ph11x Privacy Policy

ph11x operates the online gaming platform accessible at ph11x.app, offering casino games, sports betting, slots, bingo, and related entertainment services to players in the Philippines. As a platform that handles personal and financial information, ph11x takes data privacy seriously and is committed to handling your information responsibly, transparently, and in accordance with applicable Philippine law.

This Privacy Policy applies to all personal data collected by ph11x through the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and marketing communications. It applies to all users of the ph11x Platform, including registered players, visitors, and prospective players.

This Policy should be read alongside the ph11x Terms and Conditions, which govern your use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms and Conditions.

ph11x collects personal data that you provide directly to us, as well as data collected automatically through your use of the Platform. The categories of personal data we collect include:

2.1 Data You Provide to Us

• Identity Data: Full legal name, date of birth, nationality, and government-issued ID details (e.g., Philippine passport, SSS ID, driver's license, PhilSys ID);
• Contact Data: Email address, Philippine mobile number, and residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati);
• Financial Data: GCash account number, PayMaya account details, BPI/BDO/Metrobank account information, and other payment method details used for deposits and withdrawals;
• Account Data: Username, password (stored in hashed form), account preferences, and communication preferences;
• Verification Data: Copies of government-issued identification documents and proof of address submitted for KYC purposes;
• Communications Data: Records of your interactions with ph11x customer support, including chat transcripts and email correspondence.

2.2 Data Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, and device identifiers;
• Usage Data: Pages visited, games played, session duration, betting history, deposit and withdrawal history, and feature interactions;
• Location Data: General geographic location derived from your IP address (used for regulatory compliance and fraud prevention);
• Cookie Data: Data collected through cookies and similar tracking technologies as described in Section 6.

2.3 Data from Third Parties

ph11x may receive personal data about you from third-party sources, including payment processors (e.g., GCash, PayMaya), identity verification service providers, fraud detection services, and publicly available sources used for AML compliance purposes.

ph11x uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your ph11x account, including processing your registration and verifying your identity;
• Service Delivery: To provide you with access to ph11x games, sports betting, live casino, and all other Platform features;
• Financial Processing: To process deposits, withdrawals, and bonus payments, and to maintain accurate financial records;
• Legal Compliance: To comply with our obligations under Philippine law, including the Data Privacy Act of 2012, Anti-Money Laundering Act, and PAGCOR regulatory requirements;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform;
• Responsible Gaming: To monitor gameplay patterns and identify players who may be exhibiting signs of problem gambling, and to enforce self-exclusion and account restriction requests;
• Customer Support: To respond to your inquiries, complaints, and support requests;
• Marketing Communications: To send you promotional offers, bonuses, and platform updates where you have consented to receive such communications;
• Platform Improvement: To analyze usage patterns and improve the ph11x Platform, user experience, and game offerings;
• Dispute Resolution: To investigate and resolve disputes between players or between a player and ph11x.

ph11x processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012 and its implementing rules:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms and Conditions), including providing Platform access, processing transactions, and managing your account;
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing requirements, and tax obligations;
• Legitimate Interests: Processing is necessary for ph11x's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights;
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

ph11x may share your personal data with the following categories of recipients:

5.1 Service Providers

ph11x engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting providers, customer support software providers, and analytics platforms. These providers are contractually bound to process your data only on ph11x's instructions and in accordance with applicable data protection law.

5.2 Regulatory and Law Enforcement Authorities

ph11x may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Philippine law enforcement agencies, or courts where required by law, court order, or regulatory directive. ph11x will notify you of such disclosures where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of ph11x's assets, your personal data may be transferred to the acquiring entity. ph11x will notify you of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

5.4 With Your Consent

ph11x may share your data with third parties for purposes not described above where you have given your explicit prior consent to such sharing.

ph11x uses cookies and similar tracking technologies (including web beacons and local storage) to operate and improve the Platform. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management, login authentication, and security features. These cannot be disabled;
• Performance Cookies: Collect anonymized data about how you use the Platform, such as pages visited and errors encountered, to help us improve performance;
• Functional Cookies: Remember your preferences, such as language settings, game display options, and login details, to personalize your experience;
• Analytics Cookies: Used to understand aggregate usage patterns across the Platform. Data collected is anonymized and used solely for internal reporting;
• Marketing Cookies: Used to deliver relevant promotional content within the ph11x Platform. We do not use marketing cookies to track you across third-party websites.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the ph11x Platform. For detailed information on the specific cookies we use, please refer to our Cookie Notice available within the Platform settings.

ph11x 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. Our general retention periods are as follows:

• Account Data: Retained for the duration of your account and for five (5) years following account closure, in accordance with PAGCOR record-keeping requirements;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AML regulations;
• KYC and Identity Verification Documents: Retained for five (5) years following account closure or the completion of the relevant transaction;
• Customer Support Records: Retained for two (2) years from the date of the last interaction;
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent;
• Technical and Usage Data: Retained for up to twelve (12) months from collection, after which it is anonymized or deleted.

Where ph11x is required by law to retain data for a longer period, the statutory retention period will apply. Upon expiry of the applicable retention period, ph11x will securely delete or anonymize your personal data.

ph11x implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption: All data transmitted between your device and the ph11x Platform is protected using TLS (Transport Layer Security) encryption. Stored personal and financial data is encrypted using AES-256;
• Access Controls: Access to personal data is restricted to ph11x personnel and service providers who require it to perform their functions, and is governed by strict role-based access controls;
• Two-Factor Authentication: ph11x offers two-factor authentication (2FA) for player accounts to provide an additional layer of login security;
• Regular Security Audits: ph11x conducts regular internal and third-party security assessments, penetration testing, and vulnerability scans of the Platform;
• Incident Response: ph11x maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights, ph11x will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph11x:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy;
• Right of Access: You may request a copy of the personal data ph11x holds about you, along with information about how it is being processed;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you. You can update basic account information directly through your ph11x account settings;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph11x's legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to ph11x's overriding legal or operational requirements;
• Right to Data Portability: You may request that ph11x provide your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: If you believe ph11x has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact the ph11x Data Privacy Officer at the contact details provided in Section 13. ph11x will respond to all verified data subject requests within fifteen (15) business days of receipt. We may require you to verify your identity before processing your request.

ph11x employs age verification measures during the registration process to prevent access by minors. If ph11x becomes aware that personal data has been collected from an individual under the age of 21 without verifiable parental or guardian consent, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to ph11x, please contact us immediately at the details provided in Section 13 so that we can take appropriate action.

ph11x primarily stores and processes personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers and certain software platforms — may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, ph11x ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act of 2012. These safeguards may include:

• Contractual clauses requiring the recipient to protect personal data to Philippine DPA standards;
• Transfers to jurisdictions recognized by the National Privacy Commission as providing adequate data protection;
• Binding corporate rules where the recipient is part of the same corporate group as ph11x.

You may request information about the specific safeguards in place for any international transfer of your personal data by contacting our Data Privacy Officer.

ph11x reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, ph11x will notify registered players via the email address on file and display a prominent notice on the Platform for a period of not less than seven (7) days prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how ph11x protects your personal data. Your continued use of the ph11x Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy.

If you have any concerns about changes to this Privacy Policy, please contact our Data Privacy Officer before continuing to use the Platform.

ph11x has appointed a Data Privacy Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact us:

• Data Privacy Officer: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the ph11x Platform
• Response Time: Within 15 business days for data subject requests; within 24 hours for general support inquiries

All data privacy requests must be submitted in writing (via email) and must include sufficient information to verify your identity before ph11x can process your request. ph11x will not process data subject requests submitted anonymously.