010ph Privacy Policy

1. Who We Are & How to Contact Us

1.1 The 010ph platform is operated by the 010ph group of companies ("010ph," "we," "us," "our"). For all privacy-related inquiries, you may contact our Data Protection Officer (DPO) at the following address:

• Email: [email protected] (plain text — not a clickable link)
• Subject line: "Privacy Inquiry / Data Subject Request"
• Response time: We aim to respond to all privacy requests within fifteen (15) business days of receipt.

1.2 010ph serves players primarily in the Philippines. Where applicable, we register with and report to the National Privacy Commission (NPC) as required under RA 10173.

2. Data We Collect & Why

2.1 010ph collects personal data across several categories. The table below summarises each category, specific data points collected, and the primary purpose for collection:

2.2 We do not intentionally collect sensitive personal information such as biometric data, genetic data, or detailed health records unless explicitly required by a specific regulatory obligation and with your prior consent.

3. Legal Basis for Processing

3.1 Under the Data Privacy Act of 2012 and generally accepted data protection principles, 010ph processes your personal data on the following lawful bases:

• Contractual necessity: Processing required to open your account, process transactions, and deliver the services you have requested from 010ph;
• Legal obligation: Processing required to comply with Philippine anti-money laundering laws, gaming regulations, and tax obligations;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where we have obtained your explicit prior consent.

3.2 Where consent is the legal basis for processing, you may withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal.

4. How We Use Your Data

4.1 010ph uses the personal data we collect for the following specific purposes:

• To create and administer your 010ph account and verify your identity in compliance with KYC requirements;
• To process deposits and withdrawals through your chosen Philippine payment method, including GCash, Maya, BPI, or BDO;
• To deliver and personalise gaming services, including surfacing games, bonuses, and promotions relevant to your preferences and playing history;
• To detect and prevent fraud, money laundering, and other unlawful activities on the platform;
• To enforce responsible gaming obligations, including monitoring for signs of problematic gaming behaviour and enforcing self-exclusion requests;
• To communicate with you regarding your account, transactions, promotional offers (where consented), and material changes to our policies;
• To comply with regulatory requirements, including reporting obligations to the relevant Philippine gaming and financial regulatory authorities;
• To improve and develop the platform through aggregated analytics and user feedback.

5. Disclosure to Third Parties

5.1 010ph does not sell your personal data. We may share your data with third parties only in the following circumstances:

• Payment processors: We share the minimum necessary payment information with GCash, Maya, and other approved Philippine payment service providers to process your transactions;
• Game providers: Where required to resolve disputes or detect fraud, we may share relevant gaming session data with licensed third-party game software providers;
• Regulatory authorities: We are legally obligated to disclose certain data to Philippine gaming regulators, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and law enforcement authorities where required by law;
• Service providers: We engage trusted third-party vendors for services such as identity verification, cloud hosting, customer support software, and cybersecurity. These vendors are contractually bound to process your data only on our instructions and in accordance with applicable Philippine data protection law;
• Corporate transactions: In the event of a merger, acquisition, or asset sale, your data may be transferred to the acquiring entity, subject to the same privacy protections set out in this Policy.

5.2 All third parties that receive personal data from 010ph are subject to data processing agreements that require them to maintain appropriate security measures and limit use of your data to the purposes for which it was shared.

6. Cookies & Tracking Technologies

6.1 010ph uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged into your 010ph account. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and game lobby filters, to personalise your experience.
• Analytics Cookies: Allow us to understand how players navigate and use the platform so we can improve it. Data collected is aggregated and anonymised where possible.
• Security Cookies: Support our fraud detection and bot prevention systems to protect your 010ph account.

6.2 You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 010ph platform.

7. Data Retention

7.1 010ph retains personal data for as long as is necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by applicable Philippine law. Our general retention guidelines are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and gaming regulations;
• Financial transaction data: Retained for a minimum of five (5) years from the date of each transaction, as required by the AMLC and relevant tax regulations;
• Gaming session data: Retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes;
• Communications data: Support communications are retained for two (2) years; marketing consent records are retained until consent is withdrawn plus one (1) year;
• Technical and security logs: Retained for up to twelve (12) months for security analysis and fraud investigation.

7.2 When the applicable retention period expires and no further legal basis exists for retention, your data will be securely deleted or anonymised.

8. Security Measures

8.1 010ph implements technical and organisational security measures proportionate to the sensitivity of the data we process and the risks involved. These measures include:

• TLS 1.3 encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data stored at rest;
• One-way cryptographic hashing for all stored passwords;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Continuous intrusion detection and 24/7 security monitoring;
• Regular vulnerability assessments and penetration testing by qualified third-party security professionals;
• Multi-factor authentication requirements for all staff accessing systems that hold personal data.

9. Your Rights as a Data Subject

9.1 As a data subject under the Philippines' Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 010ph:

• Right to be Informed: You have the right to know what personal data 010ph collects, how it is used, and to whom it is disclosed. This Policy fulfils that obligation.
• Right of Access: You may request a copy of the personal data we hold about you at any time.
• Right to Rectification: If your data is inaccurate or incomplete, you have the right to request correction.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to Object: You may object to the processing of your personal data for marketing purposes or processing based on legitimate interests at any time.
• Right to Data Portability: Where technically feasible, you may request a copy of your data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: If you believe your data rights have been violated, you may file a complaint with the National Privacy Commission of the Philippines.

9.2 To exercise any of the above rights, contact our Data Protection Officer at [email protected] with the subject line "Data Subject Request." We will verify your identity before processing the request and respond within fifteen (15) business days.

10. Children & Minors

10.1 The 010ph platform is strictly for adults aged 21 years and older. We do not knowingly collect personal data from persons under the age of 21. If we discover that an account has been created by an underage individual, we will immediately close the account, forfeit any associated balances, and securely delete all related personal data.

10.2 If you believe a minor has registered on the 010ph platform, please contact our support team immediately so that we can investigate and take appropriate action.

11. Changes to This Policy

11.1 010ph may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify registered players by email or through a prominent notice on the platform at least seven (7) days before the changes take effect.

11.2 The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of 010ph after the effective date of any revision constitutes acceptance of the updated Policy.