Privacy Policy – 2ph85 Online Casino

1. Introduction

2ph85 ("2ph85," "we," "us," or "our") operates the online gaming platform accessible at 2ph85.org (the "Platform"). We are committed to protecting the privacy and personal data of everyone who registers, transacts, or interacts with the 2ph85 Platform. This Privacy Policy describes the types of personal information we collect, the purposes for which we use it, the conditions under which we may share it, and the rights you hold in relation to your personal data.

This Privacy Policy is incorporated into the 2ph85 Terms & Conditions by reference. By using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, you should refrain from creating a 2ph85 account or using the Platform.

This policy is written in English and applies to all users of the 2ph85 Platform, including Filipino players accessing the Platform from any location in the Philippines — whether in Metro Manila, Cebu, Davao, or elsewhere in the archipelago.

2. Data Controller

For the purposes of applicable data protection legislation, 2ph85 acts as the data controller in respect of the personal data processed through the Platform. All enquiries regarding the use of your personal data should be directed to the 2ph85 support team using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

2ph85 collects personal data from you in several ways — directly when you register or use the Platform, automatically through technical systems, and occasionally from third-party sources such as payment processors and identity verification providers. The categories of personal data we may collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (to verify the 21+ age requirement);
• Registered Philippine mobile number;
• Email address (where provided);
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine identification documents (e.g., PhilSys National ID, SSS ID, UMID, Passport, Driver's License);
• Proof of address documentation;
• Selfie or liveness verification images where required by our KYC process.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts, timestamps, and payment channels used (GCash, PayMaya, BPI, BDO, Metrobank, etc.);
• Payment account identifiers (e.g., GCash-registered mobile number) to verify ownership;
• Account balance history and bonus transaction records.

3.4 Gameplay & Activity Data

• Game session logs, including games played, wagers placed, outcomes, and duration;
• Bonus claim and usage history;
• VIP tier and loyalty point history.

3.5 Technical & Device Data

• IP address and approximate geolocation data;
• Device type, operating system, and browser information;
• Session logs and Platform interaction data collected via cookies and similar technologies.

3.6 Communications Data

• Records of live chat, email, and other communications between you and the 2ph85 support team;
• Survey responses and feedback submitted through the Platform.

4. How We Use Your Data

2ph85 uses the personal data described above for the following purposes:

5. Legal Basis for Processing

2ph85 processes your personal data on the following legal grounds:

• Contractual necessity — processing required to fulfil the agreement between you and 2ph85 when you register an account (account management, payment processing, game delivery);
• Legal obligation — processing required to comply with applicable AML, KYC, and regulatory reporting requirements in the PAGCOR-regulated Philippine online gaming market;
• Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests do not override your fundamental rights;
• Consent — processing for direct marketing communications, where consent has been obtained and may be withdrawn at any time.

6. Disclosure to Third Parties

2ph85 does not sell, rent, or trade your personal data to third-party marketers or advertisers. We may share your personal data with the following categories of third parties, strictly for the purposes described in this Policy:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, 7-Eleven, Cebuana Lhuillier, and other payment channel providers, to facilitate deposits and withdrawals;
• Identity verification providers — third-party KYC and AML compliance service providers engaged by 2ph85 to conduct identity verification;
• Game software providers — game studios and technology providers whose games are accessible on the 2ph85 platform, to the extent technically necessary for game delivery;
• Regulatory authorities — PAGCOR and other applicable regulatory or law enforcement bodies in the Philippines, where disclosure is required by law or valid legal process;
• Professional advisers — legal, accounting, and auditing firms engaged by 2ph85, subject to professional confidentiality obligations.

All third-party service providers engaged by 2ph85 are required to process personal data only in accordance with our instructions and to maintain appropriate technical and organisational security measures.

7. Cookies & Tracking Technologies

The 2ph85 Platform uses cookies and similar tracking technologies to support Platform functionality, maintain session state, and collect anonymised analytics data to improve the user experience. The categories of cookies we use include:

• Strictly necessary cookies — required for the Platform to function, including session authentication and security features. These cannot be disabled.
• Functional cookies — remember your preferences (such as language settings) to improve your experience on the Platform.
• Analytics cookies — collect aggregated, anonymised data about how players use the 2ph85 Platform, allowing us to identify and fix usability issues.

You may adjust your cookie preferences through your browser settings. Disabling strictly necessary cookies may affect the functionality of the 2ph85 Platform.

8. Data Security

2ph85 implements industry-standard technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 2ph85 Platform;
• Encryption of sensitive data at rest within 2ph85's database infrastructure;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of the 2ph85 Platform;
• Incident response procedures for managing and notifying affected parties in the event of a data breach.

While 2ph85 takes all reasonable steps to protect your personal data, no internet-based system is completely immune to risk. You are responsible for maintaining the confidentiality of your 2ph85 login credentials and for notifying us immediately if you suspect unauthorised access to your account.

9. Data Retention

2ph85 retains personal data for as long as necessary to fulfil the purposes described in this Privacy Policy and to comply with applicable legal obligations. Specifically:

• Account data and transaction records are retained for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• KYC identity documentation is retained for a minimum of five (5) years from the date of verification;
• Support communications are retained for up to three (3) years from the date of the interaction;
• Anonymised analytics data may be retained indefinitely as it cannot be linked to an individual.

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

10. Your Rights

Subject to applicable law, you have the following rights in relation to the personal data that 2ph85 holds about you:

• Right of access — request a copy of the personal data 2ph85 holds about you;
• Right of rectification — request correction of inaccurate or incomplete personal data;
• Right to erasure — request deletion of your personal data, subject to overriding legal retention obligations;
• Right to restriction — request that processing of your data be restricted in certain circumstances;
• Right to data portability — request a machine-readable copy of data you have provided to 2ph85;
• Right to withdraw consent — where processing is based on consent (e.g., marketing), you may withdraw consent at any time without affecting prior processing.

To exercise any of these rights, contact the 2ph85 support team as described in Section 14. We will respond within a reasonable period, typically within 30 days of receiving your request.

11. International Transfers

The 2ph85 Platform may use service providers and infrastructure located outside the Philippines. Where personal data is transferred internationally, 2ph85 ensures that appropriate safeguards are in place — such as data processing agreements with contractual clauses requiring recipients to maintain data protection standards equivalent to those applicable in the Philippines — before any transfer occurs.

12. Children's Privacy

The 2ph85 Platform is strictly for individuals aged 21 years and above. 2ph85 does not knowingly collect personal data from individuals under the age of 21. If we discover that a registered account belongs to a person under 21, we will immediately suspend the account, forfeit any associated balances in accordance with our Terms & Conditions, and delete the personal data collected.

If you believe that a minor has registered on the 2ph85 Platform, please contact our support team immediately so that appropriate action can be taken.

13. Changes to This Policy

2ph85 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered players via their registered contact information or through a notice on the Platform. The "Last updated" date at the top of this Policy will be revised to reflect any changes. Continued use of the 2ph85 Platform following the effective date of an amended Privacy Policy constitutes your acceptance of the revised terms.

14. Contact Us

For any questions, requests, or concerns relating to this Privacy Policy or the handling of your personal data by 2ph85, please contact our support team:

• Live Chat: Available 24/7 via the 2ph85 Platform — the fastest way to reach our team.
• Email: [email protected]

We take all privacy enquiries seriously and will acknowledge your request promptly, with a substantive response typically provided within 14 business days.