pph44 Privacy Policy

This Privacy Policy ("Policy") is published by pph44.club ("pph44," "we," "our," or "us") and applies to all personal information collected from players, visitors, and users ("you") who access or use the pph44 website, mobile interface, and all related gaming services (collectively, the "Platform").

pph44 is operated in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the regulations of the National Privacy Commission (NPC). As a PAGCOR-regulated gaming operator, pph44 also complies with the anti-money laundering and data handling requirements of the Anti-Money Laundering Act of the Philippines (Republic Act No. 9160, as amended by RA 10365).

By accessing pph44 or creating an account, you consent to the collection, processing, and use of your personal data as described in this Policy. If you do not agree, you must not use the Platform. This Policy should be read alongside pph44's Terms & Conditions and Responsible Gaming Policy.

pph44 collects personal data that is necessary to operate the Platform, verify player identities, process transactions, ensure regulatory compliance, and deliver a high-quality gaming experience. The categories of personal data collected include:

Registration & Account Data:

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify the 21+ age requirement)
• Residential address within the Philippines
• Email address and Philippine mobile number
• Username and encrypted password
• Gender (optional, for promotional personalization)

Identity Verification (KYC) Data:

• Scanned copies or photographs of government-issued identification documents (PhilSys ID, Passport, LTO Driver's License, UMID, Voter's ID, etc.)
• Selfie or liveness check photograph (for biometric KYC verification where applicable)
• Proof of address documentation (utility bill, bank statement, etc.) where required for enhanced due diligence

Financial & Transaction Data:

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method identifiers (e.g., GCash mobile number, bank account last digits)
• Account wallet balance history
• Bonus redemption and wagering activity records

Technical & Usage Data:

• IP address and approximate geolocation derived therefrom
• Device type, operating system, browser type and version
• Session logs, login timestamps, and session duration
• Game play history (games played, bet amounts, game outcomes, session duration)
• Pages visited and navigation patterns on pph44.club

Communications Data:

• Records of communications with pph44 customer support, including live chat transcripts, email correspondence, and support ticket history
• Feedback, survey responses, and complaints submitted to pph44

pph44 does not collect or store full payment card numbers, CVV codes, or full bank account numbers. Payment method credentials (GCash PIN, Maya password, internet banking credentials) are never entered on pph44 and are handled exclusively by the respective payment providers.

pph44 uses the personal data collected for the following specific, legitimate purposes:

• Account Creation and Management: To register your pph44 account, verify your identity, and manage your account throughout its lifecycle, including password resets and account recovery.
• Age Verification and KYC Compliance: To verify that all players are at least 21 years of age, as required by PAGCOR regulations, and to conduct Know Your Customer checks as required by Philippine anti-money laundering law.
• Payment Processing: To process deposits and withdrawals in Philippine Pesos through your selected payment method (GCash, Maya, BPI, BDO, Metrobank, UnionBank, USDT, Coins.ph, or 7-Eleven Cliqq), and to maintain accurate transaction records.
• Game Provision and Platform Operation: To provide access to pph44's games and features, maintain game session data, and resolve disputes regarding game outcomes or account balances.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, account takeovers, collusion, money laundering, and other prohibited conduct on the Platform.
• Regulatory Compliance and Reporting: To fulfil pph44's obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, including mandatory suspicious transaction reporting.
• Customer Support: To respond to your queries, complaints, and support requests via live chat, email, or other support channels, and to maintain records of support interactions for quality assurance.
• Responsible Gaming: To monitor gaming behaviour patterns that may indicate problem gambling and to apply deposit limits, session limits, or self-exclusion restrictions in accordance with pph44's Responsible Gaming Policy.
• Marketing and Promotions: To send you information about pph44 promotions, bonuses, and new features where you have given your consent or where pph44 has a legitimate interest in direct marketing to existing players. You may opt out of marketing communications at any time by contacting support.
• Platform Improvement: To analyse usage patterns, player behaviour, and technical performance in order to improve the pph44 platform, optimize game loading times, and identify features most valued by Filipino players.

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules, pph44 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform pph44's obligations under its Terms & Conditions, including account management, game provision, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulatory requirements, the Anti-Money Laundering Act, and NPC directives.
• Legitimate Interest: Processing necessary for pph44's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Where pph44 relies on your consent for specific processing activities (e.g., marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

pph44 does not sell, rent, or trade your personal data to third parties for their independent commercial purposes. pph44 may share your data with the following categories of recipients strictly as necessary for the purposes described in this Policy:

• Payment Processors: GCash (GXI/Mynt), Maya Philippines, BancNet, and other payment network operators to facilitate deposits and withdrawals. These processors receive only the minimum data required to execute the transaction.
• Game Software Providers: Licensed game developers and live studio operators whose games are available on pph44, for the purpose of delivering and auditing game sessions. Providers are contractually bound to use player data only for game provision purposes.
• KYC and Identity Verification Providers: Accredited third-party identity verification services that assist pph44 in processing government-issued ID documents and conducting liveness checks in compliance with PAGCOR KYC requirements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other competent Philippine government authority, where disclosure is required by law, court order, or regulatory directive.
• IT Infrastructure and Cloud Providers: Technology service providers who host pph44's platform infrastructure. All such providers are subject to data processing agreements that impose confidentiality and security obligations consistent with the Data Privacy Act.
• Professional Advisers: Legal, audit, and compliance professionals engaged by pph44, subject to professional secrecy obligations.

pph44 uses cookies and similar tracking technologies (including local storage objects and session tokens) on pph44.club for the following purposes:

• Essential Cookies: Required for the Platform to function correctly, including maintaining your login session, remembering your account preferences, and ensuring secure transaction processing. These cookies cannot be disabled without impairing Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players navigate pph44.club — including pages visited, time spent, and features used — to help pph44 improve the Platform experience.
• Security Cookies: Used to detect unusual login behaviour, prevent cross-site request forgery (CSRF), and support fraud detection systems.

You may manage non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of certain pph44 features. pph44 does not use third-party advertising cookies or retargeting pixels from external advertising networks on pph44.club.

pph44 retains personal data for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law, whichever is longer. The following retention standards apply:

• Active Account Data: Retained for the duration of your pph44 account and for a minimum of five (5) years after account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• KYC Documents: Retained for five (5) years following the end of the business relationship, or longer if required by a specific regulatory order or ongoing investigation.
• Support Communications: Retained for three (3) years from the date of the communication for dispute resolution and quality assurance purposes.
• Marketing Consent Records: Retained for the period of consent plus one (1) year after withdrawal of consent, to demonstrate compliance with consent requirements.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents re-identification.

pph44 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and pph44.club is encrypted using TLS 1.2 or higher (HTTPS). Sensitive data fields (passwords, KYC documents) are encrypted at rest using AES-256.
• Access Controls: Access to personal data is restricted on a need-to-know basis. pph44 staff are subject to confidentiality obligations and receive data protection training.
• Authentication: Two-factor authentication (2FA) is available for all player accounts and is used internally by pph44 staff accessing data systems.
• Vulnerability Management: pph44's systems undergo regular security assessments and penetration testing to identify and remediate vulnerabilities.
• Incident Response: pph44 maintains a data breach response procedure. In the event of a personal data breach affecting Philippine residents, pph44 will notify the National Privacy Commission and affected players within the timeframes prescribed by the Data Privacy Act.

While pph44 employs substantial security measures, no digital system is entirely immune to risk. You are responsible for maintaining the confidentiality of your own account credentials and for promptly reporting suspected unauthorized access to pph44 support.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by pph44:

• Right to Be Informed: The right to be informed that your personal data is being collected and processed, and about the purposes and nature of that processing — which this Policy fulfils.
• Right to Access: The right to request a copy of the personal data pph44 holds about you and information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure / Right to Be Forgotten: The right to request deletion of your personal data where it is no longer necessary for its original purpose and no legal obligation requires its retention. Note that certain data must be retained under Philippine AML and PAGCOR regulations regardless of an erasure request.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interest, subject to pph44's overriding legal or regulatory obligations.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, machine-readable format where technically feasible.
• Right to Damages: The right to claim compensation for any harm suffered as a result of a violation of the Data Privacy Act by pph44.

To exercise any of these rights, contact pph44's Data Protection Officer at [email protected] with the subject line "Privacy Rights Request." pph44 will respond within thirty (30) calendar days. We may require identity verification before processing your request to protect against unauthorized access to your data.

If you believe pph44 has not adequately addressed your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

pph44 is strictly prohibited from accepting players under the age of twenty-one (21) years. The Platform is not directed at minors, and pph44 does not knowingly collect personal data from individuals below this age threshold.

If pph44 discovers that personal data has been collected from an individual who is under 21, the account will be immediately suspended, the data will be securely deleted, and any deposits or winnings associated with that account will be handled in accordance with PAGCOR's regulatory procedures for underage access.

Parents and guardians who believe a minor has registered on pph44 should contact support immediately at [email protected]. pph44 takes these reports seriously and will act on them promptly.

Some of pph44's third-party service providers — including game software providers and cloud infrastructure partners — may be located outside of the Philippines. Where personal data is transferred to processors in other countries, pph44 ensures that appropriate safeguards are in place, including:

• Data processing agreements requiring the recipient to maintain security standards equivalent to those required under the Philippine Data Privacy Act
• Transfer to jurisdictions that the NPC recognizes as providing adequate data protection
• Use of standard contractual clauses approved by the National Privacy Commission where no adequacy finding exists

pph44 does not transfer personal data to jurisdictions where it cannot ensure an adequate level of protection for Filipino players' data rights.

pph44 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory requirements. Material changes will be communicated to registered players via email notification to the address on file and/or a prominent banner on pph44.club.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of pph44 after the effective date of any updated Policy constitutes acceptance of the revised terms. If you disagree with a material change, you may close your account by contacting support before the change takes effect.

We encourage you to review this Policy periodically to stay informed about how pph44 protects your personal data.

For all privacy-related inquiries, data rights requests, or concerns regarding pph44's data practices, please contact our Data Protection Officer:

• Email: [email protected] (subject line: "Privacy Rights Request" or "DPO Contact")
• Live Chat: Available 24/7 on pph44.club — ask to be connected to a Privacy or DPO team member
• Response Time: pph44 commits to acknowledging all DPO inquiries within 5 business days and providing a substantive response within 30 calendar days

If you are not satisfied with pph44's response to a privacy concern, you may escalate your complaint to the National Privacy Commission of the Philippines, the independent government authority responsible for enforcing the Data Privacy Act of 2012.