Privacy Policy — ph8a1

1.Introduction

This Privacy Policy ("Policy") describes how ph8a1 ("ph8a1", "we", "us", "our") collects, uses, stores, shares, and protects the personal data of individuals ("you", "Player", "User") who access or use the ph8a1 online gaming platform at ph8a1.net and its associated mobile interfaces.

ph8a1 is committed to full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). Where applicable, ph8a1 also observes the data protection requirements of PAGCOR's regulatory framework for online gaming operators.

By registering for a ph8a1 account or otherwise using the ph8a1 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. This Policy should be read alongside ph8a1's Terms & Conditions and Responsible Gaming Policy.

2.Data Controller

ph8a1 is the data controller responsible for the personal data collected through the ph8a1 platform. As data controller, ph8a1 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data protection law.

ph8a1 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the Data Privacy Act of 2012. You may contact the ph8a1 DPO at any time using the contact details provided in Section 15 of this Policy.

3.Data We Collect

ph8a1 collects the following categories of personal data from players and platform users:

ph8a1 does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless strictly required for legal compliance purposes, such as AML/CTF obligations, in which case collection is limited to the minimum necessary and handled with heightened security controls.

4.How We Collect Data

ph8a1 collects personal data through the following means:

• Direct collection: Information you provide when registering for a ph8a1 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the ph8a1 platform, including IP address, device identifiers, browser information, and session activity logs;
• Cookie and tracking technologies: Data collected via cookies, web beacons, and similar technologies as described in Section 10 of this Policy;
• Third-party sources: Identity verification data from KYC service providers, fraud screening data from anti-fraud partners, and payment confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank.

ph8a1 will always inform you at the point of collection what data is being collected and for what purpose. Where data collection is mandatory for account registration or regulatory compliance, this will be clearly indicated. Optional data fields will be marked as such.

5.How We Use Your Data

ph8a1 uses the personal data we collect for the following purposes:

• Account management: Creating and maintaining your ph8a1 account, verifying your identity and age (21+), and managing your account preferences and settings;
• Platform operation: Processing deposits and withdrawals, recording game activity, resolving disputes, and providing customer support;
• Legal and regulatory compliance: Meeting our obligations under the Data Privacy Act of 2012, PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws;
• Fraud prevention and security: Detecting and preventing fraudulent activity, money laundering, account takeover attempts, and other prohibited conduct on the ph8a1 platform;
• Responsible gaming: Monitoring gaming patterns to identify players who may be at risk of problem gambling and providing appropriate interventions, including self-exclusion tools;
• Platform improvement: Analysing aggregated, anonymised usage data to improve the ph8a1 platform's features, performance, and user experience;
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications.

ph8a1 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate legal basis for the new processing activity.

6.Legal Basis for Processing

ph8a1 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including operating your ph8a1 account, processing transactions, and providing gaming services;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AMLA obligations, and NPC directives;
• Legitimate interests: Processing necessary for ph8a1's legitimate business interests, including fraud prevention, platform security, and improving our services, where such interests are not overridden by your data protection rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including the sending of marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7.Data Sharing

ph8a1 does not sell, rent, or trade your personal data to third parties. 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 processors: GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing deposits and withdrawals on your behalf;
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age as required by PAGCOR regulations and AMLA obligations;
• Fraud prevention and security partners: Service providers who assist ph8a1 in detecting and preventing fraudulent activity, money laundering, and other prohibited conduct;
• Game software providers: Licensed game developers and live dealer studio operators whose games are available on the ph8a1 platform, to the extent necessary to operate those games;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where disclosure is required by law or regulatory directive;
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by ph8a1, subject to binding confidentiality obligations.

All third parties with whom ph8a1 shares personal data are required to process that data in accordance with applicable Philippine data protection law and ph8a1's data processing standards. ph8a1 does not permit third-party service providers to use your personal data for their own independent purposes.

8.International Data Transfers

Some of ph8a1's third-party service providers, including game software providers and technical infrastructure partners, may be located outside the Philippines. Where personal data is transferred to recipients in other countries, ph8a1 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.

Such safeguards may include contractual data processing agreements incorporating the standard data protection clauses recognised by the National Privacy Commission, or transfers to countries that the NPC has determined provide an adequate level of data protection.

You may request further information about the specific safeguards applied to any international transfer of your personal data by contacting ph8a1's Data Protection Officer at the address provided in Section 15.

9.Data Retention

ph8a1 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account and identity data: Retained for the duration of your ph8a1 account and for a minimum of five (5) years following account closure, as required by AMLA and PAGCOR regulations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA record-keeping requirements;
• Gaming activity records: Retained for a minimum of three (3) years from the date of the gaming session, for dispute resolution and regulatory audit purposes;
• Customer support communications: Retained for two (2) years from the date of the last communication, for quality assurance and dispute resolution purposes;
• Marketing consent records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent, whichever is later.

Upon expiry of the applicable retention period, ph8a1 will securely delete or anonymise your personal data in accordance with our data disposal procedures. Anonymised data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical and analytical purposes.

10.Cookies & Tracking Technologies

ph8a1 uses cookies and similar tracking technologies on the ph8a1 platform to enhance your experience, maintain session security, and analyse platform usage. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the ph8a1 platform, including maintaining your login session and ensuring platform security. These cookies cannot be disabled without affecting platform functionality;
• Performance cookies: Used to collect anonymised information about how players use the ph8a1 platform, such as which pages are visited most frequently, to help us improve platform performance;
• Functionality cookies: Used to remember your preferences, such as your preferred language and display settings, to provide a more personalised experience;
• Analytics cookies: Used to understand aggregate player behaviour on the platform, helping ph8a1 make data-driven improvements to the gaming experience.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph8a1 platform. For more information about the specific cookies used by ph8a1, please contact our support team.

11.Your Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ph8a1:

• Right to be informed: The right to be informed about how your personal data is collected, used, and shared, as set out in this Policy;
• Right of access: The right to request a copy of the personal data ph8a1 holds 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 ph8a1 holds 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 ph8a1's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on ph8a1's legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted 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 ph8a1 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact ph8a1's Data Protection Officer using the details in Section 15. ph8a1 will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified accordingly.

12.Children's Privacy

The ph8a1 platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. ph8a1 does not knowingly collect personal data from individuals under the age of 21.

If ph8a1 becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the personal data in question, and void any transactions associated with the account. If you believe that a minor has registered on the ph8a1 platform, please contact us immediately at [email protected].

ph8a1 employs age verification procedures at the point of registration and during KYC review to prevent underage access to the platform. These procedures include verification of government-issued identification documents confirming the player's date of birth.

13.Security Measures

ph8a1 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph8a1 platform;
• Encryption of sensitive personal data and financial information at rest in ph8a1's databases;
• Role-based access controls limiting access to personal data to authorised ph8a1 personnel on a need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent security specialists;
• Multi-factor authentication requirements for ph8a1 staff accessing systems that process personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While ph8a1 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your ph8a1 account and to enable two-factor authentication to further protect your account.

14.Policy Changes

ph8a1 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. Where changes are material, ph8a1 will provide at least fourteen (14) days' advance notice to registered players via email to their registered address and via a prominent notice on the ph8a1 platform.

The date of the most recent revision to this Policy is displayed at the top of this page. Your continued use of the ph8a1 platform following the effective date of any amendment constitutes your acknowledgement of the revised Policy. If you do not agree to the revised Policy, you must cease using the platform and may request account closure in accordance with ph8a1's Terms & Conditions.

ph8a1 encourages you to review this Policy periodically to stay informed about how we protect your personal data.

15.Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or ph8a1's handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: Data Privacy Request — [Your Registered Name]
• Response time: Within 30 days of receipt
• Operating hours: 24 hours a day, 7 days a week, Philippine Standard Time (PST)

If you are not satisfied with ph8a1's response to your data 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.