ph2com Privacy Policy

1 Who We Are

ph2com operates the online gaming platform accessible at ph2com.vip, offering sports betting, live casino, slot games, and bingo to registered users in the Philippines. ph2com is the data controller responsible for the personal information collected through the Platform and processed in connection with user accounts, gaming activity, and financial transactions.

ph2com processes personal data in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the applicable issuances of the National Privacy Commission ("NPC") of the Philippines. ph2com also complies with relevant Know-Your-Customer ("KYC") and Anti-Money Laundering ("AML") data obligations under Philippine financial regulations.

2 Personal Data We Collect

ph2com collects personal data that is necessary, relevant, and proportionate to the purposes for which it is processed. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, gender, and government-issued identification document details (e.g., PhilSys ID number, passport number, driver's licence number, UMID).
• Contact Data: Philippine mobile number, email address, and residential address (including city, province, and postal code).
• Financial Data: GCash account number, Maya (PayMaya) account details, bank account details (BDO, BPI, Metrobank, UnionBank, etc.), transaction history, deposit amounts, withdrawal amounts, and wallet balance records.
• Account Data: ph2com username, account registration date, login timestamps, session history, and account preferences.
• Gaming Activity Data: Betting records, game participation history, wager amounts, outcomes, and loyalty programme participation data.
• Device & Technical Data: IP address, device type, operating system, browser type, and mobile network information collected automatically when you access the Platform.
• Communications Data: Records of correspondence between you and ph2com support, including support chat transcripts and email exchanges.
• Verification Documents: Copies or images of government-issued identification submitted during KYC verification, and any supporting documents submitted for account review purposes.

3 How We Collect Personal Data

ph2com collects personal data through the following means:

• Direct Collection: Information you provide when registering your ph2com account, completing KYC verification, submitting deposit or withdrawal requests, or contacting ph2com support.
• Automated Collection: Technical data collected automatically through cookies, web beacons, log files, and similar tracking technologies when you access the Platform via browser or mobile device.
• Payment Processors: Transaction confirmation data received from GCash, Maya, and partner banking institutions when you make deposits or withdrawals on ph2com.
• Third-Party Verification Services: Identity verification data received from authorised KYC and AML screening service providers used to fulfil ph2com's regulatory obligations.
• Regulatory Sources: Information received from PAGCOR, the AMLC, or other Philippine regulatory authorities in the context of compliance obligations.

4 Legal Basis for Processing

ph2com processes personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between ph2com and the registered user — including account management, processing bets, and facilitating financial transactions in Philippine Peso.
• Legal Obligation: Processing is required to comply with ph2com's obligations under Philippine law, including KYC verification requirements, AML reporting obligations, and PAGCOR regulatory reporting.
• Legitimate Interests: Processing is conducted for ph2com's legitimate business interests, including fraud prevention, platform security, and responsible gaming enforcement, provided these interests are not overridden by the rights of data subjects.
• Consent: Where required by law or where ph2com relies on consent as a basis for a specific processing activity (such as certain marketing communications), ph2com will seek your explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

5 How We Use Your Personal Data

ph2com uses collected personal data for the following purposes:

• Creating, managing, and maintaining your ph2com account and Wallet.
• Processing deposits and withdrawals via GCash, Maya, and local Philippine bank channels.
• Verifying your identity and age (21+) in compliance with PAGCOR regulations and the DPA.
• Detecting, investigating, and preventing fraud, money laundering, and other prohibited activities.
• Providing customer support and responding to account queries from Filipino players.
• Enforcing responsible gaming tools, including deposit limits, session limits, and self-exclusion requests.
• Personalising your ph2com experience, including game recommendations and relevant promotional communications where consent has been provided.
• Complying with legal and regulatory reporting obligations, including disclosures to PAGCOR, the AMLC, and the NPC where required.
• Improving ph2com Platform performance, security, and user experience through analysis of aggregated, anonymised usage data.

6 Data Sharing & Third-Party Disclosure

ph2com does not sell your personal data to third parties. ph2com may share your personal data with the following categories of recipients, strictly to the extent necessary for the purposes described in this Policy:

• Payment Service Providers: GCash (Globe Telecom), Maya (Voyager Innovations), BDO, BPI, Metrobank, and other payment processors necessary to complete financial transactions on ph2com.
• KYC & AML Service Providers: Authorised identity verification and screening providers engaged by ph2com to fulfil regulatory compliance obligations.
• Technology Service Providers: Cloud infrastructure providers, game content providers (including licensed slot, live casino, and bingo game studios), and platform security providers engaged to operate the ph2com Platform.
• Regulatory Authorities: PAGCOR, the AMLC, the NPC, and other competent Philippine government authorities, where ph2com is legally obligated to disclose information.
• Law Enforcement & Courts: Philippine law enforcement agencies and courts, where disclosure is required by a valid legal order, warrant, or court direction.

Where personal data is shared with third-party service providers, ph2com requires those providers to process data only under ph2com's instructions and in compliance with the DPA and applicable Philippine law.

7 Data Retention

ph2com retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account Data: Retained for the duration of the active account relationship and for five (5) years following account closure, in compliance with AML record-keeping obligations under 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 financial regulations.
• KYC Verification Documents: Retained for five (5) years following the end of the business relationship, as required by AMLC regulations.
• Support Communications: Retained for two (2) years from the date of the most recent interaction, unless a longer period is required for dispute resolution purposes.
• Technical & Log Data: Typically retained for up to twelve (12) months, unless required longer for security investigation or legal compliance purposes.

Upon expiry of the applicable retention period, ph2com will securely delete or anonymise personal data in accordance with NPC-compliant data disposal standards.

8 Data Security

ph2com implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between users and the ph2com Platform.
• Encryption of sensitive data at rest, including financial account details and identification document data.
• Role-based access controls limiting internal access to personal data to authorised personnel only.
• Two-factor authentication (2FA) availability for all ph2com user accounts.
• Regular security assessments and penetration testing of the Platform infrastructure.
• Automatic session timeout and anomaly detection to identify and respond to suspicious login activity.

In the event of a personal data breach that is likely to adversely affect the rights and freedoms of data subjects, ph2com will notify the NPC within 72 hours of becoming aware of the breach, and will notify affected users without undue delay, in accordance with the DPA and NPC Circular 16-03.

9 Cookies & Tracking Technologies

ph2com uses cookies and similar tracking technologies to operate the Platform, improve user experience, and comply with regulatory monitoring requirements. The types of cookies used on ph2com include:

• Strictly Necessary Cookies: Essential for the Platform to function — including session management, login authentication, and Wallet balance display. These cannot be disabled without disrupting core Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings and game lobby filters.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the ph2com Platform, enabling ph2com to improve performance and usability. No personally identifiable information is included in analytics reports.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and abnormal session behaviour on the Platform.

You may adjust your browser settings to refuse non-essential cookies. However, disabling strictly necessary cookies will impair your ability to use the ph2com Platform. ph2com does not use third-party advertising cookies or behavioural retargeting cookies.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, registered ph2com users in the Philippines have the following rights with respect to their personal data:

• Right to be Informed: You have the right to be informed that your personal data is being collected and processed, and for what purposes, as described in this Privacy Policy.
• Right of Access: You may request a copy of the personal data ph2com holds about you, including your account data, transaction history, and gaming records.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected or updated.
• Right to Erasure / Right to be Forgotten: You may request the deletion of your personal data where ph2com no longer has a legal or contractual basis for retaining it. This right is subject to ph2com's legal retention obligations under AML and PAGCOR regulations.
• Right to Object: You may object to the processing of your personal data where ph2com relies on legitimate interests as its legal basis, and where your interests override those of ph2com.
• Right to Data Portability: Where technically feasible, you may request that your personal data be provided to you in a structured, machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph2com has not handled your personal data in accordance with the DPA.

To exercise any of the above rights, please contact ph2com's Data Protection Officer using the contact details in Section 13 of this Policy. ph2com will respond to all data subject rights requests within thirty (30) days of receipt.

11 Children & Minors

ph2com does not knowingly collect personal data from persons under 21 years of age. The Platform is strictly intended for adults aged 21 and older in accordance with Philippine gaming regulations enforced by PAGCOR.

If ph2com becomes aware that personal data has been collected from a user who is under 21 years of age, the account will be immediately suspended, all data relating to that account will be deleted to the extent not required for regulatory reporting purposes, and the matter will be escalated to the relevant authorities where required by law.

Parents and guardians are encouraged to use parental control tools on shared devices to prevent minors from accessing ph2com or any other online gaming platform.

12 Updates to This Privacy Policy

ph2com reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidance, PAGCOR regulatory requirements, or ph2com's operational practices.

Where material changes are made to this Policy, ph2com will notify registered users via email or in-platform notification prior to the changes taking effect. The "Last Updated" date at the top of this page reflects the most recent revision.

Your continued use of the ph2com Platform after the effective date of a revised Privacy Policy constitutes your acknowledgement of the updated Policy. If you do not accept the updated Policy, you should cease using the Platform and may request account closure by contacting ph2com support.

13 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or ph2com's handling of your personal data, please contact the ph2com Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. Information on how to file a complaint with the NPC is available at the NPC's official channels.