Data & Privacy

ph39 Privacy Policy – How We Protect Your Personal Data

At ph39, we take the privacy of every Filipino player seriously. This Privacy Policy explains clearly what data we collect, why we collect it, how it is used, and what rights you have over your own information.

Last updated: June 2025  ·  Applies to all registered ph39 accounts
Privacy at a Glance

Six Things You Should Know About ph39 and Your Data

These cards cover the most important points. The full Privacy Policy is below — please read it in detail so you understand exactly how ph39 handles your personal information.

Your Data Is Encrypted

All personal data stored and transmitted through the ph39 platform is protected by industry-standard encryption. Payment data handled during deposit and withdrawal transactions uses secure, encrypted channels throughout.

We Collect Only What We Need

ph39 collects personal data for specific, legitimate purposes — account registration, identity verification, payment processing, and platform improvement. We do not collect data that is unnecessary for these purposes.

We Do Not Sell Your Data

ph39 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. Data shared with service providers is limited to what is necessary for them to perform services on our behalf.

You Control Your Data

You have the right to access, correct, and request deletion of the personal data ph39 holds about you. These rights can be exercised by contacting support@ph39.best at any time.

GCash & Maya Data Is Handled Securely

When you deposit or withdraw via GCash or Maya, ph39 processes only the transaction data needed to complete the payment. Full e-wallet credentials are never stored on ph39 servers.

Philippine Data Laws Apply

ph39 operates in compliance with the Republic Act No. 10173 — the Data Privacy Act of 2012 of the Philippines. Filipino players have the full protections of that law in relation to any personal data ph39 holds about them.

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Important: This Privacy Policy is part of the agreement between you and ph39 (ph39.best). By registering an account or using the ph39 platform, you confirm that you have read and understood how your personal data will be handled as described in this Policy. If you have questions at any point, contact support@ph39.best.

1 Introduction

ph39 (accessible at ph39.best) is an online gaming platform serving Filipino players. As part of operating the platform, ph39 collects and processes personal information about its registered members. This Privacy Policy explains what information is collected, why it is collected, how it is used, who it may be shared with, and what rights you have in relation to your own data.

ph39 operates in compliance with the Data Privacy Act of2012 (Republic Act No. 10173) of the Philippines and takes its obligations under that law seriously. The National Privacy Commission (NPC) of the Philippines is the regulatory authority responsible for overseeing compliance with the Data Privacy Act.

This Privacy Policy applies to all personal data processed in connection with the ph39 platform — including data collected through the ph39 website, any associated mobile interface, customer support interactions, and payment processing. It should be read alongside the ph39 Terms and Conditions.

2 Personal Data We Collect

The categories of personal data ph39 collects about registered members and platform users are set out below. ph39 collects only data that is necessary for the specific purpose for which it is collected.

Category Data Collected
Identity Data Full legal name, date of birth, government-issued ID type and number (e.g. PhilSys, SS, UMID, Passport, Driver's Licence), nationality
Contact Data Philippine mobile number, email address
Account Data Username, encrypted password, account registration date, account status, communication preferences
Financial Data Payment method type and identifier (e.g. GCash mobile number, bank account last four digits), transaction amounts, deposit and withdrawal history
Gaming Activity Data Games played, bets placed, amounts wagered and won, session timestamps, VIP tier status
Technical Data IP address, device type, operating system, browser type, session identifiers, approximate location (country/region)
Communications Data Records of support interactions via email and live chat, including messages sent and received
Responsible Gaming Data Deposit limits set, session limits set, self-exclusion status, cooling-off period history

ph39 does not collect sensitive personal information such as biometric data, health records, or political or religious affiliations unless specifically required by law and with appropriate safeguards in place.

3 How We Collect Your Data

3.1 Directly from You

Most of the personal data ph39 holds is provided directly by you when you register an account, complete identity verification, make a deposit or withdrawal, use live chat or email support, or set responsible gaming preferences. This is the primary source of personal data at ph39.

3.2 Automatically Through Platform Use

When you access ph39 and interact with the platform, certain technical data is collected automatically. This includes your IP address, device information, browser type, session start and end times, and pages or game sections accessed. This data is collected through standard web server logs and through cookies and similar technologies (described in Section 7).

3.3 From Payment Providers

When you make a deposit or withdrawal through GCash, Maya, or other payment partners, ph39 receives transaction confirmation data from those providers — sufficient to credit your ph39 wallet or confirm a successful withdrawal. ph39 does not receive full account credentials from payment providers.

3.4 From Identity Verification Processes

During the KYC (Know Your Customer) verification process required before withdrawals, ph39 collects copies of government-issued identification documents and verifies the information they contain against the details provided at registration.

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4 Why We Use Your Personal Data

ph39 uses the personal data it collects for the following purposes. Each purpose is tied to specific categories of data and a legal basis described in Section 5.

  • Account creation and management: Processing registrations, maintaining account records, managing login security, and communicating account-related information to you.
  • Identity verification and fraud prevention: Verifying that account holders are who they claim to be, detecting and preventing fraudulent activity, confirming age eligibility, and meeting regulatory KYC obligations.
  • Payment processing: Processing deposits and withdrawals, reconciling transactions, and investigating payment disputes or discrepancies.
  • Providing gaming services: Operating games and betting markets, recording game outcomes, calculating and crediting winnings, and maintaining bet history records.
  • Bonus and promotion administration: Tracking bonus eligibility, calculating wagering requirements, verifying referal programme participation, and distributing promotional rewards.
  • Customer support: Responding to queries, resolving complaints, and maintaining records of support interactions.
  • Responsible gaming compliance: Enforcing deposit limits, session controls, and self-exclusion requests set by members; monitoring gaming patterns for potential harm indicators.
  • Legal and regulatory compliance: Meeting obligations under Philippine law including the Data Privacy Act, anti-money laundering regulations, and gaming regulatory requirements.
  • Platform improvement: Analysing usage patterns to improve platform performance, game selection, and user experience — using aggregated or anonymised data where possible.
  • Marketing communications: Sending promotions, bonus offers, and gaming updates to members who have opted in to marketing communications. You can opt out at any time by contacting support@ph39.best.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012 (Philippines), ph39 processes personal data on the following legal bases:

  • Contractual necessity: Processing required to provide the ph39 gaming services you have registered for — account management, payment processing, game operation, and support.
  • Legal obligation: Processing required to comply with applicable Philippine laws — including age verification, KYC identity checks, anti-money laundering obligations, and responsible gaming regulatory requirements.
  • Legitimate interests: Processing necessary for fraud detection, security monitoring, platform improvement, and responsible gaming analytics — where these interests do not override your privacy rights.
  • Consent: Processing for marketing communications and non-essential cookies — where we rely on your consent, you have the right to withdraw it at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

ph39 does not sell, rent, or trade your personal data. Personal data is shared only in the following limited circumstances:

6.1 Service Providers

ph39 works with third-party service providers who assist in operating the platform. These include payment processing partners (GCash, Maya, and banking partners), identity verification service providers, technology infrastructure providers (hosting and cloud services), and customer support platform providers. These providers are permitted to use your data only to perform services on ph39's behalf and are contractually bound to maintain appropriate data security.

6.2 Legal and Regulatory Disclosure

ph39 may be required to disclose personal data to regulatory authorities, law enforcement agencies, or courts in the Philippines when required by law, court order, or regulatory direction. Such disclosures are made in good faith based on a reasonable determination of the legal requirement and are limited to the data specifically requested.

6.3 Business Transfers

In the event of a merger, acquisition, or transfer of the ph39 business, personal data held by ph39 may be transferred to the acquiring entity as part of the transaction. In such circumstances, ph39 will take reasonable steps to ensure the receiving entity honours the commitments made in this Privacy Policy.

No Data Sales: ph39 does not and will not sell personal data about Filipino players to any third party for marketing, advertising, data brokerage, or any other commercial purpose unrelated to the direct provision of ph39's gaming services.

7 Cookies & Tracking Technologies

ph39 uses cookies and similar technologies on the platform. Cookies are small data files placed on your device when you access a website. They serve several purposes at ph39:

7.1 Essential Cookies

These cookies are necessary for the ph39 platform to function. They maintain your login session, remember your language and display preferences, and ensure secure page access. Essential cookies cannot be disabled without preventing normal use of the platform.

7.2 Analytics Cookies

ph39 uses analytics cookies to understand how the platform is used — which pages are most visited, how long sessions last, and which games attract the most engagement. This data is used in aggregate and anonymised form to improve the platform. Analytics cookies can be declined without affecting core platform functionality.

7.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please be aware that disabling certain cookies may affect the performance or appearance of some parts of the ph39 platform. Essential session cookies cannot be disabled without preventing login and platform access.

8 Data Retention

ph39 retains personal data for as long as it is needed for the purpose for which it was collected, or as required by applicable Philippine law. The general retention principles applied at ph39 are:

  • Active account data: Retained throughout the period your ph39 account remains active and for period after account closure in line with legal retention requirements.
  • Transaction records: Financial transaction records are retained for a minimum of five years from the date of the transaction in accordance with anti-money laundering regulatory requirements applicable in the Philippines.
  • KYC documentation: Identity verification documents and records are retained for a minimum of five years following account closure or the completion of the relevant transaction, whichever is later.
  • Support communications: Records of support interactions are retained for a reasonable period sufficient to resolve any related dispute or regulatory inquiry that may arise.
  • Gaming activity data: Bet history and game activity records are retained in line with applicable regulatory requirements and for the period necessary to resolve any winings disputes.

When data is no longer needed and the applicable retention period has expired, ph39 deletes or anonymises it in a secure manner.

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9 Data Security

ph39 implements a range of technical and organisational security measures to protect the personal data of Filipino players against unauthorised access, disclosure, alteration, or destruction. These measures include:

  • Encryption of data in transit using TLS (Transport Layer Security) for all connections between player devices and ph39 servers.
  • Encryption of sensitive data at rest, including passwords (hashed and salted) and payment identifiers.
  • Access controls limiting internal access to personal data to authorised personnel who require it for their role.
  • Regular security assessments and vulnerability testing of platform infrastructure.
  • Secure, audited payment processing integrations with GCash, Maya, and banking partners — ph39 does not store full payment credentials on its own servers.
  • Logging and monitoring of access to sensitive data systems to detect and respond to unauthorised access attempts.

While ph39 applies appropriate security measures, no system is completely immune to security incidents. In the event of a personal data breach that affects your rights and freedoms, ph39 will notify affected individuals and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

Account Security Reminder: The security of your ph39 account also depends on you keeping your login credentials private. Never share your password with anyone — ph39 staff will never ask for your password. If you suspect unauthorised access to your account, contact support@ph39.best immediately.

10 Your Data Rights

Under the Data Privacy Act of 2012 (Philippines), you have the following rights in relation to your personal data held by ph39. ph39 will respond to all valid rights requests within the timeframes required by law.

Right to Access

You can request a copy of the personal data ph39 holds about you at any time. ph39 will provide this within 15 days of a valid request.

Right to Correct

If any personal data ph39 holds about you is inaccurate or incomplete, you can request correction. Account profile details can also be updated directly in your account settings.

Right to Erasure

You can request deletion of your personal data where it is no longer necessary for the purpose it was collected and there is no overiding legal obligation to retain it.

Right to Object

You can object to the processing of your personal data for marketing purposes at any time. You can also object to other types of processing where ph39 is relying on legitimate interests as the legal basis.

Right to Withdraw Consent

Where processing is based on your consent (such as marketing communications), you can withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before the withdrawal.

How to Exercise Your Rights: To exercise any of the rights above, contact ph39 at support@ph39.best with your account details and a clear description of your request. ph39 may need to verify your identity before processing the request. There is no charge for exercising your rights under the Data Privacy Act.

11 Children's Privacy

ph39 is strictly an adult platform. The minimum age for registration is 18 years. ph39 does not knowingly collect personal data from individuals under 18 years of age.

ph39's registration process includes date of birth verification and KYC identity checks specifically to detect and prevent underage registration. If ph39 discovers that personal data has been collected from a person under 18, that account will be closed immediately, any associated funds handled in accordance with applicable regulations, and the personal data deleted in accordance with this Privacy Policy and applicable law.

Parents or guardians who believe a minor may have registered on ph39 should contact support@ph39.best immediately so the matter can be investigated and resolved promptly.

12 Cross-Border Data Transfers

ph39 is a platform serving Filipino players, and the majority of data processing occurs in connection with services provided to or from the Philippines. Some of the third-party service providers ph39 works with — such as cloud hosting providers and payment processing technology partners — may process or store data on infrastructure located outside the Philippines.

Where personal data is transferred outside the Philippines, ph39 takes steps to ensure that the transfer is protected by appropriate safeguards, including contractual arrangements with service providers that require them to handle the data with standards of protection equivalent to those required by the Data Privacy Act of 2012.

ph39 does not transfer personal data to third parties located outside the Philippines for their own independent use. Cross-border transfers are limited to service providers who process data on ph39's behalf for the purposes described in this Privacy Policy.

13 Changes to This Privacy Policy

ph39 may update this Privacy Policy from time to time to reflect changes in law, changes in how the platform operates, or improvements in data protection practices. The updated date shown at the top of this page indicates when the current version became effective.

When material changes are made to this Privacy Policy, ph39 will notify registered members via the email address on file or through an in-platform notice before the changes take effect. For minor clarifications or updates that do not materially affect your rights, ph39 may update the Policy without separate notification.

Continued use of the ph39 platform after the effective date of a revised Privacy Policy constitutes acknowledgment of the updated Policy. If you do not agree with any material change, you may close your ph39 account before the change takes effect.

14 Contact & Privacy Complaints

If you have questions about this Privacy Policy, want to exercise your data rights, or have concerns about how ph39 has handled your personal data, please contact the ph39 data protection team:

  • Email: support@ph39.best
  • Subject line: Privacy — [your query or right being exercised]
  • Response time: ph39 aims to respond to all privacy-related enquiries within 5 business days and to complete rights requests within the timeframes set by the Data Privacy Act.

If you believe ph39 has not adequately addressed your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). ph39 encourages you to contact us directly first so we have the opportunity to resolve any issue before escalation.

This Privacy Policy was last updated in June 2025 and supersedes all previous versions. ph39 ·39.best · support@ph39.best

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