Privacy Policy

1.Overview

32ph ("we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who interact with our Platform. We operate in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC).

As a personal information controller under the DPA, 32ph determines the purposes and means of processing your personal data. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing our data protection practices and ensuring compliance with applicable privacy laws. You may contact our DPO through the contact details provided in Section 13 of this Policy.

We process personal data only for legitimate, specified, and explicit purposes. We do not sell your personal data to third parties for their own marketing purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected.

2.Personal Data We Collect

Depending on how you interact with the 32ph Platform, we may collect and process the following categories of personal data:

We do not intentionally collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) unless specifically required by law or regulatory obligation.

3.How We Collect Your Data

32ph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification (KYC), making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, through cookies, web beacons, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from government databases or third-party KYC service providers; fraud prevention data from anti-fraud service providers; payment data from GCash, PayMaya, and banking partners (BPI, BDO, Metrobank, UnionBank) in connection with your transactions.
• Regulatory sources: Information received from PAGCOR, the AMLC, or other Philippine regulatory bodies in connection with our compliance obligations.

4.How We Use Your Personal Data

32ph uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your 32ph player account, including verifying your identity and age (21+ requirement) during registration and at any subsequent point.
• Platform operation: To provide you with access to games, process your bets, calculate and credit winnings, and deliver the full range of 32ph services.
• Financial transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank, and to maintain accurate financial records.
• Legal and regulatory compliance: To comply with our obligations under Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent or where we have a legitimate interest, and always with an easy opt-out option.
• Platform improvement: To analyze usage patterns and improve the design, functionality, and content of the 32ph Platform.

5.Legal Basis for Processing

Under the Data Privacy Act of 2012, 32ph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account and provide the services you have registered for.
• Legal obligation: Processing required to comply with Philippine laws and regulations, including PAGCOR licensing conditions, AMLA reporting obligations, and NPC data protection requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where our legitimate interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, where we rely on your freely given, specific, and informed consent. You may withdraw this consent at any time.

6.Data Sharing & Disclosure

32ph does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank, to process your financial transactions.
• Identity verification providers: Third-party KYC service providers who assist us in verifying your identity and age in compliance with PAGCOR requirements.
• Game software providers: Licensed game developers and live casino operators whose games are available on the 32ph Platform, to the extent necessary to deliver game services.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulatory directive.
• Fraud prevention services: Third-party anti-fraud and security service providers who help us protect the integrity of the Platform.
• Professional advisers: Lawyers, auditors, and accountants, where necessary for legal, compliance, or financial purposes, subject to professional confidentiality obligations.

Any third party with whom we share your personal data is required to process it only for the specified purpose, in accordance with our instructions, and subject to appropriate contractual data protection obligations.

7.Data Retention

32ph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general rule, 32ph retains account and transaction data for a minimum of five (5) years following the closure of your account, in accordance with PAGCOR licensing requirements and Philippine anti-money laundering regulations. Gaming history and financial records may be retained for longer periods where required by applicable law.

When personal data is no longer required, 32ph will securely delete or anonymize it in accordance with our data retention and disposal procedures.

8.Data Security

32ph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the 32ph Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Access controls ensuring that only authorized 32ph personnel can access personal data, on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments of the Platform infrastructure.
• Two-factor authentication (2FA) available for all player accounts.
• Incident response procedures to detect, report, and address personal data breaches in accordance with NPC notification requirements.

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We encourage you to use a strong, unique password for your 32ph account and to enable 2FA.

9.Cookies & Tracking Technologies

32ph uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences (such as language settings and login status) to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how visitors use the Platform, helping us improve its design and content.
• Security cookies: Used to detect and prevent fraudulent activity and unauthorized access attempts.

You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 32ph Platform. By continuing to use the Platform after being informed of our cookie use, you consent to our use of cookies as described in this Policy.

10.Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 32ph:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, which this Privacy Policy fulfills.
• Right to access: You may request a copy of the personal data we hold about you at any time, free of charge, subject to reasonable verification of your identity.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it promptly.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under PAGCOR and AMLA regulations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our overriding legal obligations.
• Right to data portability: Where technically feasible, you may request that we provide your personal data in a structured, commonly used, and machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: If you believe your privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13. We will respond to all verified requests within thirty (30) days, in accordance with NPC guidelines.

11.Minors & Age Restriction

The 32ph Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not use the 32ph Platform or provide any personal data to us.

If 32ph becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

As part of our registration process, 32ph employs age verification procedures and reserves the right to request government-issued identification documents to confirm that a player meets the 21+ age requirement at any time.

12.Changes to This Privacy Policy

32ph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email and/or by posting a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is always displayed at the top of this page. Your continued use of the 32ph Platform after any changes have been posted and notified constitutes your acknowledgment of the revised Privacy Policy. We encourage you to review this page periodically to stay informed of how we protect your personal data.

13.Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 32ph handles your personal data, please contact our Data Protection Officer. We take all privacy inquiries seriously and will respond promptly and transparently.