mph365 Privacy Policy

1Introduction and Data Controller

mph365 ("we," "us," or "our") operates the online gaming platform accessible at mph365.org (the "Platform"). In the context of this Privacy Policy, mph365 acts as the Personal Information Controller as defined under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations.

This Privacy Policy describes how mph365 collects, uses, stores, shares, and protects the personal data of individuals who register for an account, access the Platform, or otherwise interact with mph365's services ("you" or "Player"). It also describes the rights available to you under applicable Philippine data privacy law and how to exercise them.

By accessing or using the mph365 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, please discontinue use of the Platform immediately.

2Personal Data We Collect

mph365 collects personal data through several channels, including account registration, identity verification, platform usage, and customer support interactions. The categories of personal data we collect include:

Identity and Contact Data:

• Full legal name, date of birth, and nationality;
• Government-issued identification numbers (e.g., Philippine National ID, passport, driver's license);
• Residential address, email address, and mobile phone number;
• Selfie or photograph submitted for identity verification purposes.

Financial Data:

• GCash or PayMaya account details (mobile number associated with the e-wallet);
• Bank account details for bank transfer transactions (account name, account number, bank name);
• Transaction history, including deposit amounts, withdrawal amounts, and dates;
• Debit card details where applicable (card number is not stored in full; only the last four digits and expiry date are retained).

Gaming and Behavioral Data:

• Game history, wager amounts, win/loss records, and session durations;
• Bonus and promotion usage history;
• Responsible gaming settings, including deposit limits and self-exclusion requests.

Technical Data:

• IP address, device type, operating system, and browser type;
• Cookies and similar tracking technologies (see Section 8);
• Login timestamps and session activity logs.

Communications Data:

• Records of live chat conversations, email correspondence, and support tickets submitted to mph365;
• Feedback, complaints, and survey responses.

3How We Use Your Personal Data

mph365 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your mph365 account, including verifying your identity and age (21+ requirement) before activating real-money gaming features;
• Transaction Processing: To process deposits, withdrawals, and other financial transactions through GCash, PayMaya, bank transfer, and debit card channels in Philippine Peso;
• Legal and Regulatory Compliance: To fulfill our obligations under the DPA, Anti-Money Laundering Act (AMLA), and applicable Philippine gaming regulations, including Know Your Customer (KYC) and Customer Due Diligence (CDD) requirements;
• Platform Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct;
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance through our 24/7 live chat and email support channels;
• Responsible Gaming: To administer deposit limits, session reminders, self-exclusion requests, and other responsible gaming tools you have activated on your account;
• Platform Improvement: To analyze usage patterns, identify technical issues, and improve the performance and features of the mph365 Platform;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time.

4Legal Basis for Processing

mph365 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management and transaction processing;
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including the DPA, AMLA, and gaming regulations administered by relevant Philippine regulatory bodies;
• Legitimate Interests: Processing is necessary for mph365's legitimate interests in preventing fraud, ensuring platform security, and improving our services, provided these interests are not overridden by your rights and freedoms;
• Consent: For marketing communications and non-essential cookies, processing is based on your explicit consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

5Data Sharing and Disclosure

mph365 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash (Mynt), PayMaya (Voyager Innovations), and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions;
• Game Providers: Third-party game software providers whose games are available on the mph365 Platform, to the extent necessary to deliver game services and maintain game integrity;
• Identity Verification Services: Third-party KYC and identity verification providers engaged to verify your age, identity, and address as required by Philippine regulations;
• Regulatory and Law Enforcement Authorities: Philippine government agencies, regulatory bodies, courts, and law enforcement authorities where disclosure is required by law, court order, or regulatory directive;
• Anti-Money Laundering Council (AMLC): As required under Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments, mph365 may be required to report certain transactions and disclose player information to the AMLC;
• IT and Security Service Providers: Third-party providers of hosting, cloud infrastructure, cybersecurity, and fraud detection services engaged to support the operation and security of the mph365 Platform;
• Professional Advisers: Lawyers, auditors, and accountants engaged by mph365 in connection with legal proceedings, compliance reviews, or financial audits, subject to professional confidentiality obligations.

All third parties with whom mph365 shares personal data are required to process that data in accordance with applicable privacy laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

6Data Retention

mph365 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine anti-money laundering regulations;
• Identity Verification Documents: Retained for the duration of your account and for five (5) years following account closure;
• Customer Support Records: Retained for three (3) years from the date of the last interaction, or longer if the matter is subject to ongoing legal proceedings;
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given;
• Technical and Log Data: Retained for up to twelve (12) months from the date of collection, unless required for longer retention in connection with a security investigation or legal matter.

Upon expiry of the applicable retention period, mph365 will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

7Security Measures

mph365 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the mph365 Platform is encrypted using Transport Layer Security (TLS) protocols. Sensitive data at rest, including financial information and identity documents, is encrypted using industry-standard algorithms;
• Access Controls: Access to personal data is restricted to mph365 personnel and authorized third parties who require it to perform their specific functions. Role-based access controls and multi-factor authentication are enforced for all internal systems;
• Firewalls and Intrusion Detection: mph365 employs network firewalls, intrusion detection systems, and continuous security monitoring to identify and respond to potential threats in real time;
• Regular Security Audits: mph365 conducts periodic security assessments, penetration testing, and vulnerability scans to identify and remediate potential weaknesses in our systems;
• Staff Training: All mph365 personnel who handle personal data receive regular training on data privacy obligations and security best practices.

While mph365 takes all reasonable steps to protect your personal data, no system is completely immune to security risks. You are encouraged to use a strong, unique password for your mph365 account and to enable two-factor authentication where available.

8Cookies and Tracking Technologies

mph365 uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session continuity, and analyze platform performance. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in during your visit. These cookies cannot be disabled without affecting core Platform functionality;
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming configurations, so you do not need to re-enter them on each visit;
• Analytics Cookies: Used to collect aggregated, anonymized data about how Players use the Platform, including pages visited, time spent, and navigation paths. This data helps mph365 identify areas for improvement;
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the mph365 Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

9Your Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by mph365:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy;
• Right of Access: The right to request a copy of the personal data mph365 holds about you, along with information about how it is being used;
• Right to Rectification: The right to request correction of any inaccurate or incomplete 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 our legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and 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 National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within 30 calendar days. In complex cases, this period may be extended by a further 30 days, and we will notify you of any such extension.

10Children's Privacy and Age Restriction

The mph365 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations applicable to casino-style online gambling. mph365 does not knowingly collect personal data from individuals under the age of 21.

During the registration process, mph365 requires all applicants to confirm that they are at least 21 years old. Where mph365 has reasonable grounds to suspect that a registered user is under 21, we will suspend the account and initiate age verification procedures. If it is confirmed that a user is underage, the account will be permanently closed and any personal data collected will be deleted, except where retention is required by law.

If you are a parent or guardian and believe that your child has registered an account on the mph365 Platform, please contact us immediately at [email protected] so that we can take appropriate action.

11Updates to This Privacy Policy

mph365 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered Players via email or a prominent notice on the Platform at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed of how mph365 is protecting your personal data.

Your continued use of the mph365 Platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure by contacting our support team.

12Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way mph365 handles your personal data, please contact our designated Data Protection Officer:

• Data Protection Officer: mph365 Privacy Team
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 through the mph365 Platform
• Response Time: Email responses within 24 hours; DPO requests within 30 calendar days

You also have the right to escalate any unresolved privacy concern to the National Privacy Commission of the Philippines, the independent authority responsible for enforcing the Data Privacy Act of 2012.