117ph Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") governs the collection, processing, storage, and disclosure of personal data by 117ph, a PAGCOR-licensed online gaming operator serving residents of the Republic of the Philippines. This Policy applies to all users of the 117ph website, mobile applications, and related services (collectively, the "Platform").

117ph acts as the data controller for personal data processed through the Platform. We are responsible for determining the purposes and means of processing your personal data and ensuring compliance with applicable data protection laws, including the Data Privacy Act of 2012, its Implementing Rules and Regulations, and relevant National Privacy Commission (NPC) circulars.

By registering an account, depositing funds, or using any services on 117ph, you acknowledge that you have read, understood, and agreed to the data practices described in this Policy. If you do not agree with any provision of this Policy, you must immediately cease use of the Platform.

2. Data Controller and Contact Information

The data controller responsible for your personal data is:

117ph
Email: [email protected]
Data Protection Officer Email: [email protected]

If you have questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer using the email address provided above. We will respond to all inquiries within fifteen (15) business days in accordance with Data Privacy Act requirements.

3. Types of Personal Data We Collect

117ph collects various categories of personal data necessary to provide gaming services, comply with legal obligations, and ensure platform security. The types of personal data we collect include:

3.1 Account Registration Data

When you create a 117ph account, we collect the following information:

• Personal identifiers: Full legal name, date of birth, gender, nationality, and place of birth
• Contact information: Email address, mobile phone number, and residential address
• Account credentials: Username, password (stored in encrypted form), and security questions/answers
• Authentication data: Two-factor authentication credentials, device identifiers, and biometric data (if enabled)

3.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and Anti-Money Laundering (AML) laws, we collect identity verification documents including:

• Government-issued photo identification (Philippine passport, driver's license, UMID, SSS ID, Postal ID)
• Proof of address documents (utility bills, bank statements, government correspondence dated within 3 months)
• Selfie photographs holding identification documents
• Source of funds documentation for deposits exceeding PHP 50,000 or withdrawals exceeding PHP 100,000

3.3 Financial and Transaction Data

When you deposit, withdraw, or transact on 117ph, we collect:

• Payment method details (GCash account number, bank account numbers, cryptocurrency wallet addresses)
• Transaction history (deposits, withdrawals, transfers, bonus claims)
• Payment card information (card numbers are tokenized and not stored directly by 117ph)
• Transaction amounts, dates, times, and status
• Betting and wagering activity records

3.4 Behavioral and Usage Data

We automatically collect data about how you interact with the Platform:

• Device information (IP address, device type, operating system, browser type, screen resolution)
• Location data (country, region, city derived from IP address)
• Session data (login times, logout times, session duration)
• Gameplay data (games played, bets placed, wins, losses, game duration)
• Navigation patterns (pages visited, links clicked, features used)
• Cookies and similar tracking technologies (see Section 10)

3.5 Communication Data

When you communicate with 117ph, we retain:

• Customer support chat transcripts and email correspondence
• Feedback, complaints, and dispute resolution records
• Marketing communication preferences and opt-out requests
• Survey responses and feedback forms

3.6 Third-Party Data

We may receive personal data about you from third parties, including:

• Payment processors (transaction verification, fraud detection data)
• Identity verification services (enhanced due diligence checks)
• Affiliate partners (referral information, marketing campaign data)
• Social media platforms (if you choose to register via social login)

4. Legal Basis and Purposes for Data Processing

117ph processes your personal data based on the following legal grounds as defined by the Data Privacy Act:

4.1 Contractual Necessity

Processing is necessary to fulfill our contractual obligations to you, including:

• Creating and managing your gaming account
• Processing deposits, withdrawals, and transactions
• Providing access to games, sports betting, and platform features
• Awarding bonuses, promotions, and loyalty rewards
• Providing customer support and resolving disputes

4.2 Legal Compliance

Processing is required to comply with legal obligations, including:

• PAGCOR licensing requirements and regulatory reporting
• Anti-Money Laundering and Counter-Terrorism Financing (AMLA) obligations
• Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures
• Tax reporting and financial record-keeping requirements
• Responding to lawful requests from government authorities and law enforcement
• Retention of records for audit and compliance purposes

4.3 Legitimate Interests

Processing is necessary for 117ph's legitimate business interests, provided these interests do not override your fundamental rights:

• Fraud detection, prevention, and investigation
• Platform security, system monitoring, and threat detection
• Business analytics, performance measurement, and optimization
• Internal auditing, risk management, and compliance monitoring
• Marketing communications to existing customers (subject to opt-out rights)
• Enforcement of Terms and Conditions and recovery of debts

4.4 Consent

Where required by law or where no other legal basis applies, we obtain your explicit consent for:

• Marketing communications via email, SMS, or push notifications (you may withdraw consent at any time)
• Use of optional cookies and tracking technologies for personalization
• Disclosure of personal data to third parties beyond what is necessary for service provision
• Processing of sensitive personal information contained in identity documents

5. How We Use Your Personal Data

117ph uses your personal data for the following purposes:

Purpose	Description
Account Management	Create, maintain, and secure your gaming account; authenticate your identity; manage account settings and preferences.
Transaction Processing	Process deposits, withdrawals, and financial transactions; reconcile accounts; issue receipts and transaction confirmations.
Game Provision	Provide access to casino games, sports betting, live dealer games, and other gaming products; track game results and maintain game history.
Bonus Administration	Award bonuses, promotions, free spins, and loyalty rewards; track wagering requirements; enforce bonus terms and conditions.
Customer Support	Respond to inquiries, troubleshoot issues, resolve disputes, and provide technical assistance.
Regulatory Compliance	Verify player identity and age; conduct KYC/AML checks; report suspicious transactions; comply with PAGCOR regulations.
Fraud Prevention	Detect and prevent fraudulent activity, account abuse, bonus abuse, money laundering, and unauthorized access.
Platform Security	Monitor system activity; identify security threats; prevent cyberattacks; maintain platform integrity.
Responsible Gaming	Implement deposit limits, self-exclusion, and cooling-off periods; identify problem gambling patterns; provide responsible gaming resources.
Marketing Communications	Send promotional emails, SMS messages, push notifications; personalize offers based on gaming preferences; conduct surveys.
Business Analytics	Analyze user behavior, gameplay patterns, and platform performance; optimize user experience; conduct market research.

6. Data Sharing and Disclosure

117ph does not sell, rent, or trade your personal data to third parties for their marketing purposes. We share your data only in the following circumstances:

6.1 Service Providers and Business Partners

We engage third-party service providers to perform functions on our behalf. These providers are contractually obligated to process data only as instructed by 117ph and to implement appropriate security measures. Categories of service providers include:

• Payment processors: GCash, PayMaya, bank payment gateways, cryptocurrency processors
• Identity verification services: KYC/AML screening providers, document authentication services
• Game providers: Casino game developers, live dealer platform operators, sportsbook odds providers
• Technology infrastructure: Cloud hosting providers, content delivery networks (CDNs), data centers
• Customer support tools: Live chat platforms, ticketing systems, email service providers
• Marketing platforms: Email marketing services, SMS gateways, push notification providers
• Analytics and optimization: Web analytics tools, A/B testing platforms, heatmap services

6.2 Regulatory Authorities and Law Enforcement

We disclose personal data to government authorities when required by law or when we have reasonable grounds to believe disclosure is necessary to:

• Comply with PAGCOR reporting requirements and regulatory investigations
• Respond to lawful requests, court orders, subpoenas, or legal process
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Cooperate with law enforcement investigations into fraud, money laundering, or other criminal activity
• Comply with tax reporting obligations to the Bureau of Internal Revenue (BIR)

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you via email or platform notification before such transfer and provide information about the new data controller.

6.4 Fraud Prevention Networks

We participate in fraud prevention networks and may share data with other gaming operators, financial institutions, and fraud detection services to identify and prevent fraudulent activity, chargebacks, and account abuse.

6.5 With Your Consent

We may share your personal data with third parties for purposes not covered above when you provide explicit consent. You may withdraw such consent at any time by contacting our Data Protection Officer.

7. International Data Transfers

117ph operates primarily within the Philippines, and your personal data is stored on servers located in the Philippines or in jurisdictions with adequate data protection standards as recognized by the National Privacy Commission.

Some of our service providers, particularly technology infrastructure providers and game developers, may be located outside the Philippines. When we transfer personal data internationally, we ensure that:

• The recipient country has been deemed to provide adequate data protection by the NPC, or
• We implement appropriate safeguards such as standard contractual clauses, binding corporate rules, or other mechanisms approved by the NPC, and
• We obtain your consent where required by law for transfers to countries without adequate protection

You have the right to request information about the safeguards we use for international data transfers by contacting our Data Protection Officer.

8. Data Retention

117ph retains your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Retention periods vary based on data type and legal obligations:

Data Category	Retention Period
Account registration data	Duration of account plus 5 years after account closure
Identity verification (KYC) documents	5 years after account closure (AMLA requirement)
Financial transaction records	5 years after transaction date (tax and AMLA requirements)
Betting and gaming history	5 years after transaction date (PAGCOR requirement)
Customer support communications	3 years after case closure
Marketing communications records	Until opt-out, then deleted within 30 days
System logs and security records	1-2 years depending on log type
Fraud investigation records	7 years after investigation conclusion

After retention periods expire, we securely delete or anonymize personal data in accordance with our data deletion procedures. Anonymized data may be retained indefinitely for statistical and research purposes.

You may request deletion of your personal data at any time, subject to our legal retention obligations. If we cannot delete data due to legal requirements, we will restrict processing and retain only the minimum necessary data.

9. Data Security Measures

117ph implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

9.1 Technical Safeguards

• Encryption: All data transmissions use TLS 1.2+ encryption; sensitive data at rest is encrypted using AES-256
• Access controls: Role-based access control (RBAC) with principle of least privilege; multi-factor authentication for administrative access
• Firewall protection: Web application firewalls (WAF) and network firewalls to prevent unauthorized access
• Intrusion detection: Real-time monitoring systems to detect and respond to security threats
• Secure architecture: Data segregation, network segmentation, and secure coding practices
• Regular security testing: Penetration testing, vulnerability assessments, and security audits

9.2 Organizational Safeguards

• Employee training on data protection and security best practices
• Confidentiality agreements with employees and contractors
• Background checks for personnel with access to sensitive data
• Incident response plans and breach notification procedures
• Regular compliance audits and third-party security certifications
• Vendor security assessments and contractual security requirements

9.3 Account Security

You are responsible for maintaining the security of your account credentials. We recommend:

• Using strong, unique passwords (minimum 8 characters with uppercase, lowercase, numbers, and symbols)
• Enabling two-factor authentication (2FA) for additional protection
• Never sharing your password or account credentials with others
• Logging out after each session, especially on shared devices
• Keeping your email account secure (password reset emails are a common attack vector)
• Reporting suspicious account activity immediately

Despite our security measures, no system is completely secure. In the event of a data breach affecting your personal data, we will notify you and the National Privacy Commission within seventy-two (72) hours of discovery as required by the Data Privacy Act.

10. Cookies and Tracking Technologies

117ph uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance user experience, analyze platform usage, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize you on return visits.

10.1 Types of Cookies We Use

• Essential cookies: Required for platform functionality, security, and authentication. These cannot be disabled.
• Performance cookies: Collect anonymous data about how users interact with the Platform to improve performance.
• Functionality cookies: Remember your preferences, settings, and login status for convenience.
• Analytics cookies: Help us understand user behavior, traffic sources, and popular content.
• Marketing cookies: Track your activity to deliver personalized promotions and measure campaign effectiveness.

10.2 Cookie Management

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, but disabling essential cookies may affect platform functionality. To opt out of analytics cookies, visit your account settings or use browser privacy tools.

For more information about cookies and how to control them, visit www.allaboutcookies.org or your browser's help documentation.

11. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act, you have the following rights regarding your personal data:

11.1 Right to be Informed

You have the right to be informed about the collection, use, and disclosure of your personal data. This Privacy Policy serves to fulfill this obligation.

11.2 Right to Access

You may request access to your personal data held by 117ph. We will provide a copy of your data in a commonly used electronic format within fifteen (15) business days of receiving a verified request.

11.3 Right to Rectification

You may request correction of inaccurate or incomplete personal data. You can update most account information directly through your account settings, or contact customer support for assistance.

11.4 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data when it is no longer necessary for the purposes for which it was collected. However, we may retain data when required by law (e.g., AML/KYC records must be kept for 5 years).

11.5 Right to Object

You may object to processing based on legitimate interests or for direct marketing purposes. We will cease such processing unless we demonstrate compelling legitimate grounds that override your rights.

11.6 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible.

11.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

11.8 How to Exercise Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond within fifteen (15) business days. You may be required to verify your identity before we process your request.

If you are dissatisfied with our response, you have the right to lodge a complaint with the National Privacy Commission at www.privacy.gov.ph or via their complaint hotline.

12. Children's Privacy

117ph services are strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from minors. If we discover that we have inadvertently collected data from a person under 21, we will delete such data immediately and close the associated account.

If you believe a minor has provided personal data to 117ph, please contact us immediately at [email protected]. Parents and guardians are encouraged to monitor their children's online activities and prevent access to gambling platforms.

13. Third-Party Links and Services

The 117ph Platform may contain links to third-party websites, payment processors, or services. This Privacy Policy does not apply to third-party sites. We are not responsible for the privacy practices of external websites or services.

Before providing personal data to third-party services, we recommend reviewing their privacy policies. Third-party payment processors (GCash, PayMaya, banks) have their own data collection and privacy practices independent of 117ph.

14. Changes to This Privacy Policy

117ph reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated via email or prominent platform notification at least thirty (30) days before taking effect.

The "Last Updated" date at the top of this Policy indicates when it was last revised. Continued use of the Platform after changes become effective constitutes acceptance of the updated Policy. If you do not agree with changes, you must cease using the Platform and may request account closure.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.