456ph Privacy Policy

This Privacy Policy ("Policy") describes how 456ph ("456ph", "we", "us", "our") collects, uses, discloses, retains, and protects personal data relating to individuals ("you", "Data Subject") who access or use the 456ph platform at 456ph.org, including all associated gaming and account services.

456ph is committed to protecting your privacy and processing your personal data responsibly, transparently, and in full compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the directives of the National Privacy Commission ("NPC") of the Philippines.

1. Who We Are — Data Controller

1.1 456ph is the personal data controller responsible for processing personal data collected through the 456ph platform. As Data Controller, 456ph determines the purposes for which and the means by which personal data is processed.

1.2 456ph has appointed a Data Protection Officer ("DPO") in accordance with Section 21 of the DPA and NPC Advisory Opinion requirements. The DPO is responsible for overseeing 456ph's data protection strategy and compliance with the DPA. Contact details for the DPO are provided in Section 14 of this Policy.

1.3 456ph operates in compliance with PAGCOR regulations, and certain data processing activities — particularly those relating to KYC identity verification, AML monitoring, and responsible gaming — are carried out in fulfilment of PAGCOR's regulatory requirements and mandates applicable to online gaming operators in the Philippines.

2. Scope of this Privacy Policy

2.1 This Policy applies to all personal data collected by 456ph through:

• Registration and use of the 456ph platform at 456ph.org;
• Account management, KYC verification, and identity confirmation processes;
• Deposit, withdrawal, and financial transaction processes;
• Customer support interactions via live chat, email, or SMS;
• Cookies, analytics, and tracking technologies as described in Section 7;
• Promotional participation, surveys, and other voluntary communications.

2.2 This Policy does not apply to third-party websites, applications, or services that may be linked from or otherwise connected to the 456ph platform. 456ph is not responsible for the privacy practices of third parties. Players should review the privacy policies of any third-party services they use in connection with their 456ph account, including their e-wallet providers (GCash, Maya, etc.) and banking providers.

3. Personal Data We Collect

456ph collects personal data in the following categories:

3.1 Registration and Identity Data

When you register a 456ph account, we collect:

• Full legal name (as it appears on your government-issued ID);
• Date of birth (for age verification — 456ph is a 21+ platform);
• Philippine mobile number (primary identifier and OTP delivery);
• Username and encrypted account credentials;
• Residential address (required for KYC);
• Email address (where provided).

3.2 Identity Verification (KYC) Data

For KYC compliance, we collect:

• Scanned or photographed copies of valid Philippine government-issued photo identification (PhilSys National ID, passport, UMID, driver's licence, or PRC licence);
• Selfie or live facial image for liveness verification, where required;
• Proof of address documentation, where required.

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records including amount, timestamp, and payment method reference;
• Payment method details (e.g., GCash mobile number, bank account reference number — 456ph does not store full bank account or card numbers);
• Account balance history and wager records.

3.4 Usage and Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser;
• Session duration, pages visited, and in-game activity logs;
• Login timestamps and device identifiers.

3.5 Communications Data

• Records of live chat, email, and SMS communications with 456ph support;
• Survey responses and promotional opt-in/opt-out records;
• Complaint and dispute records.

4. How 456ph Uses Your Personal Data

The table below sets out the primary purposes for which 456ph processes your personal data and the categories of data used for each purpose.

4.1 456ph does not use personal data for any purpose incompatible with the purposes listed above without first seeking your separate consent, unless required to do so by applicable law.

5. Legal Basis for Processing

Under Section 12 and 13 of the Data Privacy Act of 2012, 456ph relies on the following legal bases for processing your personal data:

• Performance of a contract: Processing necessary to register your Account, process transactions, and deliver gaming services pursuant to our Terms & Conditions.
• Compliance with a legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine statutes — particularly KYC, AML transaction monitoring, and mandatory regulatory reporting.
• Legitimate interests of 456ph: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for direct marketing and promotional communications, where you have provided separate, freely given, specific, and informed consent. You may withdraw consent at any time by contacting our support team or updating your communication preferences in your Account settings.

6. Data Sharing and Disclosure

6.1 No Sale of Personal Data. 456ph does not sell, rent, lease, or trade your personal data to any third party for their own marketing or commercial purposes.

6.2 Service Providers (Data Processors). 456ph may share personal data with third-party service providers who process data on 456ph's behalf and under 456ph's instruction, subject to Data Processing Agreements that impose obligations no less protective than those in this Policy. Categories of such processors include:

• KYC and identity verification technology providers;
• Payment processing providers and e-wallet gateway operators (including GCash, Maya, and banking partners);
• Cloud hosting and data storage infrastructure providers;
• Customer support platform providers;
• Fraud detection and cybersecurity service providers;
• Analytics and platform performance monitoring providers (using aggregated or pseudonymised data only).

6.3 Regulatory and Legal Disclosure. 456ph may disclose personal data to regulatory authorities, law enforcement agencies, or courts of competent jurisdiction where required to do so by:

• PAGCOR regulatory reporting requirements;
• Anti-Money Laundering Council (AMLC) reporting obligations under the AMLA;
• A valid court order, subpoena, or other legal process;
• The National Privacy Commission in the exercise of its functions.

6.4 Business Transfers. In the event of a merger, acquisition, corporate restructuring, or sale of substantially all of 456ph's assets, personal data may be transferred to the relevant successor entity. 456ph will provide notice of any such transfer and the Privacy Policy governing the transferred data.

7. Cookies and Tracking Technologies

7.1 The 456ph platform uses cookies and similar tracking technologies (including web beacons and local storage) to operate the platform, maintain session state, and improve the user experience.

7.2 Categories of cookies used by 456ph:

• Strictly Necessary Cookies: Required for the platform to function — including session authentication, security tokens, and login state. These cannot be disabled without preventing the Platform from working.
• Functional Cookies: Store your preferences such as language, game settings, and responsible gaming limit configurations to personalise your experience across sessions.
• Analytics Cookies: Collect anonymised data about how pages and features are used, to help 456ph improve the platform. No personally identifiable data is transmitted in this context.

7.3 You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the 456ph platform.

8. Data Retention

8.1 456ph retains personal data for the period necessary to fulfil the purposes described in this Policy, taking into account the following factors:

• Active Accounts: Personal data associated with an active 456ph Account is retained for the duration of the Account's existence plus any mandatory retention period required by law or regulation.
• Closed Accounts: Following Account closure, 456ph retains identity, KYC, and transaction records for a minimum of five (5) years in compliance with PAGCOR requirements and anti-money laundering obligations under the AMLA.
• Communication Records: Customer support communications are retained for a minimum of two (2) years from the date of the last interaction, or for the duration of any ongoing dispute resolution process, whichever is longer.
• Legal Hold: Where 456ph is subject to legal proceedings or a regulatory investigation, relevant data will be retained for the duration of those proceedings regardless of the standard retention schedule.

8.2 Upon expiry of the applicable retention period, personal data will be securely deleted, destroyed, or permanently anonymised in accordance with NPC-approved data disposal standards.

9. Data Security

9.1 456ph implements appropriate technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data in transit between your device and 456ph servers;
• Encryption of sensitive personal data at rest on 456ph infrastructure;
• Multi-factor authentication and privileged access controls for 456ph staff accessing personal data systems;
• Regular security assessments, vulnerability scanning, and penetration testing;
• Employee training on data privacy obligations and information security protocols;
• Incident response procedures aligned with NPC breach notification requirements.

9.2 While 456ph takes all reasonable steps to protect your personal data, no data transmission over the internet or electronic storage system is entirely secure. You are responsible for maintaining the confidentiality of your own Account credentials and for notifying 456ph immediately upon any suspected unauthorised access.

9.3 In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 456ph will notify the National Privacy Commission and affected Data Subjects within seventy-two (72) hours of becoming aware of the breach, to the extent required by the DPA and NPC Circular No. 16-03.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 456ph. These rights may be exercised by contacting 456ph's Data Protection Officer as described in Section 14.

10.1 456ph will respond to all data subject rights requests within thirty (30) calendar days of receipt of a valid written request. In complex cases, this period may be extended by a further thirty (30) days, with written notification to the requesting Data Subject.

10.2 Requests may be subject to identity verification before 456ph processes them, to protect against fraudulent access requests. 456ph will not charge a fee for processing data subject rights requests except in cases of manifestly unfounded or excessive repetition.

10.3 Certain rights may be limited where processing is required to comply with legal obligations, PAGCOR regulatory requirements, or the exercise of legal claims.

11. Children's Privacy

11.1 The 456ph platform is strictly restricted to individuals who are 21 years of age or older. 456ph does not knowingly collect or process personal data relating to minors under the age of 21.

11.2 If 456ph becomes aware that personal data has been collected from an individual who is under 21 years of age, that Account will be immediately suspended, the data will be reviewed in accordance with KYC procedures, and — if minority is confirmed — the data will be securely deleted and any funds returned in accordance with applicable regulatory requirements.

11.3 Parents or guardians who have reason to believe that a minor has registered an Account on 456ph should contact 456ph's support team immediately to initiate an investigation.

12. Cross-Border Data Transfers

12.1 Where 456ph transfers personal data to service providers or infrastructure located outside of the Philippines, such transfers are carried out in accordance with Section 21(c) of the DPA and the NPC's rules on cross-border data flows.

12.2 Before transferring personal data to a recipient in a foreign jurisdiction, 456ph ensures that:

• The receiving country provides a level of data protection substantially equivalent to that afforded under Philippine law; or
• Appropriate contractual safeguards (such as Data Transfer Agreements incorporating NPC-approved standard contractual clauses) are in place with the recipient; or
• The transfer is necessary for the performance of the contract between you and 456ph, or for pre-contractual measures taken at your request.

13. Amendments to this Privacy Policy

13.1 456ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or 456ph's data processing practices. All amendments will be published on this page with a revised effective date.

13.2 Where amendments are material — meaning they significantly affect your rights or how 456ph processes your personal data — 456ph will provide advance notice via SMS to your registered mobile number or via a prominent notice on the Platform, at least seven (7) days before the changes take effect.

13.3 Your continued use of the 456ph platform following the effective date of any amended Privacy Policy constitutes your acknowledgement of and agreement to the revised Policy. If you do not agree with the revised Policy, you should cease using the Platform and may request Account closure.

14. Contact Us — Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or 456ph's processing of your personal data, please contact 456ph's Data Protection Officer using the contact details provided in the footer of this page (plain text — not a clickable link).

For data subject rights requests (access, rectification, erasure, portability, etc.), please include the following information in your communication to help us process your request efficiently:

• Your full legal name as registered on your 456ph Account;
• Your registered 456ph mobile number;
• A clear description of the right you wish to exercise and the specific data concerned;
• A copy of a valid Philippine government-issued ID (for identity verification purposes).

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe that 456ph has violated your rights under the Data Privacy Act. Information about the NPC complaint process is available on the NPC's official website.