16ph Casino – Privacy Policy

1. About This Privacy Policy

This Privacy Policy ("Policy") governs the collection, processing, storage, and disclosure of personal information by 16ph Casino ("16ph," "we," "us," or "our") in connection with your use of the 16ph.club platform and all associated services (collectively, the "Platform").

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission ("NPC") of the Philippines. This Policy is also consistent with applicable PAGCOR data governance requirements.

By registering an account on 16ph Casino or otherwise using the Platform, you consent to the collection and processing of your personal information as described in this Policy. If you do not agree with this Policy, please do not use the Platform.

2. Data Controller

16ph Casino is the personal information controller ("PIC") responsible for your personal data as described in this Policy. As a PIC, 16ph determines the purposes and means of processing your personal data. Where 16ph engages third-party service providers to process data on its behalf, those providers act as personal information processors ("PIPs") and are bound by data processing agreements requiring them to protect your data to the same standard required by this Policy.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register or interact with the 16ph Casino platform, we collect:

• Full legal name as it appears on government-issued identification;
• Date of birth (for age verification — must be 21 or older);
• Philippine mobile number (primary account identifier);
• Email address (optional but recommended for account recovery);
• Residential address (required for KYC completion);
• Government-issued ID documents (UMID, Passport, Driver's License, PhilSys National ID) submitted for KYC;
• Selfie or liveness verification image where required;
• Source of funds documentation where requested.

3.2 Financial Data

We collect data necessary to process your deposits and withdrawals, including:

• GCash mobile number and account name;
• Maya account details;
• Bank account name, number, and branch (BPI, BDO, UnionBank, Metrobank);
• Cryptocurrency wallet addresses where used;
• Transaction history, including deposits, withdrawals, and wagers placed on 16ph.

Note: 16ph Casino does not store full credit or debit card numbers. All payment processing through card channels (where applicable) is handled by PCI-DSS compliant third-party processors.

3.3 Automatically Collected Technical Data

When you access the Platform, we automatically collect:

• IP address and general geolocation (country/region level);
• Device type, operating system, and browser information;
• Session timestamps and duration;
• Pages visited, features used, and game sessions initiated;
• Referring URL;
• Performance and error data for platform improvement.

3.4 Communications Data

We retain records of communications between you and 16ph Casino customer support, including live chat transcripts, email correspondence, and SMS notifications sent to your registered number.

4. How We Use Your Personal Data

16ph Casino uses your personal data for the following purposes:

• Account creation and management — to register your account, verify your identity, and manage your ongoing relationship with the Platform;
• Age and eligibility verification — to confirm that you meet the 21+ age requirement and are not subject to exclusion orders;
• Payment processing — to process your deposits and withdrawals via GCash, Maya, BPI, BDO, and other supported methods;
• Regulatory compliance — to fulfill our obligations under PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act;
• Fraud prevention and security — to detect and prevent fraudulent activity, account takeovers, bonus abuse, and money laundering;
• Customer support — to respond to your inquiries, resolve disputes, and process complaints;
• Platform improvement — to analyze usage patterns and improve platform performance, game offerings, and user experience;
• Responsible gaming — to monitor gaming behavior for signs of problem gambling and administer self-exclusion and limit tools;
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications.

5. Legal Basis for Processing

16ph Casino processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent — for marketing communications and optional data collection (you may withdraw consent at any time);
• Contractual necessity — to perform the services described in our Terms & Conditions;
• Legal obligation — to comply with PAGCOR regulatory requirements, AMLA obligations, and NPC mandates;
• Legitimate interest — for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.

6. Data Sharing & Disclosure

16ph Casino does not sell your personal data to third parties. We may share your data in the following limited circumstances:

6.1 Service Providers

We share data with vetted third-party service providers who assist us in operating the Platform, including payment processors (GCash/Maya API providers, banks), KYC/identity verification services, cloud infrastructure providers, customer support software vendors, and game content providers. All such providers are contractually bound to process your data only for the specified purpose and to maintain appropriate security standards.

6.2 Regulatory Authorities

We are required by law to disclose personal and transactional data to PAGCOR for regulatory reporting, to the Anti-Money Laundering Council (AMLC) in connection with suspicious transaction reports, and to any Philippine law enforcement agency or court presenting a lawful order or subpoena.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all assets of 16ph Casino, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer via SMS and platform announcement.

7. Cookies & Tracking Technologies

The 16ph Casino platform uses cookies and similar tracking technologies (local storage, session tokens) to operate and improve the Platform. We use the following categories of cookies:

• Strictly necessary cookies — required for login session management, security tokens, and platform functionality. These cannot be disabled without breaking the Platform.
• Performance cookies — collect anonymized data on page load times, error rates, and feature usage to help us improve the Platform.
• Functional cookies — remember your preferences such as language settings, game lobby layout, and responsible gaming limit configurations.
• Analytics cookies — used to understand aggregate traffic patterns and feature adoption. Data is anonymized before analysis.

You may control non-essential cookies through your browser settings. Disabling all cookies may impair certain Platform features. 16ph does not use cookies for cross-site advertising tracking or to build behavioral profiles for third-party ad networks.

8. Data Security

16ph Casino implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data at rest;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Multi-factor authentication for all administrative systems;
• Regular security audits and penetration testing;
• Intrusion detection and 24/7 security monitoring;
• Staff data privacy training and confidentiality obligations.

In the event of a personal data breach that is likely to result in a risk to your rights, 16ph Casino will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with NPC Circular 16-03.

9. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this Policy, to maintain your active account, and to comply with applicable legal and regulatory obligations. Specific retention periods:

• Account and identity data — retained for the duration of your account and for 5 years following account closure, as required by AMLA and PAGCOR;
• Financial transaction records — retained for 5 years from the date of each transaction per AMLA requirements;
• Gaming activity logs — retained for 3 years for regulatory reporting and dispute resolution;
• Customer support communications — retained for 2 years from the date of last contact;
• Marketing consent records — retained for the duration of your consent plus 1 year for audit purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized. Data subject to an active legal hold or regulatory investigation will be retained until the matter is resolved.

10. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 16ph Casino:

• Right to be informed — to know what personal data we hold about you and how it is being used;
• Right of access — to request a copy of the personal data we hold about you;
• Right to rectification — to request correction of inaccurate or incomplete personal data;
• Right to erasure (right to be forgotten) — to request deletion of your personal data, subject to our legal retention obligations;
• Right to object — to object to processing of your personal data for direct marketing purposes;
• Right to data portability — to receive your personal data in a structured, machine-readable format;
• Right to lodge a complaint — to file a complaint with the National Privacy Commission if you believe your rights have been violated.

To exercise any of these rights, please contact 16ph Casino through our live chat or at [email protected] (plain text) with the subject line "Data Privacy Request." We will respond within 15 calendar days in accordance with NPC requirements. We may require identity verification before processing your request.

11. Children's Privacy & Underage Access

16ph Casino is strictly prohibited for persons under 21 years of age. We do not knowingly collect personal data from individuals under the age of 21. The Platform employs age verification measures at registration, and any account found to belong to a person under 21 will be immediately suspended and personal data will be deleted promptly following resolution of any associated regulatory obligations.

If you are a parent or guardian and believe that a person under 21 has created an account on 16ph, please contact us immediately at [email protected] so we can investigate and take appropriate action.

12. International Data Transfers

While 16ph Casino primarily stores and processes data within the Philippines, certain service providers (such as cloud infrastructure or game content providers) may process data in other jurisdictions. Where such transfers occur, 16ph ensures that the receiving entity provides an adequate level of data protection equivalent to that required by the Data Privacy Act of 2012, through contractual data processing agreements, standard contractual clauses, or transfers to jurisdictions recognized as providing adequate data protection.

13. Third-Party Links

The 16ph Casino platform does not contain links to third-party websites for marketing purposes. Our navigation is entirely internal. However, to the extent that any third-party service (such as a payment gateway interface) is accessed during use of the Platform, please note that 16ph is not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party service you use in connection with your 16ph account.

14. Changes to This Privacy Policy

16ph Casino reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered players via SMS notification to the registered Philippine mobile number and via a prominent notice on the Platform, at least 7 days before the changes take effect — except where immediate changes are required by law or regulatory instruction.

Continued use of the 16ph Platform following the effective date of any revised Policy constitutes acceptance of the updated terms. The "Last Updated" date at the top of this Policy will always reflect the most recent revision.

15. Contact Our Data Protection Officer

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 16ph Casino:

This Policy is governed by the Data Privacy Act of 2012 (RA 10173) and its IRR. 16ph Casino operates in compliance with applicable Philippine gaming law under PAGCOR oversight. All players must be 21 years of age or older.