Privacy Policy

1. Introduction

1.1 46ph is committed to protecting the privacy and personal data of all users of its online casino and sports betting platform. We recognize that the handling of personal data requires transparency, accountability, and a genuine commitment to data subject rights.

1.2 This Policy has been prepared in compliance with Republic Act No. 10173 (Philippine Data Privacy Act of 2012), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission of the Philippines. It also takes into account our obligations under PAGCOR's data governance requirements for regulated online gaming operators.

1.3 This Policy applies to all personal data collected from players located in the Philippines who use the 46ph platform, whether through the website, mobile browser, or any other interface through which 46ph services are accessed.

1.4 This Policy should be read alongside our Terms & Conditions, which govern the overall legal relationship between you and 46ph.

2. Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012, 46ph is the Personal Information Controller (PIC) in respect of all personal data collected through the 46ph platform.

2.2 As a Personal Information Controller, 46ph determines the purposes and means by which your personal data is processed and bears responsibility for ensuring that such processing complies with applicable Philippine data protection law.

2.3 46ph has designated a Data Protection Officer (DPO) responsible for overseeing the Company's data protection compliance. Contact details for the DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

3.1 46ph collects the following categories of personal data from players:

3.1 Identity Data

• Full legal name as it appears on a government-issued identification document
• Date of birth (for the purpose of verifying the 21+ age requirement)
• Nationality and country of residence
• Government-issued ID number (e.g., Philippine passport, SSS, PhilHealth, or UMID number)
• Photograph (where submitted as part of KYC verification)

3.2 Contact Data

• Email address
• Mobile phone number
• Residential address (for players in Manila, Cebu, Davao, Quezon City, or any other location in the Philippines)

3.3 Financial Data

• GCash or PayMaya account number
• Bank account details (BPI, BDO, Metrobank) where used for transactions
• Credit or debit card details (Visa, Mastercard) where applicable
• Transaction history, deposit records, and withdrawal requests

3.4 Account & Gameplay Data

• Username and account preferences
• Login history, session timestamps, and IP addresses at time of login
• Gameplay history across all 46ph games including slots, baccarat, bingo, crash, and sports betting
• Bonus usage, wagering activity, and VIP tier status
• Responsible gaming tool settings (deposit limits, self-exclusion periods, etc.)

3.5 Technical Data

• Device type, operating system, and browser type
• Internet Protocol (IP) address
• Cookie identifiers and session tokens
• Referring URLs and navigation patterns within the 46ph platform

3.6 Communications Data

• Records of customer support interactions via live chat or email
• Feedback submissions, survey responses, and complaint records

4. How We Collect Your Personal Data

4.1 Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in a promotion, or voluntarily provide information through any part of the 46ph platform.

4.2 Automatically — through cookies, web beacons, server logs, and similar tracking technologies when you visit or interact with the 46ph website or platform. See Section 10 for full details on cookies.

4.3 From third parties — including identity verification service providers, payment processors (GCash, PayMaya, banks), fraud detection agencies, and regulatory bodies such as PAGCOR where data sharing is permitted or required by law.

5. How We Use Your Personal Data

5.1 46ph processes your personal data for the following purposes:

5.2 46ph will not use your personal data for any purpose that is incompatible with the purposes listed above without obtaining your prior consent, except where required by law.

6. Legal Basis for Processing

6.1 Under the Philippine Data Privacy Act, 46ph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions, including account management, payment processing, and gaming service delivery.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, the Philippine Data Privacy Act, and other applicable laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming enforcement, and general platform improvement, where these interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit and freely given consent that can be withdrawn at any time.

7. Data Sharing & Disclosure

7.1 46ph may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Identity verification providers: Third-party KYC service providers engaged to verify player identity documents and age.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, as required to process transactions.
• Fraud and AML screening providers: Service providers that assist in detecting suspicious transactions and preventing financial crime.
• Game content providers: Game software providers who supply casino games on the 46ph platform may receive anonymized gameplay data for quality assurance purposes.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government agencies, as required by Philippine law.
• Law enforcement: Philippine law enforcement agencies (PNP, NBI) when legally required or in response to a valid court order.

7.2 46ph does not sell, rent, lease, or otherwise transfer your personal data to any third party for commercial or marketing purposes.

7.3 All third-party service providers who process personal data on behalf of 46ph are bound by data processing agreements that require them to maintain appropriate security measures and process data only as instructed by 46ph.

8. Data Retention

8.1 46ph retains your personal data for as long as your account remains active and for such additional periods as are required by law or legitimate business necessity. Specific retention periods include:

• Account and identity data: Retained for the duration of your account plus a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Transaction and financial data: Retained for a minimum of ten (10) years in compliance with the Anti-Money Laundering Act of the Philippines.
• Customer support records: Retained for three (3) years from the date of the interaction.
• Marketing consent records: Retained for the period of consent plus three (3) years to evidence compliance.

8.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized so that it can no longer be associated with any individual player.

9. Security Measures

9.1 46ph implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit
• Encryption of sensitive data at rest on secured servers
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• Multi-factor authentication for internal system access
• Regular penetration testing and vulnerability assessments
• Intrusion detection and prevention systems (IDPS)
• Regular staff training on data protection and information security
• Incident response procedures aligned with NPC breach notification requirements

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 46ph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach and will notify affected players without undue delay.

10. Cookies & Tracking Technologies

10.1 46ph uses cookies and similar tracking technologies to enhance platform functionality, maintain session security, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for platform functionality, user authentication, and session management. These cannot be disabled without affecting your ability to use the platform.
• Performance and Analytics Cookies: Used to understand how players interact with the 46ph platform in aggregate, enabling us to improve site performance and user experience. Data is anonymized.
• Functional Cookies: Used to remember your platform preferences such as language settings and display options.
• Marketing Cookies: Used to deliver relevant promotional content based on your interests, only where you have given consent.

10.2 You can control non-essential cookies through your browser settings or by adjusting your cookie preferences via the 46ph cookie consent tool. Disabling strictly necessary cookies may impair platform functionality.

11. Your Rights as a Data Subject

11.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 46ph:

• Right to be informed: The right to know how your personal data is being collected, used, and processed.
• Right of access: The right to obtain a copy of the personal data 46ph holds about you.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected.
• Right to erasure or blocking: The right to request the deletion or blocking of personal data that is unlawfully processed or no longer necessary for the purpose for which it was collected, subject to legal retention requirements.
• Right to object: The right to object to the processing of your personal data for direct marketing or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where processing is based on consent or contractual necessity.
• Right to damages: The right to claim compensation for damages sustained due to unauthorized or unlawful processing of personal data.
• Right to complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

11.2 To exercise any of the above rights, please contact the 46ph Data Protection Officer using the details provided in Section 15. We will respond to all data subject requests within thirty (30) calendar days of receipt.

12. Protection of Minors

12.1 The 46ph platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming laws and PAGCOR regulations. 46ph does not knowingly collect personal data from persons under the age of 21.

12.2 All account registrations are subject to age verification procedures. Where 46ph becomes aware that personal data has been collected from an underage individual, that account will be immediately suspended, all personal data will be deleted, and any deposited funds will be handled in accordance with our regulatory obligations.

12.3 If you are a parent or guardian and believe that your child under 21 has registered an account with 46ph, please contact our DPO immediately using the contact details in Section 15.

13. Cross-Border Data Transfers

13.1 Some of 46ph's third-party service providers — including game software providers, cloud infrastructure providers, and analytics platforms — may be located outside the Philippines. Where personal data is transferred to recipients in countries that do not provide an equivalent level of data protection to that afforded by Philippine law, 46ph ensures that appropriate safeguards are in place, including contractual clauses approved by the National Privacy Commission or equivalent protections.

13.2 By registering an account with 46ph, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines for the purposes described in this Policy, subject to the safeguards described above.

14. Amendments to This Policy

14.1 46ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is shown at the top of this page.

14.2 For material changes to this Policy that significantly affect how we process your personal data, 46ph will provide notice via your registered email address or through an in-platform notification prior to the change taking effect.

14.3 Continued use of the 46ph platform following the publication of an amended Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with the amended Policy, you may close your account by contacting customer support.

15. Contact & Data Protection Officer

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 46ph, please contact our Data Protection Officer through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: "Data Privacy Request – [Your Registered Username]"
• Live Chat: Available 24/7 from your account dashboard
• Response Time: Within 30 calendar days of receipt

15.2 If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through their official government portal and channels.