PHCash21 Privacy Policy

PHCash21 ("the Company," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who interact with our online gaming platform. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

This Policy describes the types of personal information we collect from players and visitors, the purposes for which that information is processed, the parties with whom it may be shared, the security measures we apply to protect it, and the rights available to you as a data subject under Philippine law.

PHCash21 acts as the Personal Information Controller in respect of all personal data collected through the Platform. Where we engage third-party service providers to process data on our behalf, those parties act as Personal Information Processors and are bound by data processing agreements consistent with the requirements of the Data Privacy Act.

If you have any questions about this Privacy Policy or about how PHCash21 handles your personal data, please refer to Section 14 for contact details of our Data Protection Officer.

PHCash21 collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include the following:

PHCash21 does not intentionally collect sensitive personal information as defined under the Data Privacy Act (such as health data, religious beliefs, or political affiliations) unless specifically required for regulatory compliance purposes, in which case your explicit consent will be obtained.

PHCash21 collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 9 for more details on our cookie practices.
• Payment Processors: Transaction confirmation data received from payment service providers such as GCash, PayMaya, BPI, BDO, and Metrobank when you conduct financial transactions on the Platform.
• Identity Verification Services: Data received from third-party KYC and identity verification providers engaged by PHCash21 to assist with regulatory compliance obligations.
• Fraud Prevention Services: Risk signals and device fingerprinting data received from fraud detection partners to protect the integrity of the Platform.

PHCash21 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your PHCash21 player account, including verifying your identity and age (21+) at registration.
• Service Delivery: To provide access to games, process bets, credit winnings, and deliver all features of the PHCash21 Platform.
• Payment Processing: To process deposits and withdrawals via your chosen payment method, and to maintain accurate financial records of all transactions.
• Regulatory Compliance: To fulfill our obligations under applicable Philippine gaming regulations, anti-money laundering (AML) laws, and Know Your Customer (KYC) requirements.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, to enforce self-exclusion and deposit limit requests, and to provide responsible gaming support where needed.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze usage patterns and player behavior in aggregate to improve the functionality, performance, and user experience of the PHCash21 Platform.
• Legal Proceedings: To establish, exercise, or defend legal claims in connection with the Platform or your account.

PHCash21 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and PHCash21 — specifically, to provide you with access to the Platform and its services in accordance with our Terms and Conditions.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and gaming regulatory requirements.
• Legitimate Interests: Processing is necessary for the legitimate interests of PHCash21, including fraud prevention, platform security, and the improvement of our services, provided that such interests are not overridden by your rights and freedoms.
• Consent: Where processing is not covered by the above bases — for example, in relation to optional marketing communications — PHCash21 will seek your explicit consent before processing your data for that purpose. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

PHCash21 does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors engaged to facilitate deposits and withdrawals on the Platform.
• Identity Verification Providers: Third-party KYC and document verification services engaged to assist PHCash21 in meeting its regulatory compliance obligations.
• Fraud Prevention and Security Partners: Service providers engaged to detect and prevent fraudulent activity, unauthorized access, and other security threats to the Platform.
• IT and Cloud Infrastructure Providers: Technology service providers who host, maintain, and support the PHCash21 Platform infrastructure, subject to strict data processing agreements.
• Regulatory and Law Enforcement Authorities: Philippine government agencies, regulatory bodies (including PAGCOR), law enforcement authorities, and courts, where disclosure is required by law, court order, or regulatory direction.
• Professional Advisers: Lawyers, auditors, and other professional advisers engaged by PHCash21 in connection with legal proceedings, compliance reviews, or business operations, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of PHCash21 are required to implement appropriate technical and organizational security measures and to process data only in accordance with PHCash21's documented instructions.

PHCash21 retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with PHCash21, and for a period of at least five (5) years following account closure, in accordance with applicable AML and gaming regulatory requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AML regulations.
• KYC and Verification Documents: Identity verification documents are retained for the duration of the account relationship and for five (5) years following account closure.
• Customer Support Records: Communications with our support team are retained for up to three (3) years from the date of the interaction, or longer if related to an ongoing dispute or legal proceeding.
• Technical and Usage Data: Aggregated and anonymized usage data may be retained indefinitely for platform analytics purposes. Identifiable technical data is retained for up to twelve (12) months.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with PHCash21's data disposal procedures.

PHCash21 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and PHCash21 servers is encrypted using industry-standard Secure Sockets Layer (SSL) / Transport Layer Security (TLS) protocols.
• Data Encryption at Rest: Sensitive personal data stored on PHCash21 servers, including financial data and identity documents, is encrypted at rest using strong encryption algorithms.
• Access Controls: Access to personal data is restricted to authorized PHCash21 personnel and service providers on a strict need-to-know basis. All access is logged and subject to regular review.
• Two-Factor Authentication: PHCash21 supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Regular Security Audits: PHCash21 conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the Platform.
• Incident Response: PHCash21 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the Data Privacy Act.

PHCash21 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device when you visit a website. The following types of cookies are used by PHCash21:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without affecting the functionality of the Platform.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred language and display options — to provide a more personalized experience on the Platform.
• Analytics Cookies: PHCash21 uses aggregated, anonymized analytics data to understand how players use the Platform and to identify areas for improvement. This data does not identify individual users.
• Security Cookies: These cookies assist in detecting and preventing fraudulent activity, unauthorized access attempts, and other security threats to the Platform.

PHCash21 does not use cookies for cross-site advertising, behavioral profiling, or the sale of data to third-party advertisers. You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may impair your ability to use certain features of the Platform.

The PHCash21 Platform is strictly intended for individuals who are 21 years of age or older. PHCash21 does not knowingly collect personal data from individuals under the age of 21.

As part of the registration process, all applicants are required to confirm that they meet the minimum age requirement and to submit valid government-issued identification for age verification purposes. Any account found to belong to a person under the age of 21 will be immediately suspended, and any personal data collected in connection with that account will be deleted in accordance with applicable law.

If you are a parent or guardian and believe that a minor has registered an account on PHCash21 or has submitted personal data to the Platform without your consent, please contact our Data Protection Officer immediately using the contact details provided in Section 14. We will take prompt action to investigate and, where confirmed, to delete the relevant data and close the account.

PHCash21 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from locations outside the Philippines — for example, where PHCash21 engages international technology service providers or cloud infrastructure partners.

Where such cross-border transfers occur, PHCash21 ensures that appropriate safeguards are in place to protect your personal data in accordance with the requirements of the Data Privacy Act of 2012 and the regulations of the National Privacy Commission. These safeguards may include:

• Data processing agreements incorporating standard contractual clauses approved by the NPC.
• Transfers to countries or organizations that have been assessed as providing an adequate level of data protection.
• Other legally recognized transfer mechanisms as permitted under Philippine data privacy regulations.

You may request further information about the specific safeguards applied to any cross-border transfer of your personal data by contacting our Data Protection Officer.

PHCash21 is committed to facilitating the exercise of your data subject rights under the Data Privacy Act of 2012. To submit a data subject rights request, please contact our Data Protection Officer using the details provided in Section 14.

When submitting a request, please provide sufficient information to allow us to verify your identity and locate the relevant personal data. PHCash21 will respond to all verified data subject rights requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, in which case we will notify you of the extension and the reasons for it.

PHCash21 will not charge a fee for processing data subject rights requests unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may be applied.

If you are not satisfied with PHCash21's response to your data subject rights request, or if you believe that PHCash21 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

PHCash21 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will update the "Last Updated" date at the top of this page and, where practicable, notify registered players via email or in-platform notification.

Your continued use of the PHCash21 Platform following the publication of any amended Privacy Policy constitutes your acknowledgment of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how PHCash21 protects your personal data. The most current version of this Policy will always be available at phcash21.net/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or to PHCash21's handling of your personal data, please contact our Data Protection Officer (DPO) through the following channels:

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available directly on the PHCash21 Platform, 24 hours a day, 7 days a week.

Our Data Protection Officer is responsible for overseeing PHCash21's compliance with the Data Privacy Act of 2012 and for handling all data subject rights requests and privacy-related inquiries. All communications addressed to the DPO will be treated with strict confidentiality.