Your Privacy Matters
at PH165

This Privacy Policy explains how PH165 ("we", "our", or "the platform") collects, uses, stores, and protects the personal information of players and visitors on ph165.com. We are committed to protecting the privacy rights of every Filipino player in line with the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules and regulations. By using PH165, you acknowledge and consent to the data practices described in this policy.

We know that privacy is not just a legal requirement — it is a matter of trust. When you share your personal information with PH165, you're trusting us to handle it responsibly. We take that seriously, and this document is our full, honest account of how we do that.

1 Who We Are

PH165 is an online betting and gaming platform serving players in the Philippines. We operate under the necessary authorisations for online gaming in the Philippines, and our operations are subject to applicable Philippine laws including the Data Privacy Act, Anti-Money Laundering Act (AMLA), and regulations issued by the relevant gaming oversight bodies.

For privacy-related concerns, we serve as both the Personal Information Controller and, in certain processing activities, the Personal Information Processor as defined under RA 10173. Our designated Data Protection Officer (DPO) oversees all data handling activities and can be reached through our official support channels.

2 Personal Data We Collect

PH165 collects only the data necessary to run your account and comply with legal obligations. Here is a breakdown of the categories of personal data we process:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued ID details (e.g., PhilSys, passport, driver's license).
• Contact Data: Mobile number, email address, and residential address (barangay, city/municipality, province).
• Account Data: Username, account ID, account creation date, login history, and session information.
• Financial Data: Deposit and withdrawal history, payment method details (GCash number, Maya account, bank account name and partial number, card type and last four digits). We do not store complete card numbers on our servers.
• Transaction Data: Bet history, game logs, bonus redemptions, and referral activity under the Refer a Friend program.
• Technical Data: IP address, device type, browser type and version, operating system, and time zone settings.
• Usage Data: Pages visited, features used, session duration, and navigation patterns on the platform.
• KYC Documents: Copies or photographs of government-issued identification documents submitted for verification purposes.

3 How We Collect Your Data

We collect personal data through several channels:

• Direct submission: Information you provide when you register an account, update your profile, complete KYC verification, submit a support request, or participate in a promotion.
• Transaction activity: Data generated automatically when you deposit, withdraw, place bets, or claim bonuses on PH165.
• Automated technologies: Cookies, web beacons, and similar tracking technologies that record how you interact with our website and mobile interface. See Section 9 for full details on our cookie use.
• Third-party payment providers: When you transact through GCash, Maya, GrabPay, InstaPay, or bank transfers, our payment processors may share transaction confirmation data with us.
• Referral activity: If you were referred to PH165 by another player, we may receive basic information to attribute the referral correctly.

4 How We Use Your Personal Data

PH165 uses your personal data for the following purposes:

• Account management: To create, maintain, and secure your PH165 account.
• Transaction processing: To process deposits and withdrawals via your chosen payment method, and to keep accurate financial records.
• Identity verification: To confirm your eligibility to use the platform and comply with KYC and AML obligations under Philippine law.
• Customer support: To respond to your queries, complaints, and requests effectively and accurately.
• Fraud prevention: To detect and prevent suspicious activity, unauthorized access, and other security threats on the platform.
• Legal compliance: To comply with obligations under RA 10173, AMLA, and applicable gaming regulations, including reporting to regulatory authorities when required.
• Platform improvement: To understand how players use PH165 and improve features, performance, and user experience.
• Communications: To send you account notifications, security alerts, and promotional messages (where you have opted in to receive them).
• Responsible gaming: To monitor betting patterns and reach out when signs of problem gambling are detected, in line with our Responsible Gaming commitments.

5 Legal Basis for Processing

Under RA 10173, PH165 processes your personal data on the following legal grounds:

• Consent: For optional data such as marketing communications and cookie preferences, we rely on your explicit consent, which you can withdraw at any time.
• Contractual necessity: Processing your identity, contact, and financial data is necessary to deliver the platform services you signed up for.
• Legal obligation: We are required to collect and retain certain data under Philippine gaming, AML, and tax regulations.
• Legitimate interests: We process technical and usage data to operate, secure, and improve the platform, provided these interests do not override your fundamental rights.

6 Sharing Your Data

PH165 does not sell your personal data. We do not share your information with advertisers, data brokers, or unrelated third parties. We may share limited data only in the following circumstances:

• Payment processors: To facilitate deposits and withdrawals through GCash, Maya, GrabPay, Coins.ph, InstaPay, PESONet, BDO, BPI, UnionBank, Visa, or Mastercard. These processors handle your payment data under their own privacy policies and security standards.
• Regulatory and law enforcement authorities: When required by law, a court order, or a regulator to disclose information in connection with AML screening, fraud investigations, or gaming licence obligations.
• Technology service providers: Trusted vendors that support our platform infrastructure, cybersecurity, and analytics under strict data processing agreements that prohibit secondary use of your data.
• Business transfers: In the unlikely event of a merger, acquisition, or asset sale, your data may be transferred to the successor entity, subject to the same privacy protections described here.

7 Data Retention

PH165 retains your personal data for as long as your account is active or as required to fulfil the purposes outlined in this policy. Specifically:

• Active account data is retained for the duration of your account's existence on the platform.
• Financial transaction records are retained for a minimum of five (5) years after each transaction, in compliance with AMLA and BIR requirements under Philippine law.
• KYC documents are retained for at least five (5) years from the date of account closure.
• Technical and usage data may be anonymised and retained indefinitely for aggregate analytics purposes, with no link back to individual players.

When retention is no longer required, data is securely deleted or anonymised so it can no longer identify you.

8 How We Protect Your Data

PH165 implements robust technical and organisational measures to protect your personal information from unauthorised access, loss, or misuse. These include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data fields at rest in our databases.
• Strict access controls — only authorised personnel with a defined need can access your personal data.
• Regular security audits, vulnerability assessments, and penetration testing.
• Two-factor authentication (2FA) options for player accounts to add an extra layer of login protection.
• Incident response procedures that trigger immediate notification to affected players and the National Privacy Commission (NPC) in the event of a confirmed data breach, as required by RA 10173.

While we take every reasonable precaution, no digital system is 100% invulnerable. We encourage you to also protect your account by using a strong, unique password and enabling 2FA.

9 Cookies and Tracking Technologies

PH165 uses cookies and similar technologies to improve your browsing experience, keep you logged in, and understand how the platform is used. Here's a quick breakdown:

• Essential cookies: Required for the platform to function — handling sessions, security tokens, and login state. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options.
• Analytics cookies: Help us understand which pages are visited most and how players navigate the site, using aggregated, anonymised data.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the PH165 platform. We do not use cookies to track you across unrelated third-party websites.

10 Your Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act, you have the following rights regarding your personal information held by PH165:

• Right to be informed: Know what personal data we hold about you and how it is being processed — which this policy provides.
• Right of access: Request a copy of the personal data PH165 holds about you.
• Right to rectification: Correct inaccurate or outdated personal information in your account.
• Right to erasure or blocking: Request deletion or restriction of your data where it is no longer necessary for the purpose it was collected, subject to legal retention requirements.
• Right to object: Withdraw consent for data uses based on consent, such as marketing communications.
• Right to data portability: Receive a copy of your data in a structured, commonly used format.
• Right to lodge a complaint: File a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, contact our support team through your PH165 account or email support@ph165.com. We will respond within 15 business days, as required under RA 10173.

11 Children's Privacy

PH165 is strictly an 18+ platform. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that a minor has registered an account or submitted personal information, that account will be immediately closed and the data deleted. If you believe a minor has accessed the platform, please contact us immediately at support@ph165.com.

12 Changes to This Privacy Policy

PH165 may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Any updates will be posted on this page with a revised "Last Updated" date. For material changes, we will make reasonable efforts to notify registered players via email or an in-platform notification before the changes take effect. We recommend reviewing this page periodically to stay informed.

Continued use of PH165 after an updated Privacy Policy is published constitutes your acceptance of the changes. If you disagree with any updated terms, you may request account closure through our support team.

13 Contact Our Data Protection Officer

If you have any questions, concerns, or requests related to this Privacy Policy or your personal data held by PH165, please reach out to us:

• Email: support@ph165.com
• Live Chat: Available 24/7 through your PH165 account dashboard
• Response Time: Within 15 business days for formal data privacy requests

If your concern is not resolved after contacting us, you have the right to file a complaint directly with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph — an independent government body that oversees data privacy rights in the country.

This policy should be read alongside our Terms and Conditions and Responsible Gaming policy, all of which form part of the agreement between you and PH165.