ph497 Privacy Policy

01 Introduction

1.1 This Privacy Policy applies to all personal data collected by ph497 through ph497.app, our mobile applications, customer support channels, and any other services we operate (collectively, the "Platform").

1.2 This Policy should be read together with our Terms & Conditions, which govern your use of the ph497 Platform. Terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

1.3 ph497 is committed to the principles of transparency, legitimate purpose, and proportionality in all personal data processing activities, as required by RA 10173 and its Implementing Rules and Regulations (IRR).

02 Data Controller

2.1 ph497 is the personal information controller responsible for the personal data collected through the Platform. As the controller, ph497 determines the purposes and means of processing your personal data.

2.2 ph497 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with RA 10173 and this Privacy Policy. Contact details for the DPO are provided in Section 13.

03 Personal Data We Collect

3.1 ph497 collects the following categories of personal data:

3.2 Sensitive Personal Information. Where required for KYC verification or responsible gaming purposes, ph497 may collect sensitive personal information as defined under RA 10173, including government-issued ID numbers and, where applicable, information relating to health or financial status provided voluntarily in connection with responsible gaming requests. Such sensitive personal information is processed only to the extent strictly necessary and is subject to enhanced security controls.

3.3 Data You Choose Not to Provide. Where the provision of personal data is required to fulfil a legal obligation or to perform a contract with you, failure to provide such data may prevent ph497 from opening or maintaining your account, processing transactions, or providing certain services.

04 How We Use Your Personal Data

4.1 ph497 uses your personal data for the following purposes:

• Account Management: To create, verify, and maintain your ph497 player account, including processing your registration and authenticating your identity at login.
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers, and to maintain accurate records of all financial transactions on your account.
• KYC & AML Compliance: To verify your identity and age (21+), to comply with the Anti-Money Laundering Act (AMLA) of the Philippines, and to report suspicious transactions to the Anti-Money Laundering Council (AMLC) where required by law.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance through our support channels.
• Responsible Gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the features and performance of the ph497 Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may withdraw this consent at any time.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including PAGCOR requirements, tax obligations, and court or regulatory orders.

05 Legal Basis for Processing

5.1 ph497 processes your personal data on the following legal bases under RA 10173:

• Contractual Necessity: Processing required to perform our contract with you, including account management, transaction processing, and customer support.
• Legal Obligation: Processing required to comply with Philippine law, including KYC verification, AMLC reporting, PAGCOR regulatory requirements, and tax obligations.
• Legitimate Interests: Processing necessary for ph497's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

06 Data Sharing & Disclosure

6.1 ph497 does not sell or rent your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash (Mynt), PayMaya (Voyager Innovations), and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services engaged to assist with age and identity verification in compliance with PAGCOR and AMLC requirements.
• Technology Service Providers: Cloud hosting, data analytics, and cybersecurity providers who process data on ph497's behalf under strict data processing agreements that require them to maintain the confidentiality and security of your data.
• Regulatory Authorities: The Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government agencies where disclosure is required by law or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other legal process.

6.2 All third-party service providers engaged by ph497 are required to implement appropriate technical and organizational security measures and are prohibited from using your personal data for any purpose other than the specific service they provide to ph497.

07 Cookies & Tracking Technologies

7.1 ph497.app uses cookies and similar tracking technologies to enhance your browsing experience, maintain your session, and analyze Platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and display options to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how visitors use ph497.app, helping us identify areas for improvement. No personally identifiable information is collected through analytics cookies.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and account takeover prevention.

7.2 You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the ph497 Platform. Strictly necessary cookies cannot be disabled as they are essential for the Platform to operate.

08 Data Retention

8.1 ph497 retains your personal data for the following periods, after which data is securely deleted or irreversibly anonymized:

• Account Data: Retained for the duration of your account and for five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the AMLA.
• Transaction Records: Retained for ten (10) years from the date of the transaction, as required by the AMLA and BIR regulations.
• KYC Documents: Retained for five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support Communications: Retained for three (3) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of the consent given.

8.2 Where ph497 is required by law to retain data for a longer period, the statutory retention period will apply. ph497 will not retain personal data beyond the periods stated above unless required by a valid legal obligation.

09 Data Security

9.1 ph497 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and ph497.app is encrypted using TLS (Transport Layer Security). Sensitive data stored in our systems is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized ph497 personnel on a strict need-to-know basis. All staff with access to personal data undergo background checks and regular data privacy training.
• Two-Factor Authentication: ph497 supports and encourages the use of two-factor authentication (2FA) on player accounts to provide an additional layer of security against unauthorized access.
• Regular Security Audits: ph497 conducts regular internal and third-party security audits and penetration testing to identify and remediate vulnerabilities in our systems.
• Incident Response: ph497 maintains a documented data breach response plan. In the event of a breach, we will notify the NPC and affected players in accordance with RA 10173 requirements.

9.2 While ph497 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the security of your ph497 account credentials and for notifying us immediately if you suspect unauthorized access to your account.

10 Your Rights as a Data Subject

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph497:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data ph497 holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data ph497 holds about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph497's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph497 has violated your data privacy rights.

10.2 To exercise any of the above rights, please contact ph497's Data Protection Officer using the contact details in Section 13. ph497 will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11 Children's Privacy

11.1 The ph497 Platform is strictly intended for persons aged 21 years and above. ph497 does not knowingly collect personal data from persons under the age of 21. If ph497 becomes aware that personal data has been collected from a person under 21, that data will be immediately deleted and the associated account will be suspended.

11.2 If you are a parent or guardian and believe that a minor has registered on ph497 or provided personal data to ph497, please contact our support team immediately so that we can take appropriate action.

12 Updates to This Privacy Policy

12.1 ph497 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. Material changes will be communicated to registered players via email or a prominent notice on ph497.app at least seven (7) days before the changes take effect.

12.2 The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how ph497 protects your personal data.

12.3 Your continued use of the ph497 Platform following notification of any update to this Privacy Policy constitutes your acknowledgment of the revised Policy. If you do not agree with any changes, you may request account closure in accordance with our Terms & Conditions.

13 Contact & Data Protection Officer

13.1 If you have any questions, concerns, or requests relating to this Privacy Policy or ph497's data processing practices, please contact our Data Protection Officer:

• Data Protection Officer: ph497 Data Privacy Team
• Email: privacy@ph497.app
• General Support: support@ph497.app
• Support Hours: 8:00 AM – 12:00 MN PHT (GMT+8), daily

13.2 If you are not satisfied with ph497's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint with the NPC is available on the NPC's official website.