88phx Privacy Policy

1. Introduction

This Privacy Policy ("Policy") applies to the online gaming platform operated under the brand name 88phx, accessible at https://88phx.cam and all associated subdomains and mobile-optimised versions thereof (collectively, the "Platform"). References to "88phx," "we," "us," and "our" in this Policy refer to the operator of the Platform. References to "you," "your," and "Player" refer to any individual who accesses, registers on, or uses the Platform.

88phx recognises that your personal data is yours, and we take seriously our obligations as a data controller operating within the Philippine regulatory environment. This Policy is designed to comply with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission ("NPC").

By registering an account on 88phx, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you should not register an account or continue using the Platform.

2. Data Controller Identity

88phx acts as the data controller in respect of the personal data you provide when registering for and using the Platform. As data controller, 88phx determines the purposes for which and the manner in which your personal data is processed.

88phx operates under a licence issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to all applicable PAGCOR data handling and player information requirements in addition to the obligations imposed by the DPA. All data processing activities conducted by 88phx are carried out within the bounds of the Platform's PAGCOR licence conditions.

For all privacy-related enquiries, requests, and complaints, you may contact our designated Data Privacy Officer ("DPO") through the contact details provided in Section 15 of this Policy.

3. Categories of Personal Data We Collect

88phx collects personal data across several categories, each serving a specific and documented purpose. The categories of data we collect include:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (for mandatory age verification — players must be 21 years of age or older)
• Registered Philippine mobile number
• Email address (where provided)
• Residential address (required at KYC verification stage)
• Nationality and country of residence

3.2 Identity Verification Documents

• Copies of government-issued identification documents submitted for KYC purposes, including but not limited to: Philippine Passport, SSS ID, GSIS ID, PhilHealth ID, Postal ID, and LTO Driver's Licence
• Proof of address documentation where required
• Source of funds documentation where required under Anti-Money Laundering (AML) obligations

3.3 Financial and Transaction Data

• GCash mobile number and account identifiers associated with deposit and withdrawal transactions
• Maya (formerly PayMaya) account identifiers
• Bank account details for players using BPI, BDO, Metrobank, or other supported bank transfer channels
• Complete transaction history including deposits, withdrawals, bonus credits, and adjustments
• Currency denomination and transaction timestamps

3.4 Gaming and Behavioural Data

• Game session history, including games played, stakes wagered, and outcomes
• Bonus participation and wagering requirement progress
• Session durations and frequency of play
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, cooling-off periods)

3.5 Technical and Device Data

• IP address at time of registration and each subsequent login
• Device type, operating system, and browser information
• Device identifiers and fingerprinting data used for fraud prevention and security monitoring
• Geographic location data (country/region level) derived from IP address

3.6 Customer Support Data

• Records of all communications between you and the 88phx support team, including live chat transcripts, support ticket contents, and any attachments submitted in connection with a support request
• Records of formal complaints and dispute resolution proceedings

4. How We Collect Your Personal Data

88phx collects personal data through the following channels and mechanisms:

• Direct submission: Data you provide voluntarily when completing account registration, undergoing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technical collection: Data collected automatically when you access and use the Platform, including IP addresses, device identifiers, session activity logs, and cookie data.
• Payment providers: Transaction confirmation data received from GCash, Maya, QR Ph, and banking partners as part of deposit and withdrawal processing.
• Third-party game providers: Aggregated game session data received from licensed game studios including JILI, Pragmatic Play, PG Soft, Evolution Gaming, and others whose titles are hosted on the Platform.
• Fraud prevention and security partners: Data received from third-party identity verification and fraud detection services engaged to support the Platform's AML and KYC compliance obligations.

5. How 88phx Uses Your Personal Data

88phx processes your personal data only for specific, documented, and legitimate purposes. The primary purposes for which we use your data are set out in the table below:

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 88phx processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform 88phx's obligations under the Player Account Agreement, including account creation, payment processing, game access, and withdrawal handling.
• Legal obligation: Processing required for compliance with PAGCOR licensing conditions, AML obligations under Republic Act No. 9160 as amended, AMLC reporting requirements, tax obligations, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained and may be withdrawn at any time.

7. Data Sharing and Disclosure

88phx does not sell your personal data to third parties. We share your personal data only in the following limited circumstances and only to the extent necessary for the stated purpose:

• Payment processors: GCash (GXI / G-Xchange Inc.), Maya Philippines Inc., QR Ph partner banks, BPI, BDO, Metrobank, and other payment channel providers, for the sole purpose of processing your deposit and withdrawal transactions.
• Game providers: Licensed game studios whose titles are hosted on the Platform (e.g. JILI, Pragmatic Play, PG Soft, Evolution Gaming, Asia Gaming), to the extent required to deliver game sessions and handle game-related disputes.
• KYC and identity verification partners: Third-party service providers engaged to assist with identity verification, document authentication, and fraud screening as part of the KYC and AML compliance process.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other Philippine government authority with legal jurisdiction to require disclosure of Player data.
• Law enforcement: Philippine law enforcement agencies where disclosure is required by court order, warrant, or other lawful process.
• IT and infrastructure service providers: Cloud hosting, data centre, and cybersecurity service providers engaged to operate and secure the Platform, under strict data processing agreements that prohibit independent use of your data.

8. Data Retention

88phx retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any longer retention periods required by applicable Philippine law or PAGCOR licensing conditions. The following general retention principles apply:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AML obligations.
• KYC documents: Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later, as required under the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction in compliance with AMLC record-keeping requirements.
• Customer support records: Retained for a minimum of three (3) years following the closure of the relevant support case or complaint.
• Marketing consent records: Retained for the duration of your consent and for a reasonable period thereafter as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

9. Data Security Measures

88phx implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 88phx Platform
• Encryption of sensitive personal data at rest in our databases
• Two-factor authentication (2FA) tied to your registered Philippine mobile number for account access
• Device fingerprinting and anomaly detection systems that flag unusual login patterns or access attempts
• Role-based access controls limiting internal access to personal data to authorised personnel only
• Regular internal security audits and penetration testing
• Incident response procedures in accordance with NPC breach notification requirements under the DPA

In the event of a personal data breach that is likely to result in a real risk of harm to affected individuals, 88phx 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, in accordance with the DPA and NPC Circular No. 16-03.

10. Cookies and Tracking Technologies

88phx uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device when you visit a website. We use the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function correctly, including maintaining your login session, processing transactions, and applying security measures. These cannot be disabled without impairing Platform functionality.
• Performance and analytics cookies: Used to collect anonymised information about how Players use the Platform, including pages visited, session duration, and navigation patterns. This data is used to improve Platform performance and user experience.
• Functional cookies: Used to remember your preferences and settings (such as language selection and responsible gaming tool configurations) to provide a more personalised experience.
• Marketing cookies: Used, with your consent, to understand your interests and deliver relevant promotional content within the Platform. These are only activated following your explicit consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as their use is essential to the provision of the service you have requested.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by 88phx:

To exercise any of the above rights, please contact our Data Privacy Officer using the details in Section 15. 88phx will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12. Minors and Age Policy

The 88phx Platform is strictly intended for individuals who are 21 years of age or older. This minimum age requirement is mandated by PAGCOR for casino-style online gaming in the Philippines and is enforced by 88phx at registration through automated age-check procedures and at the KYC withdrawal verification stage through documentary review.

88phx does not knowingly collect, process, or retain personal data from individuals under the age of 21. If 88phx becomes aware that it has collected personal data from a person under 21 years of age, it will immediately suspend the relevant account, delete the associated personal data (subject to any mandatory retention obligations), and take such further action as is required under applicable law.

If you are a parent or guardian and believe that a person under 21 in your care has registered on the 88phx Platform, please contact our support team immediately through the channels described in Section 15.

13. International Data Transfers

Some of 88phx's service providers and game studio partners may be located outside the Philippines. Where personal data is transferred to a recipient in a country that does not provide a level of data protection equivalent to that afforded under the DPA, 88phx will take appropriate steps to ensure that the transfer is subject to adequate safeguards, including but not limited to contractual clauses approved by the NPC, binding corporate rules, or other recognised transfer mechanisms under DPA Section 21 and NPC guidelines.

Any cross-border transfer of personal data by 88phx is carried out in accordance with the DPA and does not proceed until 88phx has satisfied itself that appropriate protections are in place for your personal data in the recipient jurisdiction.

14. Changes to This Privacy Policy

88phx may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, 88phx will post the revised Policy on the Platform with an updated effective date and, where feasible, notify registered Players via their registered mobile number or email address.

Your continued use of the 88phx Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to remain informed of how your data is being handled.

15. Contact Our Data Privacy Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or need to report a privacy concern, please contact 88phx's designated Data Privacy Officer through the following channels:

• Live Chat: 24/7 support accessible from the Platform navigation — select "Privacy / Data Request" from the support menu
• Email (plain text): [email protected]
• Subject line for data requests: "Data Privacy Request – [Your Account Mobile Number]"
• Response timeframe: Acknowledged within 72 hours; substantive response within 15 business days
• Operating hours: 24 hours a day, 7 days a week — Philippine Standard Time (PST / UTC+8)

For complaints that cannot be resolved through 88phx's internal process, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines.