pgph Privacy Policy

pgph ("pgph," "we," "us," or "our") operates the online gaming platform accessible at pgph.asia and all associated pages, services, and features (collectively, the "Platform"). This Privacy Policy describes how pgph processes the personal data of individuals who register an Account on the Platform, visit pgph.asia, interact with pgph's customer support channels, or otherwise engage with the pgph brand.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and applicable issuances of the National Privacy Commission ("NPC"). It is also consistent with pgph's obligations under PAGCOR's operator requirements regarding player data protection.

By registering an Account or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree to this Policy, you must not create an Account or use the Platform.

For the purposes of the Philippine Data Privacy Act of 2012, pgph is the Personal Information Controller ("PIC") responsible for the personal data collected and processed through the Platform. As PIC, pgph determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the DPA and its IRR.

pgph has designated a Data Protection Officer ("DPO") who is responsible for overseeing the Platform's data protection practices, handling data rights requests, and serving as the point of contact for the National Privacy Commission on matters relating to data privacy and protection. The DPO may be contacted via the details provided in Section 14 of this Policy.

pgph collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Data You Provide Directly

3.2 Data Collected Automatically

pgph does not collect sensitive personal information (as defined under the DPA) unless it is strictly necessary for regulatory compliance — for example, collecting a government ID as part of KYC, which falls under the legal obligation basis described in Section 4.

pgph processes your personal data only where it has a lawful basis to do so under the Philippine Data Privacy Act. The applicable legal bases are:

• Contractual Necessity: Processing is necessary to enter into and perform the contract between you and pgph — including operating your Account, processing deposits and withdrawals, and delivering gaming services.
• Legal Obligation: Processing is necessary to comply with pgph's obligations under Philippine law — including PAGCOR licensing requirements, AMLA reporting obligations, and tax regulations. KYC data processing falls under this basis.
• Legitimate Interests: Processing is necessary for pgph's legitimate interests, including fraud detection, platform security, product improvement, and responsible gaming monitoring, provided those interests are not overridden by your rights and freedoms.
• Consent: Processing is based on your freely given, specific, informed, and unambiguous consent — for example, processing your data for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

pgph uses the personal data it collects for the following specific purposes:

• Account Management: To create, maintain, and administer your pgph Account, including verifying your identity during registration and processing Account Settings changes.
• KYC & Age Verification: To verify that you meet the 21-year minimum age requirement under PAGCOR regulations and to confirm your identity before processing withdrawals, as required by applicable Philippine law.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods. Financial data is processed in accordance with PCI-DSS standards where applicable.
• Gaming Services: To operate and deliver the gaming products and services available on the Platform, including live casino, slots, bingo, and promotional features.
• Fraud & Security: To detect, investigate, and prevent fraud, money laundering, identity theft, bonus abuse, multi-accounting, and other prohibited activities, in accordance with pgph's AML and security obligations.
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling and to administer self-imposed responsible gaming tools (deposit limits, self-exclusion). pgph processes gaming activity data for player welfare purposes under its legitimate interests and regulatory obligations.
• Customer Support: To respond to your inquiries, resolve complaints, and provide account recovery assistance.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates where you have consented to receive such communications.
• Analytics & Improvement: To analyze Platform usage patterns and improve the user experience, game selection, and platform performance.
• Legal & Regulatory Compliance: To fulfill pgph's obligations to PAGCOR, the AMLC, the NPC, and other applicable Philippine regulatory bodies.

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

• Payment Service Providers: GCash (GXI), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and other payment processors that facilitate deposit and withdrawal transactions. These providers process your financial data as independent data controllers under their own privacy policies.
• Game Content Providers: Third-party software providers whose games are hosted on the pgph Platform. These providers may receive technical session data necessary to operate their game engines, governed by data processing agreements.
• KYC & Identity Verification Services: Third-party identity verification platforms that assist pgph in verifying government-issued IDs submitted during KYC. All such providers are bound by data processing agreements requiring equivalent data protection standards.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where disclosure is required by law, court order, or regulatory direction.
• IT Infrastructure Providers: Cloud hosting, server, and database providers that store and process Platform data on pgph's behalf. These providers act as Personal Information Processors under contracts requiring compliance with the DPA.
• Legal Advisors: Philippine legal counsel engaged to advise pgph on regulatory matters or to represent pgph in legal proceedings, subject to professional confidentiality obligations.

pgph uses cookies and similar tracking technologies on the Platform to ensure proper functionality, enhance your experience, and gather analytics data. Cookies are small text files placed on your device by your browser when you visit the Platform.

Types of Cookies Used

Strictly Necessary Analytics Marketing

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security cookies, and load-balancing cookies. These cannot be disabled without breaking the Platform's functionality.
• Analytics Cookies: Used to collect anonymized data about how visitors use the Platform, including pages visited, time on site, and error events. This data helps pgph improve Platform performance and user experience. These cookies are activated only with your consent.
• Marketing & Preference Cookies: Used to deliver relevant promotional content and remember your Platform preferences (such as display settings and language). These are only activated with your explicit consent.

You may manage your cookie preferences through the cookie consent banner displayed on your first visit to pgph.asia, or via your browser's built-in cookie management settings. Note that disabling non-essential cookies will not affect your ability to access the Platform's core features.

pgph retains personal data for no longer than is necessary to fulfill the purposes for which it was collected, subject to the minimum retention periods required by Philippine law. The following retention standards apply:

• Active Account Data: Retained for the duration of your Account's active status, plus a minimum of five (5) years following Account closure, to comply with PAGCOR licensing conditions and AMLA record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years following Account closure, consistent with AMLA obligations applicable to regulated gaming operators.
• Transaction Records: Deposit, withdrawal, and gaming transaction records are retained for a minimum of five (5) years following the date of each transaction.
• Customer Support Records: Support chat and email records are retained for three (3) years from the date of the interaction, unless related to a formal complaint or legal matter, in which case they are retained for the duration of the matter plus two (2) years.
• Analytics Data: Anonymized, aggregated analytics data may be retained indefinitely for platform improvement purposes. Individual-level usage data is retained for a maximum of twenty-four (24) months.
• Marketing Consent Records: Records of marketing consent (or withdrawal thereof) are retained for five (5) years from the date of the last interaction or consent action.

At the end of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC-approved data disposal standards.

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

• Encryption in Transit: All data transmitted between your browser and pgph's servers is encrypted using 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive data stored in pgph's systems — including password hashes, financial account references, and KYC documents — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within pgph's internal systems is restricted on a need-to-know basis, enforced through role-based access controls and multi-factor authentication for administrative access.
• Security Audits: pgph conducts periodic third-party security audits and penetration testing of its Platform infrastructure to identify and remediate vulnerabilities.
• Incident Response: pgph maintains a data breach response plan consistent with NPC notification requirements. In the event of a personal data breach that is likely to result in a real risk to your rights and freedoms, pgph will notify the NPC and affected individuals in accordance with the DPA's breach notification provisions.
• Employee Training: All pgph staff with access to personal data receive regular data privacy and security training as part of their onboarding and continuing professional development.

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

To exercise any of the above rights, please contact pgph's Data Protection Officer using the contact details provided in Section 14. pgph will acknowledge receipt of your request within five (5) business days and fulfill the request within fifteen (15) business days, subject to any applicable legal limitations.

The pgph Platform is strictly intended for adults aged twenty-one (21) years and above, as required by PAGCOR's regulatory framework. pgph does not knowingly collect, use, or retain personal data from individuals below the age of 21.

If pgph discovers or receives notice that personal data has been collected from an individual below the age of 21 — including through misrepresentation during registration — pgph will immediately suspend the relevant Account, delete the associated personal data to the extent permitted by law, and retain only the minimum records necessary to document the incident for regulatory and compliance purposes.

If you believe that a minor has created a pgph Account, please contact pgph support immediately at [email protected].

pgph's primary data processing infrastructure is located in data centers serving the Philippine market. Where pgph uses third-party service providers — such as cloud hosting providers, game engine operators, or KYC verification platforms — that process data in jurisdictions outside the Philippines, pgph ensures that such transfers comply with the cross-border data transfer provisions of the DPA and NPC regulations.

Specifically, pgph ensures that any transfer of personal data outside the Philippines is subject to adequate safeguards, which may include contractual clauses requiring the recipient to maintain data protection standards consistent with the DPA, or reliance on the recipient jurisdiction's adequacy determination by the NPC where applicable.

pgph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or Platform features. Material changes to this Policy will be communicated to registered Players via email at the address registered to their Account, at least fourteen (14) days prior to the effective date of the change, except where immediate amendment is required by law or regulatory directive.

The most current version of this Privacy Policy will always be accessible at pgph.asia/privacy-policy. The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the updated Policy.

For all privacy-related inquiries, data rights requests, or complaints regarding pgph's handling of your personal data, please contact pgph's Data Protection Officer through the following channels:

• DPO Email: [email protected] — Subject line: "Data Privacy Request — [Your Account ID]"
• Live Chat: Available 24/7 via the in-platform chat widget. For data privacy matters, request escalation to the Data Protection team.
• Response Timeframe: pgph will acknowledge receipt of all data privacy requests within five (5) business days and resolve them within fifteen (15) business days of acknowledgment.

If you are not satisfied with pgph's response to your data privacy concern, you have the right to file a complaint directly with the National Privacy Commission of the Philippines.