ph11b Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") describes the privacy practices of ph11b ("ph11b," "we," "us," or "our") in relation to personal information collected from users ("Player," "User," "you") of the ph11b online gaming platform accessible at ph11b.app (the "Platform").

This Policy applies to all personal information collected through your use of the Platform, including registration, account management, deposits and withdrawals, gameplay, customer support interactions, and any communications between you and ph11b. It should be read alongside ph11b's Terms & Conditions.

2. Data Controller

ph11b is the data controller responsible for personal information collected on the Platform. As data controller, ph11b determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is lawful, fair, and transparent.

ph11b processes personal data in compliance with the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations, as well as applicable PAGCOR regulatory requirements governing online gaming operators in the Philippines.

3. Personal Data We Collect

ph11b collects the following categories of personal data, depending on how you interact with the Platform:

Registration and Identity Data:

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (to verify the 21+ age requirement);
• Philippine mobile number (Globe or Smart);
• Email address;
• Username and encrypted password.

KYC and Verification Data:

• Copies of government-issued identification documents (PhilSys ID, passport, driver's license, UMID);
• Proof of address documents (utility bills, bank statements from BDO, BPI, or Metrobank issued within 3 months);
• Source of funds documentation where required by PAGCOR or anti-money laundering obligations;
• Selfie or video verification for high-value account holders.

Financial Data:

• GCash account number or PayMaya account details;
• Bank account details (account holder name, bank name, account number) for bank transfer transactions;
• Transaction history including deposits, withdrawals, and bonus activations.

Technical and Usage Data:

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages viewed, and features used;
• Game session data including bets placed, outcomes, and RTP-relevant data for compliance reporting.

Communications Data:

• Records of live chat conversations with ph11b support agents;
• Email correspondence;
• Call recordings where applicable (you will be notified at the start of any recorded call).

4. How We Use Your Personal Data

ph11b uses your personal data for the following purposes:

• Account Management: Creating and maintaining your ph11b account, verifying your identity, and managing your account settings and preferences;
• Service Delivery: Processing deposits and withdrawals, delivering game sessions, and providing access to bonuses and promotions;
• Regulatory Compliance: Fulfilling obligations under PAGCOR gaming regulations, anti-money laundering laws, and the Philippine Data Privacy Act;
• Fraud Prevention and Security: Detecting, investigating, and preventing fraud, cheating, money laundering, and other prohibited activities on the Platform;
• Customer Support: Responding to your queries, resolving disputes, and providing technical assistance;
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and administering self-exclusion and limit-setting tools;
• Platform Improvement: Analysing usage patterns and technical performance to improve ph11b's features, game library, and user experience;
• Direct Marketing: Sending you personalised promotional offers and bonus notifications where you have provided consent or where ph11b has a legitimate interest in doing so, subject to your opt-out preferences.

5. Legal Basis for Processing

ph11b processes your personal data on the following legal bases under the Philippine Data Privacy Act and applicable data protection principles:

• Contract Performance: Processing necessary to provide the gaming services you have requested, including account creation, payment processing, and game delivery;
• Legal Obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws, tax obligations, and other applicable Philippine legal requirements;
• Legitimate Interests: Processing for fraud prevention, security, platform improvement, and direct marketing of our own services, where such interests are not overridden by your privacy rights;
• Consent: Processing for non-essential cookies, certain direct marketing communications, and any other processing activities where consent is required. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

ph11b may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to contractual data protection obligations:

• Payment Processors: GCash (Mynt), PayMaya (Voyager), and participating Philippine banks (BDO, BPI, Metrobank) — for deposit and withdrawal processing;
• Game Providers: Certified third-party game studios whose games are hosted on ph11b — limited to session data required for game delivery and RTP audit purposes;
• KYC and Fraud Prevention Services: Third-party identity verification providers engaged to assist with document verification and fraud screening;
• Regulatory Authorities: PAGCOR and other Philippine government agencies where disclosure is required by law or regulatory directive;
• Legal Advisers and Auditors: Professional advisers engaged by ph11b for legal, compliance, and audit purposes;
• IT and Cloud Infrastructure Providers: Cloud hosting and infrastructure service providers engaged to operate the Platform, subject to strict data processing agreements.

ph11b does not sell, rent, or otherwise commercially transfer your personal data to third parties for their independent marketing use.

7. International Data Transfers

Some of ph11b's service providers — including game providers and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred to recipients in other countries, ph11b implements appropriate safeguards to ensure that your data receives a level of protection consistent with the Philippine Data Privacy Act.

Such safeguards may include standard contractual clauses approved by the National Privacy Commission, adequacy decisions, or binding corporate rules where applicable. ph11b prioritises working with providers who maintain data centres regionally within Southeast Asia where technically feasible.

8. Data Retention

ph11b retains your personal data for the following periods:

• Active Account Data: Retained for the duration of your ph11b account and for five (5) years following account closure, as required by PAGCOR regulations and anti-money laundering record-keeping obligations;
• KYC and Verification Documents: Retained for five (5) years following the end of the business relationship per applicable anti-money laundering laws;
• Transaction Records: Retained for five (5) years following the transaction date;
• Support Communications: Retained for three (3) years;
• Technical Logs: Retained for twelve (12) months unless extended for fraud investigation purposes.

Upon expiry of applicable retention periods, ph11b securely deletes or anonymises personal data in accordance with its data destruction policy.

9. Cookies and Tracking Technologies

ph11b uses cookies and similar technologies (pixels, local storage) on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function, including session management, login authentication, and security tokens. These cannot be disabled without impairing Platform functionality;
• Analytics Cookies: Used to understand how Players use the Platform — pages visited, session duration, game preferences — to improve the user experience. Data is aggregated and anonymised;
• Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, including device fingerprinting for login security;
• Preference Cookies: Used to remember your account settings and display preferences across sessions.

You can manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality. ph11b does not use advertising or retargeting cookies that track you across third-party websites.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by ph11b:

• Right to Access: Request a copy of the personal data ph11b holds about you;
• Right to Rectification: Request correction of inaccurate or incomplete personal data;
• Right to Erasure: Request deletion of your personal data where it is no longer necessary, subject to ph11b's legal retention obligations;
• Right to Object: Object to processing based on legitimate interests, including direct marketing;
• Right to Data Portability: Receive your personal data in a structured, commonly used format to transfer to another controller;
• Right to Lodge a Complaint: File a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact ph11b's data protection point of contact at [email protected] with "Data Privacy Request" in the subject line. ph11b will respond within thirty (30) days of receiving a verifiable request.

11. Children's Privacy

ph11b's Platform is strictly for adults aged 21 years and above in accordance with applicable Philippine gaming regulations. ph11b does not knowingly collect personal data from persons under 21 years of age. If you are under 21, you are not permitted to register or use the Platform.

If ph11b becomes aware that personal data has been collected from a person under 21, that data will be deleted and the associated account permanently closed. If you believe a minor has registered on ph11b, please contact support immediately at [email protected].

12. Security Measures

ph11b implements technical and organisational security measures appropriate to the risk associated with processing your personal data, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and ph11b's servers;
• Encryption of sensitive personal data at rest;
• Role-based access controls ensuring only authorised ph11b personnel can access personal data, on a need-to-know basis;
• Regular security assessments and vulnerability testing of Platform infrastructure;
• Multi-factor authentication options for Player accounts;
• Login location monitoring and anomaly detection to identify and respond to unauthorised access attempts.

Despite these measures, no online platform can guarantee absolute security. ph11b encourages you to protect your account by enabling Two-Factor Authentication, using a strong and unique password, and logging out of the Platform when using shared devices.

13. Updates to This Policy

ph11b may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material updates will be communicated to registered Players via email to the address on file or via prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy reflects when the most recent revision was made. We encourage you to review this Policy periodically. Continued use of ph11b following notification of a material update constitutes acceptance of the revised Policy.

14. Contact and Data Protection Point of Contact

For all data privacy enquiries, rights requests, or complaints regarding ph11b's handling of your personal information, please contact:

ph11b aims to acknowledge all data privacy requests within five (5) business days and to respond substantively within thirty (30) days. If you are unsatisfied with ph11b's response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC).