is operated at ph385.cam and is regulated by the Philippine Amusement and Gaming Corporation ("PAGCOR").

2.2 For the purposes of the Philippine Data Privacy Act, ph385 acts as the personal information controller in respect of the personal data it collects and processes from players and other data subjects. ph385's designated Data Protection Officer ("DPO") can be reached at the contact details provided in Section 16 of this Policy.

3 Personal Data We Collect

3.1 ph385 collects the following categories of personal data depending on the nature of your interaction with the Platform:

Registration and Identity Data

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (used to verify the 21+ age requirement under PAGCOR regulations);
• Email address and Philippine mobile number (Globe, Smart, or DITO) used for account authentication, two-factor verification, and communications;
• Username and encrypted password credentials;
• Residential address within the Philippines.

KYC and Verification Data

• Scanned or photographed copies of government-issued Philippine identification documents (accepted: Philippine passport, driver's license, SSS ID, UMID, PhilHealth ID, Voter's ID);
• Selfie or liveness-check image used for identity matching during KYC verification;
• Proof of registered payment method (e.g., GCash account screenshot showing registered name and mobile number);
• Source of funds documentation where required by PAGCOR anti-money laundering compliance thresholds.

Financial and Transaction Data

• GCash mobile number and transaction reference numbers;
• PayMaya account identifiers;
• BPI, BDO, or Metrobank account details where used as a payment method;
• Visa or Mastercard partial card details (first six and last four digits only — full card numbers are never stored by ph385);
• Cryptocurrency wallet addresses where applicable;
• Complete records of all deposits, withdrawals, bonuses, wagers, and account balance movements.

Gaming Activity Data

• Game session records including games played, bet amounts, outcomes, and session duration;
• Sports betting records including markets wagered on, odds accepted, and settlement outcomes;
• Responsible gaming tool settings including deposit limits, loss limits, session reminders, and any self-exclusion or cooling-off periods activated.

Technical and Device Data

• IP address and approximate geographic location derived from IP;
• Device type, model, and operating system;
• Browser type and version;
• Session logs and access timestamps;
• Cookies and similar tracking technologies as described in Section 9.

Communications Data

• Content of live chat conversations with ph385 support;
• Email correspondence with ph385 support or compliance teams;
• Complaint and dispute records.

4 How We Collect Your Data

4.1 Directly from you — when you register an account on the Platform, complete the KYC verification process, make a deposit or withdrawal, engage in gaming activity, contact ph385 support, or submit any form on the Platform.

4.2 Automatically — through the Platform's technical infrastructure, including server logs, cookies, and similar technologies, when you access or use the Platform. This includes your IP address, session data, and device information.

4.3 From third parties — including payment processors such as GCash (GXI) and PayMaya (Maya Philippines) for payment verification; identity verification service providers used in the KYC process; fraud detection and anti-money laundering screening services; and PAGCOR and relevant Philippine government agencies where required by law.

5 Purposes of Processing

5.1 ph385 processes personal data for the following purposes:

• Account creation and management — to register, maintain, and administer your ph385 account, including enabling ph385 Login access;
• Age and identity verification — to confirm that you meet the 21+ age requirement and to verify your identity as required by PAGCOR regulations;
• Payment processing — to process deposits and withdrawals via GCash, PayMaya, Philippine bank transfers, card payments, and cryptocurrency;
• Anti-money laundering and fraud prevention — to screen transactions and account activity for suspicious patterns in compliance with Republic Act No. 9160 (Anti-Money Laundering Act) and PAGCOR's compliance requirements;
• Regulatory compliance — to meet ph385's obligations under PAGCOR's operating license, the Philippine Data Privacy Act, and other applicable Philippine laws;
• Customer support — to respond to inquiries, resolve disputes, and provide assistance through live chat and email;
• Platform security — to detect and prevent unauthorised access, fraud, collusion, and other prohibited conduct on the Platform;
• Responsible gaming — to administer responsible gaming tools including deposit limits, loss limits, cooling-off periods, and self-exclusion, and to monitor for indicators of problem gambling;
• Platform improvement — to analyse aggregate usage patterns to improve Platform performance, game selection, and user experience;
• Marketing communications — to send promotional offers, bonus notifications, and relevant information to players who have opted in to receive such communications, as described in Section 14.

6 Legal Basis for Processing

6.1 ph385 processes personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity — processing required to perform the contract between ph385 and the registered player (i.e., to operate the account, process payments, and deliver gaming services);
• Legal obligation — processing required to comply with PAGCOR licensing conditions, anti-money laundering laws, tax requirements, and other applicable Philippine legislation;
• Legitimate interests — processing carried out for ph385's legitimate interests in operating a secure, fair, and commercially viable gaming platform, where those interests are not overridden by your rights and interests;
• Consent — processing for purposes where your specific, informed, and freely given consent is required and has been obtained, including certain marketing communications.

7 Data Sharing and Disclosure

7.1 ph385 does not sell, rent, or trade personal data to third-party marketers or data brokers under any circumstances.

7.2 ph385 may share personal data with the following categories of recipients where necessary for the purposes described in Section 5:

• PAGCOR and Philippine government agencies — as required by ph385's operating license conditions or by applicable Philippine law, including the Anti-Money Laundering Council (AMLC) and the Bureau of Internal Revenue (BIR);
• Payment service providers — including GXI (GCash), Maya Philippines (PayMaya), acquiring banks, and cryptocurrency payment processors, for the purpose of processing deposits and withdrawals;
• Identity verification providers — third-party KYC and anti-money laundering screening services used to verify player identities and screen transactions;
• Game providers — game studios and providers (such as Evolution Gaming and Pragmatic Play) may receive session data necessary to operate games within the Platform, subject to their own data processing obligations;
• IT and infrastructure providers — cloud hosting, data storage, and cybersecurity service providers who process data on ph385's behalf under appropriate data processing agreements;
• Professional advisers — legal, financial, and compliance advisers who require access to personal data in the context of providing professional services to ph385;
• Law enforcement — where required by a valid court order, legal process, or where ph385 is under a legal obligation to disclose.

7.3 Where ph385 shares personal data with third-party service providers acting as personal information processors, ph385 enters into appropriate data processing agreements ensuring those providers handle personal data only in accordance with ph385's instructions and in compliance with the Philippine Data Privacy Act.

8 Cross-Border Data Transfers

8.1 ph385 primarily processes and stores personal data within the Philippines. However, some of ph385's third-party service providers — including certain cloud infrastructure providers and game studios — may process data in jurisdictions outside the Philippines.

8.2 Where personal data is transferred outside the Philippines, ph385 ensures that appropriate safeguards are in place in accordance with the National Privacy Commission's requirements, including contractual arrangements that impose data protection standards equivalent to those required under Philippine law.

8.3 ph385 does not transfer personal data to jurisdictions that do not provide adequate levels of data protection without implementing appropriate contractual, technical, or organisational safeguards.

9 Cookies and Tracking Technologies

9.1 ph385 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies — essential to the operation of the Platform, including maintaining your login session state, remembering your preferences, and ensuring the security of your account. These cookies cannot be disabled without affecting Platform functionality.
• Analytics cookies — used to collect aggregate information about how players interact with the Platform, enabling ph385 to identify performance issues and improve the user experience. Analytics data is anonymised and not tied to individual player identities.
• Functional cookies — used to remember your settings and preferences on the Platform, such as your preferred game lobby view or responsible gaming dashboard configuration.

9.2 ph385 does not use third-party advertising cookies to serve targeted advertisements to players outside the Platform. Cookies used on the Platform are proprietary to ph385 or to its contracted analytics service providers.

9.3 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the Platform, including the ph385 Login function.

10 Data Retention

10.1 ph385 retains personal data for no longer than is necessary for the purpose for which it was collected, subject to the following retention periods:

• Active account data — retained for the duration of the account's active status;
• Closed account data — retained for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and Philippine anti-money laundering legislation;
• Financial transaction records — retained for a minimum of ten (10) years in compliance with the Anti-Money Laundering Act (Republic Act No. 9160, as amended);
• KYC documentation — retained for five (5) years following the end of the business relationship;
• Support communications — retained for three (3) years for dispute resolution and quality assurance purposes.

10.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identified or identifiable individual.

11 Your Data Subject Rights

11.1 Under the Philippine Data Privacy Act, registered players and other data subjects have the following rights in respect of their personal data held by ph385. To exercise any of these rights, contact ph385's Data Protection Officer using the details in Section 16.

11.2 ph385 will respond to verified data subject requests within fifteen (15) calendar days of receipt, in accordance with the NPC's prescribed timelines. Where a request is complex or high in volume, ph385 may extend this period by a further thirty (30) calendar days with notification to the data subject.

11.3 If you believe ph385 has not handled your personal data in accordance with the Philippine Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12 Security Measures

12.1 ph385 implements the following technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, and destruction:

• TLS 1.3 encryption for all data transmitted between player devices and the ph385 Platform;
• Encrypted storage for sensitive data fields including KYC documents, payment identifiers, and authentication credentials;
• Role-based access controls ensuring that ph385 staff can only access personal data necessary for their specific job function;
• Two-factor authentication available for all player accounts and enforced for all ph385 staff with access to player data systems;
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure;
• Incident response procedures enabling ph385 to identify, contain, and notify affected parties of personal data breaches within the timeframes required by Philippine law.

12.2 In the event of a personal data breach affecting your data, ph385 will notify you and the NPC as required under Section 20 of the Philippine Data Privacy Act and the NPC's breach notification requirements.

13 Children's and Minors' Data

13.1 The ph385 Platform is strictly intended for individuals aged 21 years and above, as mandated by PAGCOR regulations. ph385 does not knowingly collect personal data from individuals under the age of 21.

13.2 If ph385 becomes aware that personal data has been collected from an individual under 21 years of age, it will immediately suspend the associated account, void any transactions conducted through that account, and securely delete the personal data collected, subject to any overriding legal retention obligations.

13.3 If you believe a minor has accessed or registered on the ph385 Platform, please contact ph385's Data Protection Officer immediately using the details in Section 16.

14 Marketing Communications

14.1 ph385 may send promotional communications — including bonus offers, seasonal promotions, and platform updates — to players who have opted in to receive such communications during registration or through their account settings.

14.2 You may withdraw your consent to receive marketing communications at any time by updating your notification preferences in your account settings or by contacting ph385 support. Withdrawal of marketing consent does not affect transactional and account-related communications (such as deposit confirmations, KYC requests, and responsible gaming notifications), which ph385 may send regardless of marketing opt-in status.

14.3 ph385 does not share your personal data with third-party marketers for the purpose of sending unsolicited marketing communications.

15 Changes to This Policy

15.1 ph385 reserves the right to update or amend this Privacy Policy at any time. All changes will be published on this page with the "Last Updated" date revised accordingly. Where changes are material, ph385 will notify registered players via email or in-platform notification prior to the changes taking effect.

15.2 Continued use of the Platform following publication of an updated Policy constitutes acceptance of the revised terms. If you do not agree to the changes, please discontinue use of the Platform and contact ph385 support to arrange account closure.

16 Contact & Data Protection Officer

16.1 ph385 has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with the Philippine Data Privacy Act and for handling data subject requests and privacy-related inquiries.

16.2 To exercise any of your data subject rights, report a potential data breach, or raise any concern regarding ph385's personal data practices, you may contact the ph385 DPO through the following channels:

• Email: [email protected] — please mark your subject line "Data Privacy Request" or "Attention: DPO" so your inquiry is routed correctly;
• Live Chat: Available 24/7 on the ph385 Platform — ask to be connected to the Data Privacy team.

16.3 ph385 will acknowledge all DPO-directed inquiries within two (2) business days and will respond substantively within fifteen (15) calendar days, subject to the extension provisions described in Section 11.2.

16.4 If you are not satisfied with ph385's response to a data privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC).