Privacy Policy — How p65com Protects Your Data

1 Introduction

p65com is a PAGC OR-registered online casino and sports betting platform dedicated to serving Filipino players across the Philippines with a secure, fair, and transparent gaming experience. We understand that when you register an account and play on p65com, you entrust us with personal information — and we take that responsibility seriously.

This Policy sets out in plain, honest terms exactly what data p65com collects from you, why we collect it, how long we keep it, who we share it with, and what rights you have over your own information under Philippine law. We have written this Policy to be as clear and accessible as possible, because we believe every Filipino player on our platform deserves to know exactly how their personal data is being handled.

p65com operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and is fully subject to the requirements of the Data Privacy Act of 2012 (RA 10173), administered by the National Privacy Commission (NPC) of the Philippines. Our data handling practices are designed to meet or exceed all applicable legal and regulatory requirements.

2 Data We Collect

p65com collects personal information only to the extent necessary to provide our gaming services, meet our legal and regulatory obligations, and maintain a secure platform for all Filipino players. The categories of personal data we collect are detailed below.

p65com does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond what is strictly required for age and identity verification under PAGCOR KYC requirements.

When you visit the p65com website without registering, we may still collect certain technical data (IP address, browser type, pages visited) for security monitoring and platform analytics. This data is not linked to any identifiable individual unless you subsequently register an account.

3 How We Use Your Data

p65com uses personal data collected from Filipino players for the following specific purposes. We do not use your data for any purpose that is incompatible with the purposes listed below without first obtaining your consent or as otherwise permitted by Philippine law.

• Account Registration & Management: To create, verify, and maintain your p65com player account, including processing your login credentials and account profile information.
• Identity & Age Verification (KYC): To verify that you are at least 21 years of age and to meet PAGCOR's mandatory Know Your Customer requirements — a non-negotiable regulatory obligation for all licensed Philippine gaming operators.
• Payment Processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other accepted Philippine payment methods, and to maintain accurate transaction records in Philippine Peso.
• Gaming Services: To deliver the p65com game library — including live casino, slots, bingo, sports betting, and Prosperity Fortune Tree — and to personalise your gaming experience based on your activity and preferences.
• Fraud Prevention & AML Compliance: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct in compliance with Philippine Anti-Money Laundering Act (AMLA) requirements.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling behaviour and to administer responsible gaming tools including deposit limits, cooling-off periods, and self-exclusion where requested or required.
• Customer Support: To respond to your queries, complaints, and support requests via live chat and email, and to maintain records of support interactions for quality assurance purposes.
• Marketing Communications: To send you promotional offers, bonus updates, and platform news — but only where you have provided your consent to receive such communications. You may withdraw consent at any time.
• Legal & Regulatory Compliance: To meet p65com's obligations under Philippine law, PAGCOR regulations, and any lawful requests from competent Philippine regulatory or law enforcement authorities.
• Platform Security & Analytics: To monitor platform traffic, detect security threats, and improve p65com's technical infrastructure and user experience for all Filipino players.

4 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), p65com processes your personal data on one or more of the following lawful bases:

• Contractual Necessity: Processing is necessary for the performance of our contract with you — namely, the provision of online gaming and betting services through the p65com Platform in accordance with our Terms & Conditions.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Legitimate Interests: Processing is necessary for p65com's legitimate business interests — including fraud prevention, platform security, and responsible gaming monitoring — provided these interests are not overridden by your rights and interests as a data subject.
• Consent: For optional processing activities such as marketing communications and non-essential cookies, p65com relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without detriment to your account.

5 Cookies & Tracking Technologies

p65com uses cookies and similar tracking technologies on our website to ensure the Platform functions correctly, to maintain your logged-in session, and to gather anonymised analytics data that helps us improve the p65com experience for all Filipino players.

The types of cookies used by p65com are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged into your p65com account during a gaming session. These cookies cannot be disabled without impairing core Platform functionality.
• Functional Cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations within your p65com account.
• Analytics Cookies: Used to collect anonymised data about how visitors and registered players interact with the p65com Platform — including pages visited, session duration, and game category preferences. This data is used in aggregate to improve platform performance.
• Security Cookies: Used to support fraud detection and platform security functions, including identifying unusual login patterns or suspicious account activity.

p65com does not use third-party advertising or behavioural tracking cookies that profile you for external advertising networks. You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to use the p65com Platform.

6 Data Sharing & Disclosure

p65com does not share your personal information with third parties except in the specific, limited circumstances described below. All third parties with whom p65com shares data are bound by contractual data processing agreements and are required to handle your information securely and in accordance with applicable Philippine law.

• Payment Service Providers: We share necessary financial data with GCash, Maya, BPI, BDO, Metrobank, and other payment processors solely to facilitate deposits and withdrawals in Philippine Peso on your behalf.
• Identity Verification Providers: We share identity data with KYC service providers to perform age verification and document authentication as required under PAGCOR regulations.
• PAGCOR & Regulatory Authorities: p65com is legally required to share data with PAGCOR and other competent Philippine regulatory authorities upon lawful request, including for AML monitoring and responsible gaming compliance purposes.
• Law Enforcement: Where required by a valid legal process — including a Philippine court order, warrant, or lawful directive from a competent authority — p65com will disclose personal data as required by law.
• Technology & Hosting Partners: Our platform infrastructure relies on secure third-party hosting and technology service providers who process data on our behalf under strict contractual data processing agreements.
• Game Content Providers: Limited technical data (such as player session tokens) may be shared with licensed game content providers to deliver game content on the p65com Platform. These providers do not receive your full personal profile.

7 Data Retention

p65com retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account Data & KYC Records: Retained for a minimum of five (5) years from the date of account closure, in accordance with PAGCOR licensing requirements and Philippine AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act of the Philippines.
• Gaming Activity Logs: Retained for two (2) years from the date of each gaming session for dispute resolution, responsible gaming monitoring, and regulatory audit purposes.
• Customer Support Records: Retained for three (3) years from the date of the last support interaction.
• Marketing Consent Records: Retained for the duration of your marketing consent plus one (1) year after withdrawal of consent.
• Technical & Security Logs: Retained for twelve (12) months for platform security and fraud detection purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with p65com's internal data lifecycle management procedures. Where data is anonymised rather than deleted, the resulting anonymised data set can no longer be linked to any identifiable individual and is no longer subject to this Policy.

8 Data Security

p65com implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security framework is regularly reviewed and updated to address evolving threats to the p65com Platform and the Filipino players who use it.

• Encryption: All data transmitted between your device and the p65com Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive stored data — including passwords and financial information — is encrypted at rest.
• Access Controls: Access to personal data within p65com's internal systems is restricted on a strict need-to-know basis. All staff with access to personal data undergo background checks and regular privacy training.
• Two-Factor Authentication: p65com strongly recommends enabling two-factor authentication (2FA) on your account. 2FA is available as an optional security enhancement for all registered players.
• Penetration Testing & Vulnerability Scanning: The p65com Platform undergoes regular security assessments, including external penetration testing and automated vulnerability scanning, to identify and remediate potential security weaknesses.
• Incident Response: p65com maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) and affected individuals within the timeframes prescribed by Philippine law.

9 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by p65com. These rights may be exercised free of charge by contacting our Data Protection Officer (DPO) using the details in Section 13.

• Right to Be Informed: The right to be told how your personal data is collected and used — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data p65com holds about you, along with information about how it is being used.
• Right to Rectification: The right to request the correction of any inaccurate, incomplete, or outdated personal data we hold about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected — subject to p65com's legal retention obligations under PAGCOR and AML regulations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on p65com's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe p65com has violated your data privacy rights. The NPC can be reached at privacy.gov.ph.

p65com will respond to all data subject rights requests within fifteen (15) business days of receipt. Where a request is complex or involves a high volume of data, we may extend this period by a further fifteen (15) business days, in which case we will notify you of the extension and the reasons for it.

10 Children's Privacy

The p65com Platform is strictly restricted to individuals aged 21 years and above, in compliance with Philippine law and PAGCOR regulations governing online casino gaming in the Philippines. p65com does not knowingly collect personal data from any person under the age of 21.

Age verification is a mandatory step in the p65com registration process. If p65com discovers that an account has been registered by, or personal data has been collected from, an individual under 21 years of age, the following actions will be taken immediately:

• The account will be permanently closed.
• All personal data associated with the underage account will be securely deleted to the extent permitted by PAGCOR regulatory requirements.
• Any funds held in the underage account will be handled in accordance with PAGCOR guidelines.
• The matter may be referred to relevant Philippine authorities where required by law.

11 Cross-Border Data Transfers

p65com is a Philippines-based platform primarily serving Filipino players. The majority of personal data processed by p65com is stored on servers located within the Philippines or within jurisdictions that provide an adequate level of data protection as recognised under the Data Privacy Act of 2012.

Where personal data is transferred outside the Philippines — for example, to international technology infrastructure providers or game content suppliers — p65com ensures that adequate safeguards are in place to protect your data. These safeguards may include:

• Standard contractual clauses approved by or consistent with the requirements of the National Privacy Commission of the Philippines.
• Binding corporate rules applicable to the relevant third-party service provider.
• Transfer to jurisdictions that the NPC has recognised as providing adequate data protection standards.

By registering and using the p65com Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside the Philippines, subject to the safeguards described in this section.

12 Amendments to This Policy

p65com reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or platform functionality. When material changes are made, the "Last Updated" date at the top of this page will be revised accordingly.

For significant amendments that materially affect your rights or the way we process your personal data, p65com will notify registered players via email to the address on file, or by displaying a prominent notice upon login to the p65com Platform, prior to the changes taking effect.

Your continued use of the p65com Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you should cease using the Platform and may request account closure by contacting our support team at [email protected].

13 Contact & Data Protection Officer

p65com has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact us through the following channels:

• Data Protection Officer Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly from the p65com Platform at Philippine Standard Time
• Coverage: Serving registered players across Metro Manila, Cebu, Davao, Quezon City, Makati, and all Philippine regions

For complaints that cannot be resolved directly with p65com, you have the right to escalate to the National Privacy Commission (NPC) of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act of 2012. Information about filing a complaint with the NPC is available through official Philippine government channels.

p65com is committed to resolving all data privacy concerns promptly, fairly, and in full compliance with our obligations as a PAGCOR-registered operator and responsible processor of Filipino players' personal data.