16ph Privacy Policy

1Who We Are

16ph operates the online gaming platform accessible at 16ph.asia ("Platform"). For the purposes of this Privacy Policy, 16ph acts as the data controller in respect of personal data collected from players accessing and using the Platform. References to "16ph," "we," "us," or "our" throughout this Policy refer to the operator of the 16ph Platform.

The 16ph platform is operated within the PAGCOR regulatory framework applicable to online gaming in the Philippines and is committed to compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

2Personal Data We Collect

16ph collects the following categories of personal data from players:

3How We Collect Your Data

16ph collects personal data through the following means:

• Direct Collection: Information you provide when registering your 16ph account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the 16ph platform, including IP address, device identifiers, browser type, pages visited, session duration, and cookie data.
• Third-Party Sources: Identity verification and fraud prevention data from KYC service providers; payment transaction data from GCash, Maya, and banking partners; and publicly available sources for due diligence purposes.

4How We Use Your Personal Data

16ph uses the personal data described in Section 2 for the following purposes:

• Account Management: To create, maintain, and manage your 16ph player account, including processing deposits, withdrawals, and bonus credits.
• Service Delivery: To provide access to games, process bets, record game outcomes, and deliver the full range of 16ph platform features.
• Identity & Age Verification: To verify that you are at least 21 years old and that your identity matches the registration information provided, as required by PAGCOR regulations and our Terms & Conditions.
• Financial Compliance: To comply with anti-money laundering (AML) obligations, including transaction monitoring, suspicious activity reporting, and source of funds verification.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, collusion, and other prohibited conduct on the platform.
• Responsible Gaming: To monitor gaming patterns and identify players who may benefit from responsible gaming interventions, including displaying usage statistics, suggesting limits, or activating cooling-off measures.
• Customer Support: To respond to your queries, investigate complaints, and resolve disputes through our 24/7 Filipino support team.
• Marketing (where consented): To send you promotional offers, bonus notifications, and platform updates via email or SMS, where you have opted in to receive such communications.
• Legal Compliance: To comply with applicable Philippine laws, court orders, and regulatory directions from PAGCOR, the NPC, and other competent authorities.

5Legal Basis for Processing

16ph processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you as a registered 16ph player — including account management, game access, deposits, and withdrawals.
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulations, AML legislation, and tax obligations.
• Legitimate Interests: Processing necessary for 16ph's legitimate interests in preventing fraud, maintaining platform security, improving services, and ensuring responsible gaming — where those interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit, freely given, specific, and informed consent. You may withdraw consent at any time.

6Data Sharing & Disclosure

16ph does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly as necessary and under appropriate data protection safeguards:

• Payment Processors: GCash (Globe Fintech Innovations Inc.), Maya (Voyager Innovations Inc.), and banking partners (BPI, BDO, Metrobank) — to process your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party KYC service providers engaged to perform identity verification and age verification services.
• Fraud Prevention & Security Partners: Technology providers who assist in detecting and preventing fraud, account takeover, and other security threats.
• Game Content Providers: Licensed game studios that provide live dealer and RNG game content accessible through the 16ph platform, where technically necessary to operate those games.
• Regulatory & Law Enforcement Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), courts, and other competent authorities, where required by law or court order.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity providers engaged to operate the 16ph platform infrastructure.

7Cookies & Tracking Technologies

7.1 What Are Cookies. Cookies are small text files stored on your device when you visit the 16ph platform. They help the platform function correctly, remember your preferences, and provide aggregate analytics about platform usage.

7.2 Types Used. 16ph uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function — including session management, login authentication, and security. These cannot be disabled.
• Functional Cookies: Remember your preferences (e.g., language settings, game lobby filters) to improve your experience across sessions.
• Analytics Cookies: Collect aggregate, anonymized data about how players use the platform — used to improve platform performance and game offering. Used with your consent.
• Marketing Cookies: Used to deliver relevant promotional content. Used only where you have consented to marketing communications.

7.3 Cookie Control. You can control non-essential cookies through your browser settings or the 16ph cookie preference centre. Note that disabling certain cookies may affect platform functionality.

8Data Retention

16ph retains your personal data for the following periods, after which data is securely deleted or anonymised unless a longer retention period is required by law:

• Account & Identity Data: For the duration of your active 16ph account, plus 5 years following account closure — to comply with AML and regulatory record-keeping obligations.
• Financial Transaction Records: 5 years from the date of each transaction, in compliance with Philippine AML legislation.
• Gaming Activity Records: 3 years from the date of each session, for dispute resolution and responsible gaming purposes.
• Customer Support Communications: 2 years from the date of resolution of each support interaction.
• Marketing Data: Until you withdraw consent or for 2 years from last engagement, whichever is earlier.

9Data Security

16ph implements technical and organizational security measures appropriate to the sensitivity of the personal data we process. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 16ph platform
• Salted cryptographic hashing of account passwords — passwords are never stored in plain text
• Two-factor authentication (2FA) available to all registered 16ph players
• Automated session token expiry and anomalous login detection
• Regular independent penetration testing of platform infrastructure
• Strict access controls ensuring 16ph staff access only the minimum data required for their role
• Encrypted storage for sensitive financial data at rest

While 16ph implements all reasonable security measures, no online system can guarantee absolute security. You also play a role in protecting your account — never share your 16ph login credentials with anyone, including persons claiming to be 16ph staff.

10Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (R.A. 10173), you have the following rights in relation to your personal data held by 16ph:

• Right to be Informed: The right to know what personal data about you is being collected, how it is processed, and with whom it is shared — as set out in this Policy.
• Right of Access: The right to request a copy of the personal data 16ph holds about you and to receive information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You can update basic profile information directly in your 16ph account settings.
• Right to Erasure / "Right to be Forgotten": 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 overriding legal retention obligations.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes at any time, and to object to other processing based on legitimate interests in specific circumstances.
• Right to Data Portability: The right to receive your personal data in a structured, machine-readable format and, where technically feasible, to request its transfer to another data controller.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact 16ph's Data Protection Officer using the contact details in Section 16. 16ph will respond to all valid data subject requests within 30 days. Some requests may take longer and we will notify you accordingly.

11Children & Minors

The 16ph platform is strictly restricted to individuals aged 21 years and older, in compliance with PAGCOR's age requirements for online gaming in the Philippines. 16ph does not knowingly collect personal data from individuals under 21. If we become aware that personal data has been collected from a person under the applicable age threshold, that data will be deleted promptly and the associated account will be closed. If you have reason to believe that a minor has registered on the 16ph platform, please notify our support team immediately.

12International Data Transfers

The 16ph platform is primarily designed to serve players in the Philippines, and player data is processed within the Philippines where technically feasible. Where 16ph engages third-party service providers that may process data outside the Philippines — including cloud infrastructure, game content providers, or KYC partners — such transfers are subject to contractual safeguards requiring the recipient to maintain data protection standards equivalent to those required by Philippine law. 16ph will not transfer your personal data internationally in the absence of such safeguards.

13Third-Party Links

The 16ph platform may contain links to third-party websites or services — for example, game studio websites or payment provider pages. This Privacy Policy applies only to the 16ph platform operated at 16ph.asia. 16ph is not responsible for the privacy practices of third-party websites and recommends that you review the privacy policies of any third-party services you access. For the avoidance of doubt, this Policy does not govern the data practices of GCash, Maya, or any banking institution — those are governed by their own respective privacy policies.

14Marketing Communications

14.1 Consent-Based Marketing. 16ph sends promotional emails and SMS messages (including bonus offers, free spin credits, cashback notifications, and new game announcements) only to players who have opted in to receive such communications during registration or subsequently through account settings.

14.2 Opting Out. You may opt out of marketing communications at any time by: (a) clicking the "unsubscribe" link in any marketing email; (b) adjusting communication preferences in your 16ph account settings; or (c) contacting 16ph support through the live chat channel. Opt-out requests will be processed within 5 business days. Note that opting out of marketing communications will not affect service communications required for account management (e.g., deposit confirmations, withdrawal notifications, security alerts).

15Changes to This Privacy Policy

16ph may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform operations. When material changes are made, 16ph will notify registered players by email or through a platform notification prior to the changes taking effect. The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Policy periodically. Your continued use of the 16ph platform following notification of updates constitutes acceptance of the revised Policy.

16Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or want to raise a privacy concern, please contact the 16ph Data Protection Officer through the following channels:

• Live Chat: Available 24/7 on the 16ph platform — the fastest way to reach our support and DPO team, with average response under 2 minutes
• Email: [email protected] (plain text — not a clickable link; include "Privacy Request" in the subject line for DPO routing)

16ph is committed to addressing all privacy inquiries promptly and in good faith. Where your request relates to the exercise of a formal data subject right under the Data Privacy Act, 16ph will provide a substantive response within 30 calendar days.