phe65 Privacy Policy – Your Data, Your Rights

1 Introduction

This Privacy Policy describes how phe65 ("phe65", "we", "us", "the Company") collects, uses, discloses, stores, and protects personal information obtained from users ("you", "Player", "User") of the phe65 online gaming platform located at phe65.cam and all associated services (collectively, the "Platform").

By accessing, registering, or using the phe65 Platform, you acknowledge that you have read, understood, and consent to the collection and processing of your personal data as described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must immediately discontinue your use of the Platform.

This Privacy Policy should be read in conjunction with phe65's Terms & Conditions and Responsible Gaming Policy. In the event of any conflict, the provisions of this Privacy Policy shall govern with respect to data protection matters.

2 Data Controller

phe65 is the data controller responsible for the processing of your personal data collected through the Platform. As data controller, phe65 determines the purposes and means of processing your personal information in accordance with applicable Philippine data protection laws.

For data protection inquiries, access requests, or to exercise your privacy rights, you may contact phe65's Data Protection Officer at the contact details provided in Section 13 of this Privacy Policy.

3 Information We Collect

phe65 collects the following categories of personal information when you register, use the Platform, or interact with our services:

A. Information You Provide Directly:

• Account Registration Data: Full name, date of birth, nationality, gender, residential address, email address, mobile phone number, username, and password;
• Identity Verification Documents: Government-issued identification (e.g., Philippine Passport, UMID, Driver's License), selfie photograph, proof of address (e.g., utility bill, bank statement);
• Payment Information: Bank account details, GCash or PayMaya mobile wallet numbers, cryptocurrency wallet addresses, transaction history, deposit and withdrawal records;
• Communications: Content of emails, live chat messages, customer support tickets, feedback, and any other correspondence you send to phe65;
• Responsible Gaming Preferences: Self-exclusion requests, deposit limits, loss limits, session time limits, and reality check preferences.

B. Information Collected Automatically:

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, UDID, advertising ID);
• Usage Data: Pages visited, time spent on pages, click patterns, navigation paths, referral sources, search queries within the Platform;
• Gaming Activity: Games played, bets placed, bet amounts, win/loss records, bonus usage, withdrawal requests, session timestamps;
• Location Data: Approximate geographic location derived from IP address to verify jurisdiction and comply with geo-blocking requirements;
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, and similar technologies as detailed in Section 9.

C. Information from Third Parties:

• Payment Processors: Transaction verification, payment success/failure status, fraud risk scores;
• Identity Verification Services: Age verification, document authenticity checks, watchlist screening results;
• Affiliates and Marketing Partners: Referral codes, campaign identifiers (no personally identifiable information is shared with affiliates).

4 How We Use Your Data

phe65 processes your personal information for the following purposes:

• Account Management: To create, maintain, and administer your phe65 account, authenticate your identity, and enable access to Platform features;
• Transaction Processing: To process deposits, withdrawals, bonuses, and other financial transactions in accordance with your instructions;
• Regulatory Compliance: To comply with Know Your Customer (KYC) requirements, Anti-Money Laundering (AML) regulations, age verification mandates, and other legal obligations under Philippine law;
• Fraud Prevention and Security: To detect, prevent, and investigate fraudulent activity, money laundering, collusion, bonus abuse, multi-accounting, and other prohibited conduct;
• Customer Support: To respond to your inquiries, resolve complaints, provide technical assistance, and improve customer service quality;
• Marketing and Promotions: To send you promotional offers, bonuses, newsletters, and other marketing communications where you have provided consent or where permitted by law. You may opt out at any time;
• Platform Improvement: To analyze usage patterns, conduct A/B testing, develop new features, improve game offerings, and enhance overall user experience;
• Responsible Gaming: To enforce self-exclusion, deposit limits, and other responsible gaming controls you have set; to identify at-risk behavior and offer support resources;
• Legal Proceedings: To establish, exercise, or defend legal claims, respond to lawful requests from courts or regulatory authorities, and comply with court orders or subpoenas.

5 Legal Basis for Processing

phe65 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable Philippine data protection regulations:

• Consent: Where you have given explicit, informed, and freely given consent for specific processing activities (e.g., marketing communications);
• Contract Performance: Where processing is necessary to perform the contract between you and phe65 (i.e., the Terms & Conditions), including account creation, transaction processing, and service delivery;
• Legal Obligation: Where processing is required to comply with statutory obligations under Philippine law, including KYC/AML requirements, tax reporting, and regulatory directives;
• Legitimate Interests: Where processing is necessary for phe65's legitimate business interests, provided such interests are not overridden by your fundamental rights and freedoms. Legitimate interests include fraud prevention, security monitoring, network integrity, and business analytics;
• Vital Interests: In exceptional cases where processing is necessary to protect your life or physical safety, or that of another person.

Where we rely on consent as the legal basis, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6 Data Sharing and Disclosure

phe65 does not sell, rent, or lease your personal information to third parties for their marketing purposes. However, we may disclose your personal data to the following categories of recipients where necessary to operate the Platform or comply with legal obligations:

• Payment Service Providers: GCash, PayMaya, banks, cryptocurrency exchanges, and payment gateways require limited personal and transaction data to process deposits and withdrawals;
• Game Providers: Third-party game developers and content providers receive anonymized or pseudonymized gameplay data to deliver game content and calculate payouts;
• Identity Verification Services: Licensed KYC/AML service providers perform age verification, document authentication, and watchlist screening on phe65's behalf;
• Cloud Hosting and IT Services: Secure server infrastructure providers, database management services, and content delivery networks store and transmit data under strict confidentiality agreements;
• Customer Support Tools: Live chat platforms, email services, and ticketing systems used by phe65 support teams to assist you;
• Legal and Regulatory Authorities: Courts, law enforcement agencies, the National Privacy Commission, PAGCOR, tax authorities, or other government bodies where disclosure is required by law or court order;
• Professional Advisors: Lawyers, auditors, accountants, and consultants bound by confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, sale of assets, or corporate restructuring, your data may be transferred to the acquiring entity, subject to the same privacy protections.

All third-party service providers are contractually bound to process your data only in accordance with phe65's instructions and to implement appropriate technical and organizational security measures.

7 Data Retention

phe65 retains your personal information for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and prevent fraud.

Specific Retention Periods:

• Account Data: Retained for the duration of your account's active status, plus five (5) years following account closure, as required by Philippine AML regulations;
• Transaction Records: Retained for seven (7) years from the date of the transaction to comply with tax and financial record-keeping requirements;
• Identity Verification Documents: Retained for five (5) years following the last transaction or account closure, whichever is later;
• Marketing Consent: Retained until you withdraw consent or request deletion, after which we will cease processing for marketing purposes but may retain a suppression record to honor your opt-out;
• Customer Support Records: Retained for three (3) years to facilitate dispute resolution and improve service quality;
• Self-Exclusion Records: Retained permanently to prevent circumvention of self-exclusion commitments.

Following the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be attributed to an identifiable individual.

8 Security Measures

phe65 implements robust technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security framework includes:

• Encryption: All data transmitted between your device and phe65 servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest is encrypted using AES-256 encryption;
• Access Controls: Personal data is accessible only to authorized phe65 personnel on a strict need-to-know basis. Role-based access controls and multi-factor authentication are enforced;
• Firewalls and Intrusion Detection: phe65 servers are protected by enterprise-grade firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS);
• Regular Security Audits: Independent third-party security firms conduct annual penetration testing and vulnerability assessments;
• Data Segregation: Production, testing, and development environments are strictly segregated to prevent accidental data leakage;
• Employee Training: All phe65 staff undergo mandatory data protection and information security training;
• Incident Response Plan: phe65 maintains a documented data breach response plan to ensure swift detection, containment, and notification in the event of a security incident.

Despite these measures, no method of transmission over the internet or electronic storage is 100% secure. phe65 cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and must notify phe65 immediately if you suspect unauthorized access to your account.

9 Cookies and Tracking Technologies

phe65 uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience, analyze Platform usage, personalize content, and deliver targeted advertising.

Types of Cookies We Use:

• Strictly Necessary Cookies: Essential for the Platform to function. These cookies enable core features such as secure login, session management, and fraud prevention. They cannot be disabled;
• Performance Cookies: Collect anonymous data on how you use phe65, such as pages visited and error messages encountered. This helps us improve Platform performance;
• Functional Cookies: Remember your preferences (e.g., language, currency, display settings) to provide a more personalized experience;
• Targeting/Advertising Cookies: Track your browsing activity across phe65 and partner websites to deliver personalized advertisements and measure campaign effectiveness. These cookies require your consent.

You can manage your cookie preferences through your browser settings. Disabling certain cookies may impact your ability to use some Platform features. For detailed information on the specific cookies phe65 uses, their purpose, and expiration periods, please refer to our Cookie Policy available on the Platform.

10 Your Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal information:

• Right to Be Informed: You have the right to know what personal data phe65 collects, how it is used, and with whom it is shared;
• Right of Access: You may request a copy of all personal data phe65 holds about you, subject to identity verification;
• Right to Rectification: You may request correction of inaccurate, incomplete, or outdated personal data;
• Right to Erasure (Right to Be Forgotten): You may request deletion of your personal data where there is no overriding legal obligation to retain it (e.g., completed regulatory retention periods);
• Right to Object: You may object to processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format for transmission to another service provider;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing;
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission if you believe phe65 has violated your data protection rights.

To exercise any of these rights, please contact phe65's Data Protection Officer using the contact details in Section 13. phe65 will respond to your request within fifteen (15) calendar days, or as otherwise required by law. Identity verification will be required before we can process your request.

11 Children's Privacy

The phe65 Platform is intended exclusively for individuals aged 21 years or older. phe65 does not knowingly collect personal information from persons under the age of 21.

If phe65 becomes aware that a person under 21 has provided personal data through the Platform, we will take immediate steps to delete such information and terminate the account. If you believe that phe65 has inadvertently collected data from a minor, please contact us immediately at the contact details provided in Section 13.

Parents and guardians are encouraged to monitor their children's internet usage and to instruct them never to provide personal information on gaming or gambling websites without parental supervision.

12 Changes to This Privacy Policy

phe65 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations.

Material changes to this Privacy Policy will be communicated to registered users by email at least fourteen (14) days prior to the effective date of the change, and a prominent notice will be displayed on the Platform. Non-material changes may be implemented without prior notice.

Your continued use of phe65 following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you must cease using the Platform and may request deletion of your account and personal data in accordance with Section 10.

The most current version of this Privacy Policy is always available on this page at phe65.cam/privacy-policy. The "Last Updated" date at the top of this document indicates when the policy was last revised.

13 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal data, or phe65's data protection practices, you may contact us through the following channels:

• Data Protection Officer Email: [email protected]
• General Inquiries Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on phe65.cam
• Response Time: We aim to respond to all data protection inquiries within 4 hours during standard operating hours, and will provide a substantive response within 15 calendar days as required by law.

When contacting us about a privacy matter, please reference your phe65 username and provide a detailed description of your inquiry or request. For identity verification purposes, we may ask you to provide additional information before processing certain requests.