PH94 Privacy Policy

01 About This Policy

This Privacy Policy ("Policy") describes how PH94 ("PH94," "we," "us," or "our") collects, uses, stores, and discloses personal information about individuals ("you," "your," or "Player") who access or use the PH94 online gaming platform at ph94.net and any associated mobile applications (collectively, the "Platform").

PH94 is committed to protecting the privacy and security of your personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as the guidelines issued by the National Privacy Commission (NPC). This Policy should be read alongside our Terms and Conditions, which govern your use of the Platform.

By registering an account or continuing to use the PH94 Platform, 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 with any part of this Policy, you should discontinue use of the Platform and contact us to request account closure.

02 Data We Collect

PH94 collects the following categories of personal data from players and platform visitors:

PH94 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required for responsible gaming assessments or as mandated by applicable law.

03 How We Collect Data

PH94 collects personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from document verification service providers; fraud and AML screening data from compliance partners; payment transaction data from GCash, PayMaya, and banking partners.
• Publicly available sources: Information from public records or databases where necessary for compliance with anti-money laundering obligations.

04 How We Use Your Data

PH94 uses your personal data for the following purposes:

• To create, manage, and maintain your player account on the Platform;
• To verify your identity and age in compliance with the 21+ requirement and applicable PAGCOR regulations;
• To process deposits, withdrawals, and other financial transactions via GCash, PayMaya, BDO, BPI, and Metrobank;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To provide customer support and respond to your enquiries and complaints;
• To send you transactional communications, including account notifications, security alerts, and promotional offers where you have opted in to receive them;
• To monitor your gaming activity for responsible gaming purposes, including identifying patterns that may indicate problem gambling;
• To comply with our legal and regulatory obligations under Philippine law, including reporting requirements to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC);
• To improve and personalise the Platform experience based on your usage patterns and preferences;
• To enforce our Terms and Conditions and other platform policies.

PH94 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

05 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, PH94 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms and Conditions you agreed to upon registration, including account management and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML reporting, PAGCOR compliance, and NPC requirements;
• Legitimate interests: Processing necessary for PH94's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications and certain cookie-based tracking. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Sharing Your Data

PH94 does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BDO, BPI, Metrobank, and other payment service providers for the purpose of processing your financial transactions;
• Identity verification providers: Third-party KYC and document verification services used to confirm your identity and age;
• Fraud and compliance partners: AML screening and fraud detection service providers who assist PH94 in meeting its regulatory obligations;
• Technology providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government bodies where disclosure is required by law or court order;
• Professional advisers: Legal counsel, auditors, and accountants where necessary for the conduct of PH94's business operations.

All third parties with whom PH94 shares personal data are required to handle that data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose beyond what is strictly necessary.

07 Cookies and Tracking Technologies

PH94 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. They help us recognise your browser, remember your preferences, and analyse how the Platform is used.

PH94 uses the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login status to provide a more personalised experience.
• Analytics cookies: Collect anonymised data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats to the Platform.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. PH94 does not use cookies to serve third-party advertising.

08 Data Retention

PH94 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act;
• Identity verification documents: Retained for the duration of your account and for five (5) years following closure;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Technical and usage logs: Retained for up to twelve (12) months for security and performance purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with NPC guidelines. Where data is anonymised, it may be retained indefinitely for statistical and analytical purposes.

09 Data Security

PH94 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the PH94 Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls ensuring that only authorised PH94 personnel can access personal data, and only to the extent required for their specific role;
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While PH94 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. If you suspect that your account has been compromised, please contact PH94 support immediately.

10 Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by PH94:

• Right to be informed: The right to know what personal data PH94 collects about you and how it is used — which is the purpose of this Policy;
• Right of access: The right to request a copy of the personal data PH94 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: 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: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: The right to file 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 PH94's Data Protection Officer using the contact details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

11 Children and Minors

The PH94 Platform is strictly intended for individuals who are 21 years of age or older. PH94 does not knowingly collect personal data from individuals below the age of 21. The minimum age for participation in casino-style gambling in the Philippines is 21 years, as prescribed under applicable PAGCOR regulations.

If PH94 becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the PH94 Platform, please contact our support team immediately so that we can investigate and take appropriate action.

12 Changes to This Policy

PH94 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When we make material changes to this Policy, we will notify registered players via email or an in-platform notification at least fourteen (14) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how PH94 protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

If you have concerns about any changes to this Policy, you may contact our Data Protection Officer or choose to close your account before the changes take effect.

13 Contact Our Data Protection Officer

PH94 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact our DPO using the details below.

Data Protection Officer — PH94
Email: [email protected]
Support: [email protected]

Please note that email addresses above are displayed as plain text for reference. Our customer support team is also available 24/7 via live chat on the Platform for urgent privacy-related matters. We aim to respond to all written privacy requests within thirty (30) calendar days.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have not been adequately addressed by PH94.