phh22 Privacy Policy – How We Protect Your Data

1 About This Privacy Policy

This Privacy Policy describes how phh22 ("we," "us," "our," the "Platform") collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," "Player," "User") who access or use the phh22 online gaming platform at phh22.vip.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). It also reflects the data governance requirements imposed by the Philippine Amusement and Gaming Corporation (PAGCOR) on licensed online gaming operators.

By registering an account on phh22, using the Platform, or interacting with our customer support channels, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, you must not use the phh22 Platform.

2 Data Controller Information

The data controller responsible for your personal data is the entity operating the phh22 Platform. For all data-related inquiries, requests, and complaints, players may contact the designated Data Protection Officer (DPO) through the contact details provided in Section 14 of this Policy.

phh22 has appointed a Data Protection Officer in accordance with Section 21 of the Data Privacy Act. The DPO is responsible for overseeing phh22's data protection strategy and compliance across all personal data processing activities on the Platform.

3 Personal Data We Collect

phh22 collects the following categories of personal data, limited to what is necessary for the stated purposes:

phh22 does not collect sensitive personal information (as defined under Section 3(l) of the DPA) unless specifically required by law or expressly consented to by the player. We do not collect or store full credit or debit card numbers on our servers.

4 How We Collect Your Data

phh22 collects personal data through the following means:

• Direct collection: Data you provide when registering your phh22 account, completing KYC verification, making a deposit or withdrawal, contacting support, or updating your account profile;
• Automated collection: Data generated automatically during your use of the Platform, including through cookies, web beacons, log files, and analytics tools — see Section 10 for full details;
• Payment providers: Confirmation data shared by GCash, PayMaya, BPI, BDO, Metrobank, or other payment processors when you initiate a transaction;
• Identity verification partners: Data returned by our KYC/AML verification service providers when processing identity document checks;
• Third-party game providers: Session and bet data shared by JILI, PG Soft, Evolution Gaming, Pragmatic Play, and other game studios integrated into the phh22 Platform.

5 Purposes of Personal Data Processing

phh22 processes your personal data for the following specific, legitimate, and declared purposes:

1. Account creation and management — to register your phh22 account, verify your identity, and maintain your player profile;
2. Transaction processing — to process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved Philippine payment channels;
3. Regulatory compliance — to fulfil obligations under PAGCOR licensing, the Anti-Money Laundering Act (AMLA), and other applicable Philippine statutes;
4. Age verification — to confirm that all phh22 players meet the minimum age requirement of 21 years as mandated by Philippine law;
5. Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, unauthorized account access, and abuse of Platform features;
6. Responsible gaming — to monitor player activity, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of gambling harm;
7. Customer support — to respond to your inquiries, resolve disputes, and improve the quality of phh22's support services;
8. Platform improvement — to analyze aggregate usage data for the purpose of improving phh22's games, features, mobile performance, and overall user experience;
9. Marketing communications — to send promotional offers, bonus notifications, and gaming updates to players who have opted in to receive such communications. Players may opt out at any time.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, phh22 relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing necessary to perform the contract between you and phh22 (i.e., providing the gaming services you have registered for);
• Legal obligation: Processing required to comply with Philippine laws, including PAGCOR regulations, AMLA requirements, and NPC data retention obligations;
• Legitimate interest: Processing for fraud prevention, Platform security, and responsible gaming monitoring, balanced against player privacy rights;
• Consent: Processing for optional marketing communications, where you have explicitly opted in. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Third-Party Disclosure

phh22 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following circumstances and only to the extent strictly necessary:

• PAGCOR and regulatory authorities: As required by our operating license and applicable Philippine law;
• Anti-money laundering authorities: The Anti-Money Laundering Council (AMLC) and other government agencies, as required under the AMLA and its amendments;
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and similar Philippine payment service providers, solely for the purpose of processing your transactions;
• KYC/Identity verification providers: Third-party services engaged to verify the identity documents of phh22 players, operating under strict data processing agreements;
• Game technology providers: JILI, PG Soft, Evolution Gaming, Pragmatic Play, and similar providers, who receive limited gameplay data necessary to deliver their game products;
• Legal and law enforcement: When required by court order, subpoena, or other lawful demand from Philippine authorities with proper jurisdiction;
• Business successors: In the event of a corporate merger, acquisition, or asset sale involving phh22, subject to the acquiring entity maintaining equivalent data protection standards.

All third parties who process personal data on behalf of phh22 are bound by data processing agreements that require them to maintain appropriate security measures and process data only for the purposes specified by phh22.

8 Data Retention

phh22 retains personal data only for as long as necessary for the purposes for which it was collected, and in accordance with Philippine legal retention requirements:

• Active accounts: All personal data is retained for the duration of your active phh22 account;
• Post-closure retention: Following account closure, phh22 retains transaction records, identity data, and gaming history for a minimum of five (5) years in compliance with PAGCOR and AMLA requirements;
• Support records: Customer support communications are retained for three (3) years for dispute resolution purposes;
• Marketing data: Retained only for as long as you maintain your opt-in status; deleted within 30 days of an opt-out request;
• Technical / log data: Retained for up to 12 months for security and fraud investigation purposes, then anonymized or deleted.

9 Security Measures

phh22 implements a layered set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data in transit between your device and phh22 servers;
• AES-256 encryption at rest for all sensitive personal and financial data stored in phh22 databases;
• Multi-factor authentication enforced for all phh22 administrative system access;
• Regular independent penetration testing and vulnerability assessments;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Automated anomaly detection systems to identify and respond to unusual access patterns or potential data breaches;
• Regular staff training on data privacy obligations under RA 10173.

In the event of a personal data breach that poses a real risk to your rights and freedoms, phh22 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay.

10 Cookies & Tracking Technologies

phh22 uses cookies and similar tracking technologies to operate the Platform effectively and improve your experience. The following types of cookies are used:

• Essential cookies: Required for the Platform to function. These maintain your logged-in session, enforce security measures, and remember your account preferences. These cannot be disabled without breaking core Platform functionality.
• Analytics cookies: Used to understand how players interact with phh22 — which games are most played, how long sessions last, where players encounter difficulties. This data is aggregated and does not identify individual players.
• Functional cookies: Remember your display preferences, language settings, and last-visited game sections to personalize your phh22 experience.
• Marketing cookies: Used only if you have opted in to marketing communications, to present relevant bonus offers and promotions based on your gaming preferences.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use core phh22 gaming features.

11 Your Data Subject Rights

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by phh22:

• Right to be informed — to know what personal data phh22 holds about you and how it is processed (fulfilled by this Policy);
• Right of access — to request a copy of all personal data phh22 holds about you;
• Right to correction — to request that inaccurate or incomplete personal data be corrected or updated;
• Right to erasure / right to be forgotten — to request deletion of your personal data, subject to phh22's legal retention obligations;
• Right to object — to object to processing of your personal data for direct marketing at any time;
• Right to data portability — to receive your personal data in a structured, commonly used format, where technically feasible;
• Right to lodge a complaint — to file a complaint with the National Privacy Commission if you believe phh22 has violated your data privacy rights.

To exercise any of these rights, contact the phh22 Data Protection Officer at [email protected]. phh22 will respond to verified data subject requests within fifteen (15) business days, or within the timeframe required by applicable NPC regulations.

12 Children's Privacy

The phh22 Platform is strictly prohibited for individuals under the age of 21. phh22 does not knowingly collect personal data from persons below the legal gaming age. If we become aware that personal data has been collected from an individual under 21 — whether through fraudulent registration or error — we will immediately close the relevant account, forfeit any associated funds in accordance with our Terms and Conditions, and securely delete all associated personal data.

If you are a parent or guardian and believe that your child has registered on phh22, please contact our support team immediately at [email protected] so that we can take prompt action.

13 Changes to This Privacy Policy

phh22 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable laws, or PAGCOR regulatory requirements. When material changes are made, phh22 will notify registered players via the Platform's notification system or by email to the registered address, at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically. Your continued use of phh22 after the effective date of any amendment constitutes your acceptance of the updated Policy.

14 Contact the Data Protection Officer

For all privacy-related inquiries, data subject requests, or complaints regarding phh22's data processing practices, please contact:

• Data Protection Officer, phh22
• Email: [email protected]
• Live Chat: Available 24/7 on the phh22 Platform (response under 90 seconds)

If you believe that phh22 has not adequately addressed your data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) through its official channels.