p65 Privacy Policy

This Privacy Policy ("Policy") is issued by p65, the operator of the online gaming platform accessible at p65.biz ("the Platform"). p65 acts as the personal information controller ("PIC") in respect of all personal data collected from users of the Platform, as defined under the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and the implementing rules and regulations issued by the National Privacy Commission (NPC).

p65 is licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) to offer online gaming services to eligible players in the Philippines. The collection and processing of personal data by p65 is conducted in accordance with PAGCOR licensing requirements, the Anti-Money Laundering Act (Republic Act No. 9160, as amended), and all applicable Philippine data protection laws.

This Policy applies to all personal data collected through your use of the p65 website, any associated mobile-optimized pages, live chat support, customer email communications, KYC verification processes, and payment processing activities.

p65 collects the following categories of personal information, each collected for a specific and lawful purpose:

2.1 Registration and Identity Data

• Full legal name as it appears on a government-issued Philippine ID
• Date of birth (for age verification — players must be 21 or older)
• Gender
• Nationality
• Residential address
• Email address and mobile phone number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Copy of government-issued photo ID (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID)
• Selfie or liveness verification image submitted for biometric matching
• Proof of address documents where required for enhanced due diligence
• Source-of-funds documentation for players subject to AMLA enhanced due diligence thresholds

2.3 Financial and Transaction Data

• GCash account details (mobile number associated with your GCash wallet)
• Maya account details where applicable
• Bank account details (BPI, BDO, Metrobank, or other BSP-supervised institution) where applicable
• Deposit and withdrawal transaction records including amounts, timestamps, and reference numbers
• Wallet balance history

2.4 Gaming Activity Data

• Game play history including game titles, bet amounts, outcomes, and session durations
• Sports betting selections and results
• Bonus and promotion usage records
• Loyalty program tier and point accumulation data

2.5 Technical and Device Data

• IP address at the time of login and during sessions
• Device type, operating system, and browser type
• Session identifiers and access timestamps
• Geolocation data (country/city level, derived from IP) for compliance purposes
• Cookies and similar tracking technology data, as further described in Section 8

2.6 Communications Data

• Records of live chat, email, and support ticket interactions
• Complaint and dispute records
• Preferences indicated through account settings, including marketing communications opt-in/opt-out status

p65 uses the personal data we collect for the following purposes:

p65 does not use automated decision-making that produces legal or similarly significant effects on players, except for fraud detection systems that may temporarily flag accounts pending human review. Players may request human review of any automated flag by contacting customer support.

Under the Data Privacy Act of 2012 and its implementing regulations, p65 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to perform the services you have contracted with p65 for — including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act reporting duties, National Privacy Commission requirements, and other applicable Philippine law.
• Legitimate Interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where these interests do not override your privacy rights.
• Consent: Processing for marketing communications and optional personalization features, which you may withdraw at any time by updating your account preferences or contacting support.

Where processing is based on consent, withdrawal of that consent will not affect the lawfulness of any processing carried out prior to withdrawal.

p65 does not sell, rent, or trade your personal data. We share personal data with third parties only in the following defined circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: GCash (operated by G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), and other BSP-supervised payment service providers require your account identifiers and transaction data to execute deposits and withdrawals.
• KYC Verification Providers: p65 engages authorized identity verification service providers to perform document authentication and biometric checks. These providers process your ID documents and selfie data under strict data processing agreements and are prohibited from using your data for their own purposes.
• Game Technology Providers: Game studios and RNG certification bodies may receive anonymized session data required to operate or audit specific games. No identity-linked data is shared with game providers beyond what is technically necessary.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies may receive transaction reports, player data, and suspicious activity reports as required by law. p65 complies with all lawful requests from competent Philippine authorities.
• Legal and Law Enforcement: In response to valid court orders, subpoenas, or lawful requests from law enforcement agencies in the Philippines, p65 may disclose personal data as required.
• Professional Advisors: p65's legal counsel, auditors, and compliance consultants may access limited personal data in the course of performing their professional services, under applicable confidentiality obligations.

All third-party service providers engaged by p65 are subject to written data processing agreements that require them to protect your data to standards no less protective than those set out in this Policy and the Data Privacy Act of 2012.

p65 does not transfer personal data outside the Philippines except where required by a specific regulatory obligation or where you have expressly consented to an international transfer, and only to jurisdictions that provide adequate levels of data protection.

p65 retains personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following specific retention obligations:

• Account Data: Retained for the duration of the active account relationship, and for a minimum of 5 years following account closure, as required by PAGCOR licensing conditions and AMLA record-keeping obligations.
• KYC Documents: Retained for 5 years from the date of the last transaction, as required under the Anti-Money Laundering Act.
• Transaction Records: Retained for 5 years from the transaction date, in accordance with AMLA requirements and BSP record-keeping standards.
• Gaming Activity Data: Retained for 5 years for compliance audit purposes, then aggregated and anonymized for analytical use.
• Customer Support Communications: Retained for 3 years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of the marketing relationship plus 2 years following consent withdrawal, as evidence of the consent history.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized using industry-standard data destruction procedures. Where technical constraints prevent immediate deletion, data is quarantined and access-restricted until deletion is executed.

p65 implements a comprehensive set of technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction:

• All data in transit is encrypted using TLS 1.3 with 256-bit SSL certificates. All data at rest in p65 production databases is encrypted using AES-256.
• Access to personal data is restricted to p65 personnel who have a legitimate need to access it. Role-based access controls are enforced and audited quarterly.
• p65's production infrastructure is hosted in BSP-compliant data center facilities in the Philippines with physical access controls, redundant power, and 24/7 monitoring.
• Two-factor authentication is mandatory for all p65 staff accessing systems that contain personal data.
• p65 conducts regular penetration testing and vulnerability assessments on all production systems.
• An information security incident response plan is maintained and tested annually, covering the 72-hour breach notification obligation to the NPC.

p65 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device by the p65 web server. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in, security tokens, and cookies that remember your account settings. These cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, game lobby filter preferences, and responsible gaming reminder intervals. Disabling these may reduce the personalization of your experience.
• Analytics Cookies: Used to understand how players interact with the Platform — including which game categories are most visited, average session durations, and navigation paths. Analytics data is aggregated and does not identify individual players.
• Security and Fraud Prevention Cookies: Used to detect abnormal login patterns, bot behavior, and multi-account activity for compliance and security purposes.

p65 does not use third-party advertising cookies or serve behavioral advertising based on your Platform activity. You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in to your p65 account.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by p65. You may exercise any of these rights by contacting our Data Protection Officer using the details in Section 13:

The p65 Platform is strictly intended for persons who are 21 years of age or older, as required by PAGCOR regulations governing online gambling in the Philippines. p65 does not knowingly collect personal data from any person below the age of 21.

p65 enforces age verification through its KYC process, which requires submission of a government-issued Philippine ID. If p65 discovers that personal data has been collected from a person below the minimum age, the account will be immediately closed, all collected data will be deleted except as required by legal retention obligations, and any deposited funds will be handled in accordance with PAGCOR guidance.

If you are a parent or guardian and believe your child has registered on p65, please contact our Data Protection Officer immediately using the contact details in Section 13.

The p65 Platform does not contain links to third-party websites. p65.biz is a self-contained platform and all navigation within the site directs users to internal pages only. This Policy applies solely to the p65 Platform and does not extend to any other website or platform that you may access independently.

p65 may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or operational procedures. When material changes are made, p65 will notify registered players via the email address on file at least 14 days before the amended policy takes effect.

The date of the most recent update is displayed at the top of this page. We encourage you to review this Policy periodically to remain informed about how p65 protects your personal data. Your continued use of the Platform after the effective date of any updated Policy constitutes acceptance of the revised terms.

p65 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Policy. To exercise your data rights, report a privacy concern, or ask questions about this Policy, please contact:

• Data Protection Officer — p65: [email protected] (plain text — not a clickable link)
• General Support: [email protected] (plain text — not a clickable link)
• Live Chat: Available on p65.biz daily from 8:00 AM to 12:00 Midnight PST

p65 will acknowledge all privacy-related requests within 3 business days and will provide a substantive response within 15 business days of receiving a complete and verifiable request. For complaints that cannot be resolved through p65's internal process, you may escalate to the National Privacy Commission of the Philippines.