Privacy Policy

1. Data Controller Identity

The data controller responsible for your personal data is 82ph, the operator of the 82ph online gaming platform ("82ph", "we", "us", or "our"). For all data privacy matters, including the exercise of your data subject rights, you may contact our Data Protection Officer at [email protected].

2. Personal Data We Collect

82ph collects personal data in the following categories, depending on how you interact with the Platform:

82ph does not intentionally collect sensitive personal information as defined under the Philippine Data Privacy Act (e.g., health data, religious beliefs, political affiliations) unless specifically required for responsible gaming assessments or legal compliance purposes, in which case your explicit consent will be sought.

3. Legal Basis for Processing

82ph processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012 (RA 10173):

• Contractual necessity: Processing required to create and manage your 82ph account, process deposits and withdrawals, and deliver gaming services.
• Legal obligation: Processing required to comply with Philippine anti-money laundering (AML) laws, PAGCOR regulatory requirements, and NPC data protection obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and optional personalisation features, where you have provided explicit, informed consent. You may withdraw consent at any time.

4. How We Use Your Personal Data

82ph uses your personal data for the following purposes:

• Creating, verifying, and managing your 82ph account
• Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels
• Verifying your identity and age (21+ requirement) through KYC procedures
• Detecting and preventing fraud, money laundering, and other prohibited activities
• Monitoring gameplay for responsible gaming purposes, including identifying patterns that may indicate problem gambling
• Providing customer support and resolving disputes
• Sending transactional communications (account confirmations, withdrawal notifications, security alerts)
• Sending promotional communications where you have opted in to receive them
• Complying with applicable Philippine laws and regulatory requirements
• Improving Platform performance, game offerings, and user experience

5. Disclosure of Personal Data to Third Parties

5.1 Service Providers. 82ph shares personal data with third-party service providers who assist in operating the Platform, including payment processors (GCash, PayMaya, and banking partners), KYC verification providers, game software providers, cloud hosting providers, and customer support platform operators. All service providers are bound by data processing agreements that restrict their use of your data to the specific services they provide to 82ph.

5.2 Regulatory Authorities. 82ph may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where required by law or in response to a lawful request.

5.3 No Sale of Data. 82ph does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. Any disclosure beyond the categories described in this section requires your explicit prior consent.

5.4 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of 82ph's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

6. Data Retention

82ph retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for two (2) years from the date of the interaction.
• Technical and usage data is retained for up to twelve (12) months, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 82ph's data disposal procedures.

7. Cookies and Tracking Technologies

82ph uses cookies, web beacons, and similar tracking technologies on the Platform. These technologies serve the following functions:

• Essential cookies: Required for the Platform to function correctly, including maintaining your login session and processing transactions. These cannot be disabled.
• Performance cookies: Collect anonymised data about how users interact with the Platform to help us identify and fix performance issues.
• Functional cookies: Remember your preferences (e.g., language, game lobby layout) to personalise your experience.
• Analytics cookies: Help 82ph understand aggregate usage patterns to improve game offerings and Platform features.

You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. 82ph does not use third-party advertising cookies or cross-site tracking technologies.

8. Data Security

82ph implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data in transit between your device and 82ph servers
• Encryption of sensitive data at rest, including financial account references and government ID numbers
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security assessments and penetration testing of Platform infrastructure
• Multi-factor authentication requirements for administrative access to data systems
• Incident response procedures for detecting, reporting, and managing personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 82ph will notify the National Privacy Commission and affected data subjects in accordance with the timelines prescribed by RA 10173 and its implementing rules.

9. Your Rights 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 82ph:

10. Children and Minors

The 82ph Platform is strictly intended for individuals who are 21 years of age or older. 82ph does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

82ph reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The date of the most recent revision is displayed at the top of this page. Where changes are material, 82ph will notify registered users via email or a prominent notice on the Platform at least fourteen (14) days before the changes take effect. Continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

12. Contact and Data Subject Requests

To exercise any of your data subject rights, or if you have any questions or concerns about this Privacy Policy or 82ph's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]

82ph will acknowledge all data subject requests within seventy-two (72) hours and will respond substantively within thirty (30) calendar days, as required by the NPC's implementing rules. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.