46ph Privacy Policy

46ph ("we", "us", "our") is committed to safeguarding the privacy and personal data of every individual who uses the 46ph Platform at https://46ph.net. This Privacy Policy describes our information practices in full — what personal data we collect from Filipino players and website visitors, how we process and protect that data, with whom we share it, how long we keep it, and the rights you may exercise at any time.

This Policy applies to all personal data collected through the following channels:

• The 46ph website and all pages accessible under the domain https://46ph.net.
• The 46ph account registration and verification process.
• Financial transactions including deposits and withdrawals processed through GCash, PayMaya, BPI, BDO, Metrobank, or cryptocurrency channels.
• Customer support interactions conducted via Live Chat or email.
• Marketing communications and promotional activities where you have opted in.
• Any other service offered by 46ph through the Platform.

This Privacy Policy is to be read alongside the 46ph Terms & Conditions and Responsible Gaming Policy, each of which is incorporated by reference.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), 46ph acts as the Personal Information Controller in respect of all personal data collected through the Platform. As Personal Information Controller, 46ph determines the purposes and means of processing your personal data and is responsible for ensuring that processing is lawful, fair, and transparent.

Where 46ph engages third-party service providers — such as payment processors, KYC verification partners, or cloud infrastructure providers — to process personal data on its behalf, those parties act as Personal Information Processors under binding data-processing agreements that require them to protect your data to the same standard as 46ph.

46ph collects personal data across several categories, depending on how you interact with the Platform. The table below sets out the categories of personal data we process and the context in which each is collected.

46ph does not intentionally collect sensitive personal information as defined under RA 10173 (e.g., religious beliefs, health data, political opinions) except where such information is voluntarily provided by you in the course of a support interaction or as required by a regulatory obligation such as a responsible gaming self-exclusion request.

46ph collects personal data through the following means:

4.1 Information You Provide Directly

When you register a 46ph account, complete KYC verification, make a transaction, use Live Chat, or communicate with 46ph by email, you voluntarily provide personal data that we collect and process for the purposes described in this Policy.

4.2 Automatically Collected Technical Data

When you access the 46ph Platform, our servers and analytics systems automatically collect certain technical information about your device, browser, and session, including your IP address, device identifiers, operating system, and navigation patterns within the Platform. This data is collected primarily for security, fraud prevention, and platform performance purposes.

4.3 Cookies and Similar Technologies

46ph uses cookies and similar tracking technologies as described in Section 8 of this Policy. Certain cookies are strictly necessary for Platform functionality; others are used for analytics and, where you have consented, for personalisation of your experience.

4.4 Third-Party Sources

In connection with our Know Your Customer (KYC) obligations under Philippine anti-money laundering law, 46ph may receive identity verification data from accredited third-party KYC service providers, credit reference agencies, or government-issued database lookups where authorized. 46ph may also receive data from payment processors in connection with transaction confirmation and fraud screening.

Under the Philippine Data Privacy Act, 46ph processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between you and 46ph — including operating your account, processing deposits and withdrawals, and resolving disputes.
• Legal obligation: Processing required for 46ph to comply with Philippine law, including anti-money laundering obligations under RA 9160 (as amended), PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing conducted for 46ph's legitimate business interests, including fraud prevention, platform security, and the improvement of gaming services — where such interests are not overridden by your fundamental rights and freedoms as a data subject.
• Consent: For processing activities not covered by the above bases — such as the sending of promotional communications and certain uses of non-essential cookies — 46ph relies on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

46ph processes your personal data for the following purposes, each of which is grounded in one or more legal bases described in Section 5:

• Account creation and management: To create, maintain, and administer your 46ph account, including authentication, profile management, and preference settings.
• Payment processing: To process deposits, withdrawals, and refunds via GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency channels, and to maintain accurate transaction records in Philippine Peso (PHP).
• Identity verification (KYC/AML): To verify your identity, age (21+ requirement), and the source of funds in compliance with PAGCOR requirements and the Anti-Money Laundering Act of the Philippines.
• Responsible gaming: To apply and monitor any deposit limits, loss limits, self-exclusion requests, or reality check tools you activate on your 46ph account.
• Fraud prevention and platform security: To detect, investigate, and prevent fraudulent transactions, account misuse, cheating, money laundering, and other unlawful activity.
• Customer support: To respond to your enquiries, resolve disputes, and provide assistance via Live Chat and email.
• Service improvement: To analyse platform usage patterns, game popularity, and user behaviour in aggregate or pseudonymised form to improve the quality and range of 46ph services.
• Legal and regulatory compliance: To comply with court orders, regulatory requests from PAGCOR, NPC, AMLC, and other competent Philippine authorities.
• Marketing communications: Where you have opted in, to send you information about 46ph promotions, bonuses, new games, and platform updates via email or in-platform notification. You may opt out at any time via your account settings.

46ph does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We share your data only in the following limited circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processing partners receive transactional data strictly necessary to process your financial instructions.
• KYC and identity verification providers: Accredited third-party providers who assist with age and identity verification receive identity data solely for that purpose under data-processing agreements.
• Cloud infrastructure and technology providers: Hosting, database, security, and analytics vendors who process data on 46ph's behalf under binding contractual terms that mandate equivalent data protection standards.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities where disclosure is required by law, court order, or legitimate regulatory enquiry.
• Group companies and successors: In the event of a corporate restructuring, merger, or acquisition, your data may be transferred to a successor entity that will continue to operate the 46ph Platform under this Privacy Policy or a materially equivalent policy.

46ph uses cookies — small text files stored on your device — and similar tracking technologies to operate and improve the Platform. The categories of cookies we use are as follows:

8.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be switched off. They include session cookies that keep you logged in to your 46ph account, security tokens that protect against cross-site request forgery, and load-balancing cookies. No consent is required for strictly necessary cookies.

8.2 Analytics and Performance Cookies

These cookies collect aggregate, anonymised data about how users navigate the 46ph Platform — which pages are visited most often, how long sessions last, and where users encounter errors. This information helps us improve platform performance and user experience. These cookies are activated only with your consent where required.

8.3 Functional Cookies

Functional cookies remember your preferences — such as your preferred language, last-visited game category, or notification settings — so that you do not need to re-enter them on each visit. These cookies enhance your experience on 46ph but are not strictly necessary for basic platform operation.

You may manage your cookie preferences at any time through your browser settings. Note that disabling certain categories of cookies may affect the functionality of some 46ph Platform features. Blocking strictly necessary cookies may prevent you from accessing your account.

46ph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by Philippine law. The following retention guidelines apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be attributed to any identifiable individual.

46ph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption: All data in transit between your device and 46ph servers is encrypted using 256-bit SSL/TLS protocols.
• Encryption at rest: Sensitive data fields — including identity data and financial identifiers — are encrypted in storage using industry-standard algorithms.
• Access controls: Access to personal data within 46ph is restricted on a need-to-know basis. All staff with access to personal data are bound by confidentiality obligations and receive data privacy training.
• Multi-factor authentication: Internal systems containing personal data require multi-factor authentication for all authorised personnel.
• Regular security assessments: 46ph conducts periodic vulnerability assessments and penetration testing of its Platform and supporting infrastructure.
• Incident response: In the event of a personal data breach, 46ph maintains a documented incident response procedure. Where required by RA 10173, affected data subjects and the National Privacy Commission will be notified within the timeframes prescribed by law.

Under the Philippine Data Privacy Act of 2012, you hold the following rights with respect to the personal data that 46ph holds about you. These rights are enforceable and may be exercised at any time by contacting our Data Protection Officer as described in Section 15:

To exercise any of the rights above, please contact 46ph's Data Protection Officer using the contact details in Section 15. 46ph will respond to verified data subject requests within the timeframes required by the NPC — generally within 15 business days of receiving a complete and verifiable request.

The 46ph Platform is strictly intended for adults aged 21 years and above, in compliance with PAGCOR regulations applicable to online gaming in the Philippines. 46ph does not knowingly collect personal data from any individual under the age of 21.

If 46ph becomes aware that personal data has been collected from a person under 21 years of age, that account will be immediately suspended, all associated personal data will be deleted, and any deposits or winnings will be handled in accordance with 46ph's Terms & Conditions and applicable PAGCOR guidelines.

46ph primarily processes personal data within the Philippines. However, some of our technology and service partners — including cloud infrastructure providers and international game content suppliers — may process data on servers located outside the Philippines.

Where such cross-border transfers occur, 46ph ensures that appropriate safeguards are in place in accordance with Section 21 of the Data Privacy Act and relevant NPC issuances, including:

• Binding contractual clauses that impose data protection obligations on the recipient equivalent to those required under RA 10173.
• Transfers only to jurisdictions or organisations that the NPC has determined to provide adequate protection for personal data.
• Data minimisation — only the minimum data necessary for the specific processing purpose is transferred cross-border.

46ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. The effective date displayed at the top of this page will be updated whenever a material change is made.

Where changes are material, 46ph will notify registered users via the email address associated with their account or by displaying a prominent notice on the Platform prior to the change taking effect. Your continued use of the 46ph Platform after the effective date of a revised Privacy Policy constitutes your acceptance of the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how 46ph protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by 46ph, please contact us through the following channels. Our Data Protection Officer (DPO) is responsible for overseeing 46ph's compliance with the Data Privacy Act and will personally handle all data subject enquiries.

• Live Chat: Available 24/7 via the 46ph Platform — average response time 3–5 minutes. Please mention "Data Privacy Request" at the start of your chat so our team can route your query directly to the DPO.
• Email: [email protected] — please use the subject line "Data Privacy Request – [Your Name]" for all data subject rights enquiries.

46ph will acknowledge receipt of your request within 3 business days and provide a substantive response within 15 business days of receiving a complete and verifiable request, in accordance with NPC guidelines.

If you are not satisfied with 46ph's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the government body responsible for enforcing RA 10173.