Privacy Policy — 88ph Data Commitment

This Privacy Policy ("Policy") describes how 88ph ("88ph," "we," "us," or "our") — the operator of the online gaming platform at 88ph.club — collects, uses, stores, discloses, and protects the personal information of users ("you," "Player," or "User") who access or use the 88ph Platform, including its website, mobile applications, and all associated services.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. It is also consistent with the requirements of the Philippine Amusement and Gaming Corporation (PAGCOR) with respect to the handling of player data by licensed online gaming operators.

By registering an account on 88ph or using any feature of the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please do not use the 88ph Platform.

88ph collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Gender
• Nationality and country of residence
• Valid email address
• Philippine mobile number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys National ID)
• Proof of address documents (e.g., utility bill, bank statement)
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account)
• Selfie or liveness verification image where required

2.3 Financial & Transaction Data

• Deposit and withdrawal amounts, dates, and payment methods used
• GCash or PayMaya account reference numbers
• Bank account details (account name, bank name, account number) for bank transfer transactions
• Transaction history and account balance records

2.4 Gaming Activity Data

• Game session logs, including games played, bet amounts, win/loss records, and session duration
• Bonus and promotion usage history
• Sports betting selections and wager history
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, cooling-off periods)

2.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type and version
• Unique device identifiers
• Login timestamps and session activity logs
• Cookie identifiers and similar tracking data (see Section 6)

2.6 Communications Data

• Records of your communications with 88ph customer support, including chat transcripts, email correspondence, and support ticket history
• Feedback, survey responses, and promotional opt-in preferences

88ph uses the personal data we collect for the following purposes:

• Account Management: To create, verify, maintain, and manage your 88ph account, including processing your registration, verifying your identity, and enabling you to log in securely.
• Age Verification: To confirm that you meet the minimum age requirement of 21 years as mandated by PAGCOR and Philippine gaming regulations.
• Service Delivery: To provide you with access to all 88ph gaming products and services, including live casino, slots, bingo, fishing games, and sports betting.
• Payment Processing: To process your deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card, and to maintain accurate financial records of all transactions.
• Regulatory Compliance: To comply with our obligations under Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable regulations. This includes conducting KYC checks, monitoring transactions for suspicious activity, and reporting to the Anti-Money Laundering Council (AMLC) where required.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, to enforce responsible gaming tools you have activated (such as deposit limits and self-exclusion), and to contact you if we have concerns about your gaming behavior.
• Customer Support: To respond to your inquiries, resolve disputes, investigate complaints, and provide technical assistance.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, cheating, collusion, and other prohibited conduct on the Platform.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the performance, features, and user experience of the 88ph Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent to receive such communications. You may withdraw your marketing consent at any time by contacting support or updating your account preferences.

Under the Data Privacy Act of 2012, 88ph processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide the gaming services you have registered for and to process your financial transactions.
• Legal Obligation: Processing is required to comply with our legal obligations under Philippine law, including PAGCOR licensing conditions, AMLA reporting requirements, and NPC data protection obligations.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform — including fraud prevention, security monitoring, and platform analytics — provided these interests are not overridden by your rights and interests.
• Consent: For marketing communications and certain non-essential cookies, we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

88ph does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: GCash (G-Xchange, Inc.), PayMaya Philippines, Inc., and Philippine banking institutions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) — for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged by 88ph to assist with document verification and liveness checks.
• Game Software Providers: Licensed game content providers whose titles are available on the 88ph Platform may receive limited technical data (such as session tokens and bet data) necessary to deliver their games.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory mandate.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid legal order, warrant, or subpoena.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by 88ph, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of 88ph's assets, your personal data may be transferred to the acquiring entity, subject to the same data protection obligations set out in this Policy. You will be notified of any such transfer via a prominent notice on the Platform.

The 88ph Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and analyze Platform usage. A cookie is a small text file placed on your device by a website you visit.

Types of cookies we use:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming tool configurations.
• Analytics Cookies: Collect anonymized data about how users interact with the Platform — pages visited, time spent, and features used — to help us improve the user experience. These are only set with your consent.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your gaming interests. These are only set with your explicit consent and can be withdrawn at any time.

You can manage your cookie preferences through the cookie consent banner displayed on your first visit to the Platform, or by adjusting your browser settings. Note that disabling strictly necessary cookies may impair the functionality of the Platform.

88ph retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations.

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AMLA obligations.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, as required by AMLA and PAGCOR regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA reporting obligations.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines. Anonymized data may be retained indefinitely for statistical and research purposes.

88ph implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and the 88ph Platform is encrypted using TLS (Transport Layer Security) 1.2 or higher. Sensitive data at rest, including KYC documents and financial records, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 88ph personnel and service providers on a strict need-to-know basis. All staff with access to personal data undergo data privacy training and are bound by confidentiality obligations.
• Two-Factor Authentication: 88ph supports and encourages the use of two-factor authentication (2FA) for all player accounts to prevent unauthorized access.
• Penetration Testing: The Platform undergoes regular security assessments and penetration testing by independent cybersecurity professionals.
• Incident Response: 88ph maintains a documented data breach response plan. In the event of a personal data breach that poses a real risk to your rights and freedoms, we will notify the NPC within 72 hours of discovery and notify affected players without undue delay, as required by the DPA.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 88ph:

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data we hold 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 we hold 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 our legal retention obligations under AMLA and PAGCOR regulations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our 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 it to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days, as required by the DPA. We may need to verify your identity before processing your request.

The 88ph Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21, you are not permitted to register an account or use any feature of the Platform.

If 88ph becomes aware that personal data has been collected from a person under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

88ph primarily stores and processes your personal data within the Republic of the Philippines. However, some of our third-party service providers — including game software providers and cloud infrastructure partners — may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, 88ph ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses approved by the NPC, adequacy decisions, or other legally recognized transfer mechanisms.

By using the 88ph Platform, you consent to the transfer of your personal data to jurisdictions outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

The 88ph Platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 88ph Platform and does not cover the privacy practices of any third-party websites or services. 88ph is not responsible for the content, privacy policies, or data practices of any third-party sites.

We encourage you to review the privacy policies of any third-party websites you visit before providing them with your personal data.

88ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 88ph, please contact our Data Protection Officer (DPO):

• DPO Email: [email protected]
• General Support: [email protected]
• Response Time: Within 15 business days for formal data privacy requests; within 24 hours for general support inquiries
• Support Hours: 24 hours a day, 7 days a week

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.