ph974 Privacy Policy

The following definitions apply throughout this Privacy Policy:

• "ph974", "we", "us", or "our" refers to the operator of the ph974.club Platform and its affiliated entities.
• "Platform" means the ph974.club website, mobile-optimised versions thereof, and all services, games, and account features accessible through it.
• "Personal Data" means any information that directly or indirectly identifies a natural person, as defined under the Philippine Data Privacy Act of 2012 (RA 10173).
• "Sensitive Personal Information" has the meaning given to it under RA 10173, and includes government-issued ID numbers, financial account details, and health information.
• "Data Subject" means any identified or identifiable natural person whose Personal Data is processed by ph974 — in the context of this Policy, this means you as a Player or visitor.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, and deletion.
• "NPC" means the National Privacy Commission of the Philippines, the regulatory body responsible for enforcing RA 10173.
• "DPO" means ph974's designated Data Protection Officer, who may be contacted at the address specified in Section 15 of this Policy.
• "PAGCOR" means the Philippine Amusement and Gaming Corporation.

ph974 acts as the Data Controller in respect of the Personal Data of its Account holders, site visitors, and any other individuals whose data ph974 collects in the course of operating the Platform. As Data Controller, ph974 determines the purposes and means of processing your Personal Data and bears primary responsibility for compliance with RA 10173.

Where ph974 engages third-party service providers to process Personal Data on its behalf — such as payment processors, KYC verification providers, and live dealer studio operators — those providers act as Data Processors under written agreements that impose data protection obligations consistent with RA 10173 and this Policy.

ph974 collects the following categories of Personal Data, to the extent necessary for the purposes described in Section 5:

ph974 does not collect biometric data (fingerprints, facial recognition data) directly. KYC document images are processed by our third-party identity verification provider and are not stored on ph974's own servers after verification is completed.

ph974 collects Personal Data through the following means:

• Direct provision by you: When you register an Account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey or promotion, you directly provide ph974 with Personal Data.
• Automated technical collection: When you visit or use the ph974 Platform, technical data including your IP address, device identifiers, browser fingerprint, and session information is automatically collected by our servers and analytics infrastructure.
• Payment processing partners: When you transact through GCash, Maya, BPI, BDO, Metrobank, or other supported payment channels, ph974 receives transaction confirmation data and payment reference information from those providers. ph974 does not receive your full payment account credentials.
• KYC verification providers: When you submit identity documents for KYC verification, our third-party verification provider returns a verification result and a confidence score to ph974. The raw document images are processed by the provider and are not retained by ph974 in their original form after verification.
• Cookies and tracking technologies: The Platform uses cookies, web beacons, and similar technologies to collect usage data and maintain session state. See Section 9 for full details.
• Referral and affiliate systems: If you arrive at ph974 through an affiliate link, ph974 may record the referring affiliate code associated with your registration. This is used for commission attribution only and does not affect the privacy rights described in this Policy.

ph974 processes your Personal Data for the following purposes:

ph974 processes your Personal Data on the following lawful bases as recognized under the Philippine Data Privacy Act of 2012 and its Implementing Rules:

• Performance of a contract: Processing necessary for the performance of the agreement between you and ph974 — including account management, deposits, withdrawals, game access, and customer support.
• Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and any direction issued by a competent Philippine authority.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregated analytics, where those interests are not overridden by your rights and interests as a Data Subject.
• Consent: Processing for marketing communications and any other purpose not covered by the above bases, where ph974 has sought and received your express consent. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

ph974 does not sell, rent, or trade your Personal Data. ph974 may share your Personal Data with the following categories of recipients, strictly to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash / GXI, Maya (Voyager Innovations), BancNet, and other payment infrastructure providers, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party providers engaged to verify the identity and age of Account holders as required by PAGCOR regulations.
• Game content providers: Licensed game suppliers may receive a player identifier and wager data through their game APIs for the purpose of game play and audit. They do not receive your full identity data.
• Fraud prevention and security providers: Providers of risk scoring, device fingerprinting, and anti-fraud tools that assist ph974 in detecting and preventing fraudulent activity.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or any other competent Philippine government authority, where disclosure is required by law or by an order of a court of competent jurisdiction.
• Professional advisors: Lawyers, auditors, and other professional advisors, to the extent necessary for the conduct of their engagement, under binding confidentiality obligations.
• Corporate transactions: In the event of a merger, acquisition, or sale of the ph974 Platform, your Personal Data may be transferred as part of the transaction, subject to the same protections described in this Policy.

All third-party recipients of ph974 player data are required to handle that data in accordance with RA 10173 and are subject to written data processing agreements where applicable.

ph974 retains your Personal Data only for as long as is necessary for the purposes set out in this Policy, including to satisfy legal, regulatory, tax, and accounting requirements.

Following the expiry of the applicable retention period, ph974 will securely delete or anonymize your Personal Data in accordance with its internal data deletion procedures.

ph974 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device by our web server. The following types of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens, CSRF protection tokens, and load-balancing cookies. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings and opted-in notifications. Disabling these cookies may reduce Platform convenience but will not prevent access.
• Analytics Cookies: Used to collect anonymized or pseudonymized information about how visitors use the Platform — pages visited, session duration, game categories browsed. This data helps ph974 improve the Platform. Analytics cookies require your consent on first visit.
• Security Cookies: Used to detect and prevent fraudulent logins, bot activity, and other security threats. These cookies process device fingerprint and behavioral signals for risk assessment purposes.

You may manage cookie preferences through your browser settings. Blocking strictly necessary cookies will impair your ability to use the Platform. If you are using Chrome on Android — as most Filipino mobile users are — you can manage cookie settings in Chrome's Settings > Privacy and Security menu.

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your Personal Data held by ph974. These rights may be exercised by contacting the ph974 DPO as described in Section 15.

ph974 will respond to verifiable rights requests within fifteen (15) calendar days of receipt. In cases requiring more complex assessment, ph974 may extend this period by a further thirty (30) days with written notice to you.

ph974 implements technical and organizational security measures designed to protect your Personal Data against unauthorized access, disclosure, alteration, destruction, or accidental loss. Key security controls include:

• AES-256 encryption for Personal Data at rest on ph974 servers.
• TLS 1.3 encryption for all data transmitted between your device and ph974 servers.
• Role-based access controls limiting access to Personal Data to authorized personnel with a documented need to access it.
• Two-factor authentication required for all ph974 internal systems that access production data.
• Regular penetration testing and vulnerability assessments of the Platform infrastructure.
• Formal incident response procedures, including breach notification protocols consistent with RA 10173's 72-hour notification requirement to the NPC in the event of a notifiable breach.
• Staff training on data protection obligations on an annual basis.

ph974 does not knowingly collect Personal Data from persons under the age of 21. The ph974 Platform is strictly prohibited for persons under 21, as mandated by PAGCOR regulations governing casino-style gaming in the Philippines. All registration attempts are subject to age verification during the KYC process.

If ph974 becomes aware that it has inadvertently collected Personal Data from a person under 21, it will immediately suspend the relevant Account, delete or anonymize the associated Personal Data to the extent permitted by PAGCOR reporting obligations, and report the incident if required under applicable law.

Some of ph974's third-party service providers — including live dealer game studio operators, cloud infrastructure providers, and fraud prevention vendors — process data on servers located outside of the Philippines.

Where Personal Data is transferred outside the Philippines, ph974 ensures that such transfers are conducted in compliance with Section 21 of RA 10173, which requires that the recipient country be deemed to provide an adequate level of protection, or that appropriate contractual safeguards are in place. ph974 uses standard contractual clauses and data processing agreements to protect Personal Data transferred to processors in other jurisdictions.

ph974 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, regulatory requirements, or Platform functionality. When material changes are made, ph974 will provide notice to Account holders via SMS to the registered mobile number or by prominent notice on the Platform, no less than seven (7) calendar days before the revised Policy takes effect.

The "Last Revised" date shown at the top of this Policy will be updated each time a material change is made. Continued use of the Platform after the effective date of a revised Policy constitutes acceptance of the revised terms. If you do not agree to any amendment, you should cease using the Platform and may request Account closure and data deletion in accordance with Sections 10 and 11.

ph974 has designated a Data Protection Officer (DPO) as required under RA 10173. For any data privacy-related queries, requests to exercise your rights, complaints, or concerns, please contact the ph974 DPO through the following channels: