ph17 Privacy Policy

1. About This Privacy Policy

This Privacy Policy ("Policy") describes how ph17 ("ph17," "we," "us," "our") collects, processes, stores, and shares personal information in connection with the operation of ph17.club and all associated services ("Services"). It applies to all registered players, prospective players, and visitors to ph17.club, regardless of location.

This Policy is issued in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its implementing rules and regulations. ph17 operates as a Personal Information Controller as defined under the DPA with respect to the personal data it collects from users of ph17.club.

By using ph17 Services, you acknowledge that you have read, understood, and agree to the collection and use of your information as described in this Policy. This Policy should be read alongside ph17's Terms & Conditions and Responsible Gaming Policy.

2. Personal Data We Collect

ph17 collects personal data that is necessary for the purposes described in this Policy. The categories of data we may collect include:

ph17 does not intentionally collect sensitive personal information as defined under the DPA (such as medical records, political opinions, or religious beliefs) except where expressly required by law or regulation — for example, where a player self-discloses a gambling disorder in the context of a responsible gaming support request.

3. How We Collect Your Data

ph17 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or responding to ph17 promotions.
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, and server logs when you access or use ph17.club.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance screening providers; payment confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors.

4. How We Use Your Personal Data

ph17 uses personal data solely for legitimate, specified purposes. We use your data to:

• Create and manage your ph17 account and verify your identity;
• Process deposits, withdrawals, and in-platform transactions in Philippine Peso (₱);
• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Philippine law, including reporting obligations to the Anti-Money Laundering Council (AMLC) where required;
• Verify that you meet the minimum age requirement of 21 years to use ph17 Services;
• Provide customer support and resolve disputes;
• Detect, investigate, and prevent fraudulent transactions, cheating, collusion, or other prohibited conduct;
• Monitor your gaming activity for responsible gaming purposes and apply self-imposed limits or exclusions;
• Send you transactional communications such as deposit confirmations, withdrawal notifications, and account security alerts;
• Send you promotional communications about ph17 bonuses and offers, where you have opted in or where permitted by applicable law;
• Improve and personalize the ph17 platform experience;
• Comply with applicable Philippine laws and regulations, including any applicable licensing requirements.

ph17 does not use your personal data for automated decision-making that produces legal effects concerning you, except where such decisions are necessary for fraud prevention or AML compliance, in which case you have the right to request human review of the decision.

5. Legal Bases for Processing

Under the Data Privacy Act of 2012, ph17 processes your personal data on the following lawful bases:

• Contractual necessity: Processing required to fulfill ph17's obligations under the Terms & Conditions you accepted upon registration, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML legislation, gaming regulations, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes such as marketing communications, where you have given clear, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

ph17 does not sell, rent, or trade your personal data to third parties for commercial purposes. ph17 may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• KYC & Identity Verification Providers: Third-party identity verification services used to confirm your identity and age during onboarding.
• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your deposit and withdrawal transactions.
• Fraud & AML Screening Services: Compliance technology providers used to screen transactions against AML watchlists and detect fraudulent activity, as required under Philippine AML laws.
• Cloud & Infrastructure Providers: Hosting and cloud services providers that store ph17 platform data under strict data processing agreements that prohibit independent use of your data.
• Regulatory & Law Enforcement Authorities: Where ph17 is required or permitted by law to disclose data to the Anti-Money Laundering Council (AMLC), Philippine National Police (PNP), National Bureau of Investigation (NBI), or other competent authorities.
• Professional Advisors: Legal counsel, auditors, and accountants, under obligations of confidentiality, where reasonably necessary for ph17's legal and compliance obligations.

All third-party service providers engaged by ph17 are bound by data processing agreements requiring them to process personal data only on ph17's documented instructions and to maintain appropriate security standards.

7. Data Retention

ph17 retains your personal data for as long as necessary to fulfill the purposes described in this Policy and to comply with applicable legal obligations. Specific retention periods are as follows:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, consistent with AML record-keeping requirements under Philippine law.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Support and communications records: Retained for three (3) years from the date of the last interaction, or longer where relevant to an ongoing dispute or legal proceeding.
• Marketing consent records: Retained for the duration of your account plus three (3) years, to demonstrate consent compliance.

When personal data is no longer required for any legitimate purpose, ph17 will securely delete or anonymize it in accordance with applicable data disposal requirements.

8. Cookies & Tracking Technologies

ph17.club uses cookies and similar tracking technologies to operate the platform, remember your session, and analyze usage patterns. The categories of cookies we use include:

• Strictly necessary cookies: Required for the website and your account session to function. These cannot be disabled.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use ph17.club, helping us improve performance and navigation.
• Security cookies: Used to detect and prevent fraud, account takeover attempts, and bot activity.

You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of ph17.club. ph17 does not use third-party advertising or tracking cookies that share your data with external advertisers.

9. Data Security

ph17 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph17.club;
• Encryption of sensitive data fields (including financial data) at rest in ph17's database systems;
• Two-factor authentication (2FA) available to all registered players to protect account access;
• Access controls restricting ph17 staff access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of ph17 infrastructure;
• Incident response procedures in place to detect, contain, and notify affected individuals of any personal data breach in accordance with NPC notification requirements under the DPA.

No data transmission over the internet can be guaranteed to be completely secure. While ph17 takes all reasonable steps to protect your personal data, ph17 cannot guarantee absolute security against all possible threats. Players are encouraged to use strong, unique passwords and to enable 2FA on their accounts.

10. Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ph17:

• Right to be informed: The right to know what personal data ph17 holds about you and how it is used — which this Policy fulfills.
• Right of access: The right to request a copy of the personal data ph17 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• 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 ph17's legal retention obligations.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe ph17 has processed your data in breach of the DPA.

To exercise any of these rights, please contact ph17's Data Protection Officer at: [email protected] (plain text — not a mailto link). ph17 will respond to verified requests within fifteen (15) working days.

11. Children & Minors

ph17 Services are strictly available only to persons aged 21 years or older. ph17 does not knowingly collect personal data from persons under 21 years of age. ph17's registration process includes age verification steps designed to prevent access by minors.

If ph17 becomes aware that personal data has been collected from a person under 21 years of age, ph17 will immediately close the relevant account, void any associated transactions, and securely delete the personal data of the underage individual. If you believe that a minor has registered on ph17.club, please contact ph17 support immediately.

12. Updates to This Policy

ph17 reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, ph17 will notify registered players via email or through an in-platform notification, and will update the "Last updated" date at the top of this Policy.

Your continued use of ph17 Services following the publication of an updated Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must cease using ph17 Services and may request account closure.

13. Contact & Data Protection Officer

For any questions, concerns, or formal requests regarding this Privacy Policy or ph17's personal data practices, please contact ph17's Data Protection Officer:

ph17 is registered as a Personal Information Controller with the National Privacy Commission of the Philippines in accordance with applicable NPC issuances.