PHCash16 Privacy Policy — How We Handle Your Personal Data

This Privacy Policy explains how phcash16 ("phcash16", "we", "us", "our") collects, stores, processes and protects the personal information of members and visitors of phcash16.net ("the Platform"). It applies to all personal data we handle in connection with your registration, use of our sports betting and live casino services, payment transactions and communications with our support team.

phcash16 is committed to protecting your privacy and handling your data responsibly in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its implementing rules and regulations. By registering and using phcash16, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

For the purposes of the Data Privacy Act of 2012, phcash16 is the Personal Information Controller (PIC) for all personal data collected through phcash16.net. This means phcash16 determines why and how your personal information is processed.

Our designated Data Protection contact point for all privacy-related enquiries and requests from Filipino members is our support team, reachable at support@phcash16.net. We aim to acknowledge all data rights requests within three (3) business days and resolve them within fifteen (15) business days.

phcash16 collects personal information only to the extent necessary to operate the platform safely and in compliance with applicable regulations. The categories of personal data we may collect from phcash16 members include:

phcash16 does not collect special categories of sensitive personal data (such as health records, religious beliefs or political affiliations) unless directly required for a specific legal obligation and only with your explicit consent.

phcash16 collects personal data through the following means:

• Direct registration: Information you provide when creating your phcash16 account, completing KYC verification or contacting support.
• Automated platform interactions: Data collected automatically when you use phcash16.net, including cookies, session logs, device identifiers and IP addresses.
• Payment processors: Transaction confirmation data received from GCash, Maya, InstaPay and other payment services used at phcash16.
• Identity verification providers: Results from third-party KYC/AML services used to verify the identity documents you submit to phcash16.
• Third-party game providers: Session and wager data from licensed game suppliers whose products run on phcash16.

phcash16 uses the personal data it collects for the following purposes:

• Account creation and management: To register your phcash16 account, verify your identity, process your login and maintain your account settings.
• Transaction processing: To accept your deposits, settle winning bets, process withdrawals to your GCash or bank account and manage your phcash16 wallet balance.
• Legal compliance: To meet Know-Your-Customer (KYC), Anti-Money Laundering (AML), age verification and other obligations under Philippine law and our operating licence conditions.
• Fraud prevention and security: To detect, investigate and prevent fraudulent activity, multi-accounting, unauthorised access and other abusive behaviour on phcash16.
• Responsible gaming: To monitor wagering patterns that may indicate problem gambling behaviour, enforce self-exclusion and deposit limits set by members and comply with responsible gaming obligations.
• Customer support: To respond to your enquiries, resolve account disputes and communicate about your phcash16 activity.
• Platform improvement: To analyse usage patterns and improve the phcash16 user experience, fix bugs and develop new features based on how Philippine members actually use the platform.
• Marketing communications: To send you promotional offers and news about phcash16, only if you have opted in to receive them. You can opt out at any time.

phcash16 does not use automated decision-making or profiling that produces legal effects or similarly significant impacts on individual members without human review.

Under the Data Privacy Act of 2012, phcash16 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to provide phcash16's services under the agreement formed when you register, such as running your account and processing transactions.
• Legal obligation: Processing necessary for compliance with Philippine law, including AML/KYC requirements and reporting obligations to regulatory bodies.
• Legitimate interests: Processing for fraud prevention, platform security and general business operations, where phcash16's interests do not override your fundamental rights and freedoms.
• Consent: Processing for marketing communications and optional personalisation features, where you have given clear and freely-withdrawable consent.

phcash16 does not sell your personal data. We do not share your information with advertisers or third-party data brokers. We share your data only in the following controlled circumstances:

• Payment service providers: GCash, Maya, InstaPay/PESONet partner banks and card processors — to process your phcash16 deposits and withdrawals. These providers are contractually bound to handle your data securely.
• Identity verification providers: Accredited KYC and document verification services used to validate the identification documents you submit to phcash16.
• Game suppliers: Licensed third-party game providers whose software runs on phcash16 receive session and wager data necessary to operate their games.
• Regulatory and law enforcement authorities: phcash16 will disclose personal data to the National Privacy Commission, Philippine law enforcement agencies or other competent regulatory bodies where legally required to do so.
• IT and security service providers: Cloud hosting, data analytics and cybersecurity providers who operate under strict data processing agreements with phcash16 and are not permitted to use your data for their own purposes.

Some of phcash16's service providers — particularly cloud infrastructure and game suppliers — may process personal data outside the Philippines. When phcash16 transfers your data to providers in other countries, we ensure that appropriate safeguards are in place, including:

• Data processing agreements requiring the recipient to meet standards equivalent to those under the Data Privacy Act of 2012;
• Selection of service providers located in jurisdictions recognised by the National Privacy Commission as offering adequate data protection; and
• Technical and organisational measures ensuring data in transit and at rest remains encrypted and access-controlled.

Your personal data is not transferred internationally except where the above safeguards are confirmed and documented. phcash16 maintains records of all cross-border data flows.

phcash16 retains your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy and to comply with applicable legal obligations. Specific retention periods include:

• Active account data: Retained for the lifetime of your phcash16 account plus a minimum of five (5) years after account closure, in line with AML record-keeping requirements.
• KYC/identity documents: Retained for at least five (5) years from the date of submission or account closure, whichever is later.
• Transaction records: Retained for a minimum of five (5) years following the transaction date for compliance and audit purposes.
• Technical and usage logs: Retained for up to twelve (12) months for security monitoring, after which they are anonymised or deleted.
• Marketing consent records: Retained until you withdraw your consent and for a short period thereafter as proof of the consent status.

When personal data is no longer required, phcash16 securely destroys or anonymises it so it can no longer be linked to you as an individual.

phcash16.net uses cookies and similar technologies to operate the platform, remember your preferences and gather anonymised analytics data. The types of cookies used by phcash16 include:

• Strictly necessary cookies: Required for phcash16 to function at a basic level — session authentication, security tokens and bet slip management. These cannot be disabled.
• Functional cookies: Remember your language preference, login status and display settings so you don't have to reconfigure phcash16 each visit.
• Analytics cookies: Collect anonymised data about how members use phcash16 pages, which features are popular and where errors occur, to help us improve the platform.
• Marketing cookies: Used only if you have given consent, to track whether marketing communications prompted your visit and to avoid showing you the same message repeatedly.

You can manage non-essential cookie preferences through your browser settings. Disabling functional or analytics cookies may affect parts of the phcash16 user experience but will not prevent you from accessing core platform features.

phcash16 takes data security seriously and has implemented technical and organisational measures appropriate to the risk involved in processing your personal data, including:

• TLS/SSL encryption for all data transmitted between your device and phcash16.net;
• Encryption of sensitive data at rest, including identity documents and financial records;
• Access controls ensuring that phcash16 staff can only access member data relevant to their specific job functions;
• Regular security assessments and penetration testing of phcash16's technical infrastructure;
• Two-factor authentication options for member accounts;
• 24/7 automated monitoring for suspicious login attempts and unusual transaction patterns; and
• Staff data protection training and confidentiality obligations.

In the event of a personal data breach that is likely to affect your rights and freedoms, phcash16 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected members as soon as reasonably practicable.

phcash16 is strictly for adults aged 21 years and above. We do not knowingly collect or process personal data from individuals under 21. If phcash16 discovers that a registered account belongs to a person under 21, the account will be immediately closed, all deposits returned to the payment source (minus any winnings) and all associated data deleted, except where retention is required by law.

If you believe a minor has registered with phcash16, please notify us immediately at support@phcash16.net. phcash16 takes under-age access prevention seriously and will act on any verified reports promptly.

As a phcash16 member and data subject under the Data Privacy Act of 2012, you have the right to access, correct, delete, object to, restrict or request portability of your personal data. To exercise any of these rights, contact phcash16 by email at support@phcash16.net with the subject line "Data Rights Request". Include:

• Your full name and phcash16 registered email address;
• The specific right you wish to exercise;
• Sufficient information to identify the data in question; and
• A copy of a valid government-issued photo ID to verify your identity as the account holder.

phcash16 will acknowledge your request within three (3) business days. We will complete the request or provide a substantive response explaining any limitations within fifteen (15) business days of identity verification. Some requests — such as erasure — may be subject to retention obligations that override your request, in which case phcash16 will explain the specific legal reason in writing.

If you are unsatisfied with phcash16's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).

phcash16.net does not contain links to external websites. The platform is a closed environment with no outbound links to third-party sites from within member-facing pages. If you navigate away from phcash16 through your own browser activity, phcash16 has no control over and takes no responsibility for the privacy practices of those external destinations.

phcash16 may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations or service offerings. When we make material changes, we will notify registered phcash16 members by email or by displaying a prominent notice on phcash16.net. The "Last Updated" date at the top of this page will be revised to reflect the most recent version.

Your continued use of phcash16 after the effective date of any Privacy Policy update constitutes your acceptance of the revised policy. If you do not agree with a material change, please contact phcash16 support to discuss your options, which include closing your account.

For all privacy-related questions, data rights requests or concerns about how phcash16 handles your personal information, please reach us through the following channel: