Privacy Policy

1. Data Controller

The data controller responsible for personal data collected through the ph33e platform (accessible at ph33e.vip) is ph33e ("Company," "we," "us," "our"), a PAGCOR-regulated online gaming operator based in the Philippines.

ph33e processes personal data in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission of the Philippines ("NPC"). For all privacy-related matters, you may contact our Data Protection Officer at the details provided in Section 13 of this Policy.

2. Personal Data We Collect

ph33e collects personal data in the following categories, depending on how you interact with the Platform:

ph33e does not collect sensitive personal information as defined under Section 3(l) of the DPA (such as racial origin, health records, or religious beliefs) except where expressly required by PAGCOR regulations or applicable law.

3. How We Use Your Personal Data

ph33e uses your personal data for the following purposes:

• Account registration and management: Creating, maintaining, and securing your ph33e account, including identity verification and password recovery via your registered Philippine mobile number;
• Service delivery: Enabling access to games, processing deposits and withdrawals in Philippine Peso via GCash, PayMaya, and Philippine banks, and personalising your in-platform experience;
• Regulatory compliance: Fulfilling obligations under PAGCOR regulations, Republic Act No. 9160 (Anti-Money Laundering Act), and the Data Privacy Act of 2012, including transaction monitoring, suspicious activity reporting to AMLC, and KYC record-keeping;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, multi-accounting, and other prohibited conduct;
• Responsible gaming: Monitoring player activity to identify potential problem gambling patterns, applying self-exclusion restrictions, and enforcing deposit limits;
• Customer support: Responding to your enquiries, resolving disputes, and managing complaints in English and Tagalog;
• Platform improvement: Analysing aggregated usage data to improve platform performance, game selection, and user experience — this analysis uses anonymised or pseudonymised data where possible;
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to your registered mobile number or email, subject to your communication preferences. You may opt out at any time via Account Settings.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, ph33e relies on the following lawful bases for processing your personal data:

• Contractual necessity: Processing required to provide the ph33e gaming service under the Terms and Conditions you agreed to at registration (e.g., account management, payment processing, game access);
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, and other applicable Philippine law (e.g., KYC, transaction monitoring, AML reporting);
• Legitimate interests: Processing necessary for ph33e's legitimate interests where these do not override your rights — including fraud detection, platform security, and service improvement using anonymised analytics;
• Consent: Where ph33e relies on your consent (e.g., for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

5. Data Sharing & Third Parties

ph33e shares personal data with third parties only to the extent necessary and under strict data processing agreements that require those parties to protect your data in accordance with the DPA:

• Payment processors: GCash (GXI Inc.), PayMaya (Voyager Innovations), and Philippine banks (BPI, BDO, Metrobank) — to process your deposits and withdrawals in PHP;
• Game providers: Licensed game software providers who supply game content to ph33e — they receive only pseudonymous session data necessary for game delivery and do not receive your identity documents;
• KYC and identity verification providers: Third-party services that assist in verifying government-issued Philippine IDs and conducting facial matching — these providers are bound by strict contractual and legal obligations;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement authorities where ph33e is legally required to disclose information;
• Cloud and infrastructure providers: Hosting and cloud computing services that store ph33e's systems — these providers process data only under ph33e's documented instructions;
• Customer support platforms: Third-party live chat and helpdesk software used to deliver ph33e's 24/7 English and Tagalog support — communication data is processed only for support purposes.

6. Data Retention

ph33e retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• KYC and identity records: A minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Financial transaction records: A minimum of five (5) years, consistent with AML obligations and Bureau of Internal Revenue (BIR) requirements;
• Gaming activity logs: A minimum of three (3) years following the recorded activity, for dispute resolution and regulatory audit purposes;
• Customer support records: A minimum of two (2) years following the close of any support interaction;
• Marketing consent records: Until withdrawal of consent or account closure, whichever occurs first.

After the applicable retention period expires, ph33e will securely delete or anonymise your personal data, provided no ongoing legal obligation or legitimate dispute requires its continued retention.

7. Security Measures

ph33e implements technical and organisational security measures appropriate to the sensitivity of the personal data processed and the risks presented by online gaming platform operations. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser or mobile device and ph33e's servers;
• Encryption at rest for sensitive personal data, including identity documents and financial records, stored in ph33e's systems;
• Role-based access controls limiting access to personal data to ph33e staff with a documented business need;
• Multi-factor authentication for ph33e staff accessing internal systems containing personal data;
• Regular penetration testing and security vulnerability assessments of the ph33e Platform;
• Automated monitoring for unusual account activity, including anomalous login patterns and suspicious transactions;
• An incident response procedure in compliance with the NPC's data breach notification requirements under NPC Circular 16-03.

Despite these measures, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. ph33e recommends enabling two-factor authentication (2FA) and using a strong, unique password for your ph33e account.

8. Cookies & Tracking Technologies

ph33e uses cookies and similar tracking technologies to operate the Platform, ensure security, and analyse usage. The categories of cookies in use are:

• Strictly necessary cookies: Essential for the Platform to function — session authentication tokens, security cookies, and load balancing cookies. These cannot be disabled without preventing access to the Platform;
• Functional cookies: Remember your preferences such as language settings, game lobby layout, and deposit method — these improve your experience but are not essential;
• Analytics cookies: Collect anonymised or aggregated data about how players navigate the Platform to help ph33e improve performance and usability. No personally identifiable information is transmitted in analytics data;
• Security cookies: Used to detect and prevent fraudulent access, bot activity, and multi-accounting attempts.

ph33e does not use third-party advertising or tracking cookies that would share your browsing data with external advertisers. You may manage non-essential cookie preferences through your browser settings; however, disabling strictly necessary cookies will affect the Platform's functionality.

9. Your Data Subject Rights

Under the Philippines Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph33e:

To exercise any of these rights, contact ph33e's Data Protection Officer via live chat or at [email protected] (plain text). ph33e will respond within fifteen (15) calendar days of a verified request. Identity verification is required before processing data subject requests. If you are unsatisfied with ph33e's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

10. Minors & Age Restriction

If ph33e discovers or is notified that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, any balance will be frozen pending investigation, and the personal data will be deleted to the extent not required to be retained by applicable law. If you believe a minor may have accessed ph33e, contact support via live chat immediately.

11. Cross-Border Data Transfers

Some of ph33e's third-party service providers — including game software providers and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred outside the Philippines, ph33e ensures that appropriate safeguards are in place, including:

• Contractual clauses requiring the recipient to protect data to a standard at least equivalent to the Philippines Data Privacy Act;
• Transfer only to jurisdictions or organisations that the NPC has determined provide an adequate level of protection;
• Minimisation of the personal data transferred to only what is strictly necessary for the specific processing purpose.

Identity documents and KYC records are, wherever technically and operationally feasible, stored on servers located within the Philippines or in jurisdictions with equivalent data protection standards.

12. Changes to This Privacy Policy

ph33e reserves the right to update this Privacy Policy at any time to reflect changes in Philippine law, NPC guidance, PAGCOR regulations, or ph33e's data processing practices. Material changes — those that significantly affect your rights or ph33e's data processing activities — will be communicated to registered players via their registered Philippine mobile number or email at least fourteen (14) days before the changes take effect.

The "Last updated" date at the top of this Policy indicates the date of the most recent revision. We recommend reviewing this Policy periodically. Your continued use of the ph33e Platform after a Policy update constitutes acknowledgment of the revised Policy.

13. Contact & Data Protection Officer

For all data privacy enquiries, data subject rights requests, or to contact ph33e's designated Data Protection Officer (DPO) as required under Section 21 of the Data Privacy Act of 2012, please use the following channels:

• Live Chat: Available 24/7 on the ph33e.vip Platform — the fastest channel for urgent privacy matters
• Email (plain text — not a clickable link): [email protected] — mark your message with the subject line "Data Privacy Request"
• Messenger / Viber: Available via contact details provided within the ph33e Platform

ph33e's support team is available in English and Tagalog, 24 hours a day, every day of the year. Data subject rights requests will be acknowledged within 5 business days and substantively responded to within 15 calendar days. Complex requests may require up to 30 calendar days — you will be notified if an extension is required.

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe ph33e has not handled your personal data in accordance with the Data Privacy Act of 2012.