pph44 Privacy Policy — How We Handle Your Personal Data

pph44 ("pph44," "we," "us," "our") is committed to protecting the privacy and personal data of all individuals who access or use the pph44 platform at pph44.app and its associated domains ("Platform"). This Privacy Policy has been prepared in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as overseen by the National Privacy Commission ("NPC") of the Philippines.

This Policy applies to all personal data collected from:

• Registered account holders and active players on pph44
• Individuals who have initiated but not completed account registration
• Visitors to the pph44 website who have not registered, to the extent that data is collected through cookies or analytics
• Individuals who contact pph44 customer support via any channel

This Privacy Policy should be read together with pph44's Terms & Conditions and Responsible Gaming Policy, all of which collectively govern your relationship with pph44.

pph44 collects the following categories of personal data from players and platform users. The specific data collected at any given time depends on the nature of your interaction with the Platform.

• Full legal name as it appears on your Philippine government-issued identification document
• Date of birth (for age verification purposes — must confirm you are 21 years or older)
• Gender (where voluntarily provided during registration)
• Nationality and country of residence
• Registered username chosen at account creation

• Philippine mobile number (primary contact and two-factor authentication)
• Email address
• Residential address (collected during KYC verification or high-value withdrawal review)

• Scanned copy or photograph of a valid Philippine government-issued ID (e.g., PhilSys National ID, UMID, Passport, LTO Driver's License, COMELEC Voter's ID, or Postal ID)
• Proof of residential address (e.g., utility bill, bank statement) where required
• Source of funds documentation, where required by AML compliance review

• GCash account number or PayMaya account number linked to your pph44 wallet
• Philippine bank account details (BPI, BDO, Metrobank) used for deposits or withdrawals
• Complete record of all deposit and withdrawal transactions including amounts, timestamps, and payment method used
• Bonus and promotional credit history

• Complete game history including game titles, bet amounts, outcomes, and timestamps
• Sports betting slips and settlement records
• Session durations and active playing hours
• Bonus utilization and wagering history
• Responsible gaming settings including deposit limits, session timers, and any self-exclusion periods activated

• IP address at time of login and during active sessions
• Device type, operating system, and browser version
• Device fingerprint identifiers used for fraud prevention
• Geographic location data derived from IP address (approximate)
• Cookies and session identifiers (see Section 9 for full cookie details)

• Records of all communications between you and pph44 customer support, including live chat transcripts, email correspondence, and support ticket records
• Feedback and survey responses where voluntarily submitted

pph44 collects personal data through the following methods:

• Direct collection at registration: Information you provide when creating your pph44 account, including username, mobile number, email, and date of birth.
• KYC verification submission: Identity documents and address verification materials submitted to fulfill verification requirements.
• Payment and transaction processing: Financial information provided when making deposits or withdrawals, or automatically captured during transaction processing.
• Platform usage and game activity: Automatically recorded data generated as you use the platform — game sessions, bets placed, game outcomes, and navigation behavior.
• Device and browser data: Automatically collected technical data when your device connects to the pph44 platform, including IP address, device identifiers, and browser information.
• Cookies and tracking technologies: Session management, analytics, and fraud prevention data collected via cookies and similar technologies during your visit to pph44 (see Section 9).
• Customer support interactions: Information provided when you contact pph44 support, including the content of your communications and any documentation you submit.
• Third-party identity verification services: Where pph44 uses certified third-party KYC providers to assist with identity document verification, data may be processed by such providers under strict data processing agreements.

pph44 processes your personal data only for specific, legitimate, and clearly defined purposes. The table below summarizes our primary data processing activities:

Under the Data Privacy Act of 2012 (RA 10173), pph44 relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing required to register your account, execute your bets, process your deposits and withdrawals, and deliver the gaming services you have contracted with pph44 to receive.
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, Anti-Money Laundering Act obligations (RA 9160, as amended), National Privacy Commission requirements, and other applicable Philippine laws and regulations. This includes mandatory KYC verification, AML transaction monitoring, and record retention obligations.
• Legitimate interests: Processing necessary to protect the security and integrity of the pph44 platform, prevent fraud and abuse, improve the player experience through analytics, and enforce the Terms & Conditions. In each case, pph44 has assessed that its legitimate interests are not overridden by your data protection rights.
• Consent: Processing for purposes beyond the above categories — primarily marketing communications — requires your explicit consent. This consent is obtained separately at registration or through account settings and may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

pph44 does not sell your personal data to third parties. We do not share your personal information with third-party marketing agencies for their own use. Your data may be shared only in the following specific circumstances:

pph44 engages carefully selected third-party service providers who process personal data on our behalf, strictly under written data processing agreements that require them to maintain confidentiality and process data only as directed by pph44. These include:

• KYC and identity verification technology providers
• Payment processing partners (GCash/GXI, PayMaya/Maya Bank, BancNet, and similar Philippine payment infrastructure providers)
• Game software providers (JILI Games, PG Soft, Pragmatic Play, and others) to the extent necessary for game session integrity
• Cloud hosting and infrastructure providers operating the technical backend of the pph44 platform
• Customer support platform providers for live chat and ticket management
• Anti-fraud and cybersecurity analytics services

pph44 is required by law to disclose certain player data to regulatory and law enforcement authorities in the following circumstances:

• Disclosure to PAGCOR in connection with its regulatory oversight functions
• Disclosure to the Anti-Money Laundering Council (AMLC) as required under the Anti-Money Laundering Act
• Compliance with valid court orders, subpoenas, or other legally binding process issued by Philippine courts or competent authorities
• Disclosure to the National Privacy Commission in connection with data breach notifications or NPC investigations

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of pph44's assets, your personal data may be transferred to the acquiring entity as part of that transaction. pph44 will notify affected players of such a transfer via email or platform notification and ensure that the recipient is bound by data protection obligations at least equivalent to those in this Policy.

pph44 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to any longer retention period required by Philippine law.

• Active account data: Retained for the lifetime of your active pph44 account plus the legally required period following account closure.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the closure of your account, as required by the Anti-Money Laundering Act and PAGCOR regulatory requirements.
• Transaction records (deposits, withdrawals, bets): Retained for a minimum of five (5) years following the relevant transaction date, in compliance with AML record-keeping obligations.
• Customer support communications: Retained for three (3) years following the date of the last communication in a support thread.
• Marketing consent records: Retained for as long as the consent is active, plus one (1) year following withdrawal of consent for record-keeping purposes.
• Technical log data (IP logs, session logs): Retained for up to twelve (12) months for fraud prevention and security purposes, after which they are anonymized or deleted.

Upon expiry of the applicable retention period, pph44 will securely delete or anonymize your personal data using industry-standard data destruction procedures. Anonymized data that can no longer be linked to any individual is not subject to deletion timelines and may be retained indefinitely for aggregate analytics purposes.

pph44 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• TLS Encryption: All data transmitted between your device and pph44's servers is encrypted using TLS (Transport Layer Security) with 256-bit keys. This applies to the login page, game sessions, payment pages, and all other platform interactions.
• Encryption at Rest: Sensitive personal data including KYC documents and payment details are encrypted in storage using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. pph44 staff members can only access player data that is necessary for their specific role. All staff access is logged and auditable.
• Two-Factor Authentication: pph44 supports and recommends two-factor authentication (2FA) for all player accounts to reduce the risk of unauthorized access resulting from credential compromise.
• Intrusion Detection and Monitoring: pph44's infrastructure is monitored 24/7 for unusual access patterns, intrusion attempts, and security anomalies.
• Vulnerability Management: pph44 conducts regular security assessments and penetration testing of the platform to identify and remediate security vulnerabilities.
• Staff Training: All pph44 staff with access to personal data receive regular training on data privacy obligations and security procedures.

pph44 uses cookies and similar tracking technologies to operate the platform, authenticate user sessions, prevent fraud, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the pph44 platform. These include session authentication cookies that keep you logged in, security tokens that prevent cross-site request forgery (CSRF), and load-balancing cookies. These cookies cannot be disabled without breaking the platform's core functionality.
• Functional Cookies: Remember your preferences and settings on pph44, such as language preferences and display settings. These improve your experience but are not essential to core platform operation.
• Analytics Cookies: Used to collect anonymized or pseudonymized data about how players navigate and interact with the pph44 platform. This data helps pph44 improve the user experience and identify technical issues. Analytics data is processed in aggregate form and is not linked to individual player identities.
• Security and Fraud Prevention Cookies: Used to identify and flag suspicious activity, including unusual login patterns, multiple account detection, and bot behavior. These cookies are essential for protecting the integrity of the platform and the security of all players.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to or using the pph44 platform. Disabling analytics or functional cookies will not affect your ability to play but may degrade some non-essential features.

As a data subject under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by pph44:

• Right to be Informed: The right to be informed of what personal data pph44 collects, why it is processed, and how it is used — fulfilled by this Privacy Policy.
• Right to Access: The right to obtain a copy of the personal data pph44 holds about you, and information about how it is processed. Access requests are fulfilled within 15 business days of receipt.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. Account information (mobile number, email, address) may be updated through Account Settings or by contacting customer support.
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Note that this right is subject to exceptions where retention is required by law (e.g., AML record-keeping obligations).
• Right to Object: The right to object to the processing of your personal data where processing is based on legitimate interests. This includes the right to withdraw consent for marketing communications at any time.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe pph44 has processed your personal data in violation of the Data Privacy Act.

The pph44 platform is strictly restricted to individuals who are at least 21 years of age. This is both a legal requirement under PAGCOR regulations applicable to casino-style gambling in the Philippines and a core commitment of pph44's responsible gaming policy.

pph44 does not knowingly collect personal data from individuals under the age of 21. All accounts are subject to mandatory KYC identity verification that confirms the account holder's age before any deposit or gaming activity is permitted. Any account found to have been created by or on behalf of a person under 21 years of age will be immediately closed and all funds will be handled in accordance with applicable regulations.

In some circumstances, your personal data may be transferred to and processed in countries outside the Philippines. This may occur where pph44 uses cloud infrastructure providers, game software partners, or technical service providers whose operations are based outside the Philippines.

Where personal data is transferred outside the Philippines, pph44 implements appropriate safeguards to ensure that your data receives equivalent protection to that required under Philippine law. These safeguards include:

• Contractual data protection clauses in agreements with all international service providers, requiring them to maintain data protection standards consistent with RA 10173
• Transfer only to providers located in countries recognized as having adequate data protection frameworks
• Data minimization — only the minimum personal data necessary for the specific processing purpose is transferred internationally

pph44 does not transfer personal data to international third parties for marketing or commercial purposes unrelated to the delivery of pph44 gaming services.

pph44 reserves the right to update or amend this Privacy Policy at any time to reflect changes in Philippine data protection law, NPC guidance, PAGCOR regulatory requirements, or pph44's operational practices.

Where changes are material — meaning they affect the purposes for which your data is processed, the categories of data collected, or your rights as a data subject — pph44 will notify registered players via the email address on file at least fourteen (14) days before the revised Policy takes effect. The notification will summarize the key changes and provide a link to the full updated text.

Non-material changes (such as clarifications, corrections of typographical errors, or structural reorganization that does not affect substance) may be made without advance notice. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. Your continued use of pph44 following the effective date of any revised Policy constitutes acceptance of the updated terms.

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data by pph44, you may contact our Data Privacy team through the following channel:

If you are dissatisfied with pph44's response to a data privacy request or believe that pph44 has violated your rights under the Data Privacy Act of 2012, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines through their official complaint process. pph44 cooperates fully with all NPC inquiries and investigations.