ph39 Casino – Privacy Policy

Last Updated: May 15, 2026

1. Introduction

ph39 Casino ("ph39," "we," "us," "our") is committed to protecting the privacy and personal data of every player who uses the ph39 online gaming platform at ph39.app. This Privacy Policy describes how ph39 collects, uses, stores, shares, and protects your personal information when you access or use the ph39 platform, including all associated services, mobile applications, and communications.

This Privacy 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 ("IRR"), and the applicable issuances of the National Privacy Commission ("NPC"). It also reflects ph39's obligations under PAGCOR's data governance framework for licensed online gaming operators.

By registering a ph39 account or using the ph39 platform, 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, please discontinue use of the ph39 platform.

2. Personal Data We Collect

ph39 collects the following categories of personal data from players and platform users:

2.1 Identity & Registration Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Gender;
• Nationality and country of residence;
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license, SSS/GSIS number).

2.2 Contact Data

• Email address;
• Mobile phone number (Philippine mobile number required for SMS verification);
• Residential address (province, city/municipality, barangay, ZIP code).

2.3 Financial & Payment Data

• GCash or PayMaya (Maya) account number linked to your ph39 account;
• Philippine bank account details (bank name, account number) for bank transfer withdrawals;
• Debit card details (card number, expiry, cardholder name) where applicable;
• Transaction history, including deposits, withdrawals, and bonus transactions.

2.4 Gaming & Activity Data

• Game history, including games played, wagers placed, wins, and losses;
• Session duration and login timestamps;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status).

2.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Cookies and session identifiers;
• Platform interaction logs and error reports.

2.6 Communications Data

• Records of your communications with ph39 customer support (live chat transcripts, email correspondence);
• Survey responses and feedback submitted through the ph39 platform.

3. How We Collect Your Data

ph39 collects personal data through the following means:

• Directly from you — when you register a ph39 account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions;
• Automatically — through cookies, web beacons, and server logs when you access and use the ph39 platform;
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, Philippine banks), fraud detection services, and PAGCOR where required by regulation.

4. How We Use Your Personal Data

ph39 uses your personal data for the following purposes:

5. Legal Basis for Processing

ph39 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity — processing required to fulfill our obligations under the ph39 Terms and Conditions, including account management, payment processing, and game provision;
• Legal obligation — processing required to comply with Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and NPC regulations;
• Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights;
• Consent — processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

6. Data Sharing and Disclosure

ph39 does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only where necessary and lawful:

• PAGCOR and Philippine regulatory authorities — as required by our gaming license and applicable law;
• National Privacy Commission (NPC) — in response to lawful orders or investigations;
• Anti-Money Laundering Council (AMLC) — for mandatory suspicious transaction reporting under the AMLA;
• Payment processors — GCash, PayMaya, and Philippine banks, solely to process your deposits and withdrawals;
• Identity verification providers — third-party KYC service providers engaged to verify your identity documents;
• IT and security service providers — cloud hosting, cybersecurity, and fraud detection vendors operating under strict data processing agreements;
• Law enforcement — where required by a valid court order, subpoena, or other lawful process under Philippine law.

All third-party service providers engaged by ph39 are contractually required to process your data only for the specified purpose, maintain appropriate security measures, and comply with the Philippine Data Privacy Act.

7. Data Retention

ph39 retains your personal data for as long as your account is active and for a period thereafter as required by law. Specific retention periods include:

• Account and identity data — retained for the duration of your account plus five (5) years after account closure, as required by PAGCOR and AMLA regulations;
• Financial transaction records — retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA requirements;
• Gaming activity logs — retained for three (3) years from the date of the activity;
• Customer support communications — retained for two (2) years from the date of the communication;
• Marketing consent records — retained until consent is withdrawn, plus one (1) year thereafter.

After the applicable retention period, ph39 will securely delete or anonymize your personal data in accordance with NPC guidelines.

8. Data Security

ph39 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the ph39 platform;
• AES-256 encryption for sensitive data stored in ph39 databases;
• Multi-factor authentication (MFA) for ph39 account access;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular penetration testing and vulnerability assessments by independent security firms;
• 24/7 security monitoring and intrusion detection systems;
• Incident response procedures compliant with NPC breach notification requirements.

In the event of a personal data breach that poses a real risk of serious harm to affected individuals, ph39 will notify the NPC within seventy-two (72) hours of discovery and will notify affected players without undue delay, as required by the Data Privacy Act.

9. Cookies and Tracking Technologies

ph39 uses cookies and similar technologies (web beacons, pixel tags, local storage) on the ph39 platform. The types of cookies we use include:

• Essential cookies — required for the ph39 platform to function, including session management and security tokens. These cannot be disabled;
• Functional cookies — used to remember your preferences such as language settings and game display options;
• Analytics cookies — used to understand how players use the ph39 platform, helping us improve performance and user experience. Data collected is aggregated and anonymized;
• Marketing cookies — used only with your explicit consent to deliver relevant ph39 promotions. You may withdraw consent at any time via your browser settings.

You can control and manage cookies through your browser settings. Please note that disabling essential cookies may affect the functionality of the ph39 platform.

10. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph39:

• Right to be informed — you have the right to know what personal data ph39 collects and how it is used, as described in this Privacy Policy;
• Right of access — you may request a copy of the personal data ph39 holds about you at any time;
• Right to rectification — you may request correction of inaccurate or incomplete personal data in your ph39 account;
• 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 ph39's legal retention obligations;
• Right to data portability — you may request a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to object — you may object to the processing of your personal data for direct marketing purposes at any time;
• Right to lodge a complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph39 has violated your data privacy rights.

To exercise any of these rights, please contact ph39's Data Protection Officer at the details provided in Section 15 of this Privacy Policy. ph39 will respond to all verified requests within fifteen (15) business days, as required by the DPA.

11. International Data Transfers

ph39 primarily stores and processes your personal data within the Philippines. Where it is necessary to transfer personal data to service providers located outside the Philippines (for example, cloud infrastructure providers), ph39 ensures that such transfers are made only to countries or organizations that provide an adequate level of data protection, or under appropriate contractual safeguards such as standard contractual clauses approved by the NPC.

ph39 will not transfer your personal data to jurisdictions that do not provide adequate protection without your explicit consent, except where required by Philippine law.

12. Children's Privacy

The ph39 platform is strictly intended for individuals aged 21 years and above, in compliance with PAGCOR regulations. ph39 does not knowingly collect, use, or store personal data from individuals under the age of 21.

If ph39 discovers or is notified that personal data has been collected from a person under 21 years of age, we will immediately delete that data, close the associated account, and return any deposited funds in accordance with applicable law. If you believe a minor has registered on the ph39 platform, please contact us immediately at [email protected].

13. Third-Party Links

The ph39 platform may contain links to third-party websites or services for informational purposes. ph39 is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to the ph39 platform at ph39.app.

14. Changes to This Privacy Policy

ph39 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days before taking effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent revision was made. Your continued use of the ph39 platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

15. Contact & Data Protection Officer

ph39 has appointed a Data Protection Officer (DPO) in compliance with the Philippine Data Privacy Act. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact:

• Data Protection Officer, ph39 Casino
• Email: [email protected]
• General Support: [email protected]
• Response time: Within 15 business days for formal DPO requests; within 24 hours for general support inquiries

For complaints that cannot be resolved directly with ph39, you may contact the National Privacy Commission (NPC) of the Philippines through their official channels.