Privacy Policy

1. Introduction

ph11t ("ph11t", "we", "us", "our") is committed to protecting the privacy and personal data of all users ("you", "your") of the ph11t online gaming platform accessible at ph11t.app (the "Platform"). This Privacy Policy describes how ph11t collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines. By registering for or using the ph11t Platform, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.

This Privacy Policy should be read together with our Terms & Conditions, which govern your use of the Platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

2. Personal Data We Collect

ph11t collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

2.1 Registration and Identity Data

• Full legal name, date of birth, and nationality
• Government-issued identification number (e.g., PhilSys ID, passport, driver's licence)
• Email address, mobile number, and residential address
• Username and encrypted password
• Selfie or photograph for identity verification purposes

2.2 Financial and Transaction Data

• GCash account number, PayMaya account details, or bank account information (BPI, BDO, Metrobank, and others)
• Deposit and withdrawal history, transaction amounts, and timestamps
• Bonus and promotional activity records

2.3 Gaming Activity Data

• Game session logs, bet history, win/loss records, and wagering patterns
• Responsible gaming tool usage (deposit limits, self-exclusion requests, cooling-off periods)

2.4 Technical and Device Data

• IP address, device type, operating system, and browser type
• Cookies, session tokens, and similar tracking technologies
• Platform access logs, including login timestamps and session duration

2.5 Communications Data

• Records of your communications with ph11t customer support, including live chat transcripts and email correspondence
• Survey responses, feedback submissions, and promotional opt-in records

ph11t does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive information is collected (such as government ID numbers), it is handled with the highest level of security and access controls.

3. How We Use Your Personal Data

ph11t uses your personal data for the following purposes:

ph11t will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

4. Legal Basis for Processing

ph11t processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform our contract with you — i.e., to provide the ph11t gaming platform and related services you have registered for.
• Legal obligation: Processing is required to comply with applicable laws and regulations, including PAGCOR licensing conditions, AML obligations, and NPC guidelines.
• Legitimate interests: Processing is necessary for ph11t's legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided those interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

ph11t does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

5.1 Service Providers

ph11t engages trusted third-party service providers to assist in operating the Platform, including payment processors, KYC verification providers, cloud hosting providers, and customer support technology vendors. These providers are contractually bound to process your data only on ph11t's instructions and in accordance with applicable data protection laws.

5.2 Regulatory and Law Enforcement Authorities

ph11t may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent authorities where required by law, court order, or regulatory directive. ph11t will notify you of such disclosures where legally permitted to do so.

5.3 Game and Technology Partners

Certain game providers and technology partners integrated into the ph11t Platform may receive limited technical data (such as session tokens or anonymised player identifiers) necessary to deliver their services. These partners are subject to data processing agreements with ph11t.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of ph11t's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

6. Cookies and Tracking Technologies

ph11t uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including maintaining your ph11t Login session and security tokens. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, helping us improve performance and usability.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and measure the effectiveness of our marketing campaigns.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

7. Data Retention

ph11t retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting obligations. 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 and AML requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• Gaming activity logs: Retained for a minimum of 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, unless a longer period is required for dispute resolution.
• 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, ph11t will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8. Data Security

ph11t implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the ph11t Platform.
• Encryption of sensitive data at rest, including financial information and government identification details.
• Role-based access controls ensuring that only authorised ph11t personnel can access personal data on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform infrastructure.
• Multi-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Incident response procedures to detect, report, and address personal data breaches in accordance with NPC notification requirements.

While ph11t takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your ph11t Login credentials and for notifying us immediately if you suspect any unauthorised access to your account.

9. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph11t:

• Right to be informed: You have 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: You may request a copy of the personal data ph11t holds about you, along with information about how it is being used.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You may 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 may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines 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 in Section 13. ph11t will respond to all verified requests within thirty (30) days of receipt, in accordance with NPC guidelines.

10. Children's Privacy

The ph11t Platform is strictly intended for persons who are at least 21 years of age, as required by PAGCOR regulations. ph11t does not knowingly collect personal data from individuals under the age of 21. If ph11t becomes aware that personal data has been collected from a person under 21, the relevant account will be immediately suspended and the data will be deleted in accordance with applicable law.

If you are a parent or guardian and believe that a minor has registered on the ph11t Platform, please contact our support team immediately so that we can take appropriate action.

11. International Data Transfers

ph11t primarily stores and processes your personal data within the Philippines. In certain circumstances, your data may be transferred to, stored in, or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international game technology partners.

Where such transfers occur, ph11t ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law. These safeguards may include contractual data processing agreements incorporating standard data protection clauses approved by the NPC, or transfers to jurisdictions that have been assessed as providing an adequate level of data protection.

12. Changes to This Privacy Policy

ph11t reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Where changes are material, ph11t will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the ph11t Platform following the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about how ph11t protects your data.

13. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by ph11t, please contact our Data Protection Officer (DPO):

ph11t will acknowledge all data privacy requests within five (5) business days and provide a full response within thirty (30) days, in accordance with NPC guidelines. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.