78ph Privacy Policy

1. Data Controller

78ph ("78ph," "we," "us," "our") is the data controller responsible for the personal information collected through the website at 78ph.asia and all associated services, features, and promotions (collectively, the "Platform").

If you have any questions about how your data is handled, please contact us at the details provided in Section 12. We are committed to protecting your privacy in accordance with applicable data protection laws of the Republic of the Philippines, including Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations.

2. Personal Data We Collect

When you register for and use a 78ph account, we may collect the following categories of personal data:

We collect only the data that is necessary for the purposes described in this Policy. We do not collect sensitive personal information such as biometric data or health records unless required by law or explicit consent is obtained.

3. How We Collect Your Data

78ph collects personal data through the following means:

• Direct interactions: Data you provide when you register your 78ph account, complete KYC verification, make deposits or withdrawals, contact support, or respond to promotions.
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, and server logs. See Section 8 for our Cookie Policy.
• Third-party sources: Data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, fraud prevention services, and analytics providers, in each case subject to their own privacy policies.
• Publicly available sources: Where permitted by law, we may supplement your data with information from publicly available databases for fraud prevention and AML compliance purposes.

4. Purposes and Legal Basis for Processing

We process your personal data for the following purposes and on the following legal bases:

• Account registration and management — necessary for the performance of our contract with you as a registered 78ph player.
• Payment processing and financial transactions — necessary for the performance of our contract and compliance with legal obligations under AML regulations.
• Identity verification (KYC) — required by applicable Philippine gaming and anti-money laundering regulations; constitutes a legal obligation.
• Fraud prevention and platform security — constitutes our legitimate interest in protecting 78ph, its players, and the integrity of the Platform.
• Customer support — necessary for the performance of our contract and our legitimate interest in maintaining service quality.
• Responsible gaming monitoring — required by applicable gaming regulations and our legitimate interest in player welfare.
• Marketing and promotions — based on your consent, where you have opted in to receive marketing communications. You may withdraw consent at any time.
• Platform analytics and improvement — based on our legitimate interest in understanding how Filipino players use the Platform and improving our services.
• Legal and regulatory compliance — necessary to comply with our obligations under Philippine law, including reporting obligations to relevant regulatory authorities.

5. Sharing Your Personal Data

78ph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processors, solely to facilitate your financial transactions on the Platform.
• Identity verification and KYC providers: Regulated third-party services used to verify your identity and comply with AML obligations.
• IT and platform service providers: Cloud hosting, data storage, cybersecurity, and analytics providers engaged by 78ph under data processing agreements that impose obligations equivalent to this Policy.
• Fraud prevention and AML monitoring services: Services used to detect and prevent fraud, money laundering, and other unlawful activity on the Platform.
• Regulatory and law enforcement authorities: Where required by Philippine law, court order, or binding regulatory direction — including PAGCOR and the Anti-Money Laundering Council (AMLC) — we will disclose personal data as legally required.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or part of 78ph's business, personal data may be transferred to the acquiring entity, subject to the same level of data protection as this Policy.

All third-party recipients are required to process your data lawfully and only for the specific purpose for which it was shared. 78ph does not transfer personal data outside the Philippines unless adequate data protection safeguards are in place.

6. Data Retention

78ph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, and regulatory reporting requirements.

• Account data: Retained for the duration of your active 78ph account and for a minimum of five (5) years after account closure, in compliance with applicable AML and gaming regulations.
• Financial transaction records: Retained for a minimum of ten (10) years in accordance with Philippine AML and banking regulation requirements.
• KYC / identity documents: Retained for the period required by applicable law from the date of last transaction or account closure, whichever is later.
• Marketing data: Retained until you withdraw your consent or request erasure, provided no overriding legal obligation requires continued retention.

When data is no longer required, 78ph securely destroys or anonymises it.

7. Security Measures

78ph implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, and disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 78ph servers.
• Encryption of sensitive data at rest, including financial and identity records.
• Role-based access controls restricting employee access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments of the Platform.
• Multi-factor authentication requirements for staff accessing systems that store personal data.
• Incident response procedures and mandatory data breach notification protocols in accordance with applicable Philippine law.

While 78ph takes all reasonable precautions, no online platform can guarantee absolute security. You are responsible for keeping your 78ph login credentials confidential. Report any suspected unauthorised account access to [email protected] immediately.

8. Cookies and Tracking Technologies

The 78ph Platform uses cookies and similar tracking technologies to enable core functionality, remember your preferences, analyse Platform usage, and deliver relevant content. The categories of cookies we use are:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled without breaking core features such as login sessions and account access.
• Functional cookies: Used to remember your preferences (e.g., language, currency) to improve your experience on subsequent 78ph visits.
• Analytics cookies: Used to understand how Filipino players navigate the Platform so we can improve usability and content. Data collected is aggregated and anonymised.
• Marketing cookies: Used only with your consent to deliver relevant promotions and track the effectiveness of 78ph marketing campaigns.

You can manage or withdraw consent for non-essential cookies through your browser settings at any time. Note that disabling certain cookies may affect Platform functionality.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 and applicable data protection law, you have the following rights in relation to the personal data 78ph holds about you:

• Right to be informed: You have the right to be told how your personal data is being used, as set out in this Policy.
• Right of access: You may request a copy of the personal data 78ph holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where there is no overriding legal obligation requiring retention.
• Right to object: You may object to processing based on legitimate interests, including direct marketing.
• Right to data portability: You may request a machine-readable copy of personal data you have provided to 78ph.
• Right to withdraw consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond within 30 days of receiving your request. We may require identity verification before processing rights requests.

10. Minors and Age Restriction

The 78ph Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 78ph does not knowingly collect personal data from individuals under 21 years of age.

If we become aware that personal data has been collected from a person under 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the relevant account. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

78ph reserves the right to update this Privacy Policy from time to time to reflect changes in law, regulatory requirements, or our data practices. When material changes are made, we will notify registered players by email and/or by posting a prominent notice on the Platform prior to the changes taking effect.

The "Effective Date" at the top of this Policy indicates when the current version came into force. Continued use of the 78ph Platform following notification of changes constitutes your acceptance of the updated Privacy Policy.

12. Contact and Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the 78ph Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 on the 78ph Platform
• Response time: We aim to acknowledge all data privacy enquiries within 48 hours and provide a substantive response within 30 days.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for data protection enforcement in the Philippines.