Privacy Policy

1. Introduction

19ph ("we", "us", "our") is committed to protecting the privacy and personal data of all users of the 19ph platform. We understand that Filipino players trust us with sensitive personal and financial information, and we take that responsibility seriously.

This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in connection with the 19ph website at 19ph.net, the 19ph mobile application, and all related services (collectively, the "Platform"). It has been prepared in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference. Capitalised terms not defined in this Privacy Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, 19ph is the personal information controller responsible for your personal data collected through the Platform.

As the personal information controller, 19ph determines the purposes and means of processing your personal data. We are accountable for ensuring that your data is handled in accordance with applicable Philippine data privacy law and this Privacy Policy.

If you have any questions, concerns, or requests relating to your personal data, you may contact our Data Protection Officer through the contact details provided in Section 16 of this Privacy Policy.

3. Data We Collect

19ph collects the following categories of personal data from users of the Platform:

We do not collect sensitive personal information beyond what is strictly necessary for identity verification, regulatory compliance, and the provision of our services. We do not collect information about your race, religion, political affiliations, or health status unless specifically required by law.

4. How We Collect Your Data

19ph collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 10 for more details on cookies.
• Third-Party Sources: Identity and fraud verification data from third-party KYC and anti-money laundering service providers; payment data from payment processors such as GCash and PayMaya; and publicly available information used for fraud prevention purposes.
• Regulatory Sources: Information received from PAGCOR or other regulatory authorities in connection with our compliance obligations.

5. Purposes of Processing

19ph processes your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 19ph account, including verifying your identity and age (21+ requirement), processing your registration, and managing your account preferences.
• Service Delivery: To provide you with access to the games and features available on the 19ph Platform, process your bets, and credit your winnings.
• Financial Transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods; to maintain accurate financial records; and to detect and prevent fraudulent transactions.
• Regulatory Compliance: To comply with our obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012. This includes maintaining records of your gaming activity and financial transactions as required by law.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, to enforce responsible gaming limits you have set, and to administer self-exclusion requests.
• Customer Support: To respond to your queries, complaints, and requests, and to maintain records of our communications with you.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the 19ph Platform.
• Marketing Communications: To send you promotional offers, bonuses, and updates about 19ph, where you have consented to receive such communications. You may opt out at any time.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 19ph processes your personal data on the following legal bases:

• Contractual Necessity: Processing necessary for the performance of our contract with you — i.e., providing you with access to the 19ph Platform and processing your gaming transactions.
• Legal Obligation: Processing necessary to comply with our legal obligations under Philippine law, including PAGCOR regulations, AMLA requirements, and tax obligations.
• Legitimate Interests: Processing necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, security monitoring, and platform improvement — provided such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Sharing Your Personal Data

19ph does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and Compliance Providers: Third-party identity verification and anti-money laundering service providers engaged to assist with our regulatory compliance obligations.
• Technology Service Providers: Cloud hosting providers, software vendors, and IT service providers who support the operation of the 19ph Platform, subject to strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or regulatory obligation.
• Law Enforcement: Philippine law enforcement agencies, where required by a valid legal order, warrant, or subpoena.
• Professional Advisers: Legal counsel, auditors, and other professional advisers engaged by 19ph, subject to professional confidentiality obligations.

8. Data Retention

19ph retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine anti-money laundering regulations.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for a minimum of two (2) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.
• Technical and Log Data: Retained for up to twelve (12) months from the date of collection, unless required for longer retention in connection with a security investigation or legal proceeding.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, 19ph will securely delete or anonymise the data in accordance with our data disposal procedures.

9. Data Security

19ph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the 19ph Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data stored on our systems, including passwords and financial information, is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorised 19ph personnel and service providers who require access to perform their duties. All access is logged and monitored.
• Secure Infrastructure: The 19ph Platform is hosted on secure, regularly audited infrastructure with firewalls, intrusion detection systems, and regular vulnerability assessments.
• Staff Training: All 19ph personnel who handle personal data receive regular training on data privacy obligations and security best practices.
• Incident Response: 19ph maintains a data breach response procedure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

10. Cookies & Tracking Technologies

19ph uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the 19ph website. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the operation of the Platform, including maintaining your login session and enabling secure transactions. These cookies cannot be disabled without affecting Platform functionality.
• Performance Cookies: Used to collect anonymised information about how visitors use the Platform, such as which pages are visited most frequently and whether error messages are received. This data helps us improve Platform performance.
• Functionality Cookies: Used to remember your preferences and settings, such as your preferred language and responsible gaming limits, to provide a more personalised experience.
• Analytics Cookies: Used to analyse usage patterns and measure the effectiveness of our Platform features. Analytics data is aggregated and does not identify individual users.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 19ph Platform. Your continued use of the Platform following our cookie notice constitutes your consent to our use of cookies as described in this section.

11. Your Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 19ph:

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data 19ph holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain account information directly through your 19ph account settings.
• Right to Erasure: 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 our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time through your account settings or by contacting our support team.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 19ph has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details in Section 16. We will respond to all verified requests within thirty (30) days of receipt. We may need to verify your identity before processing your request.

12. Minors

The 19ph Platform is strictly intended for persons who are 21 years of age or older, in accordance with Philippine gaming regulations. 19ph does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 19ph Platform, please contact our support team immediately.

Our registration process includes age verification steps, and we reserve the right to request government-issued identification to confirm that any user meets the 21+ age requirement at any time.

13. International Data Transfers

19ph primarily processes and stores personal data within the Philippines. In some cases, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or technology vendors operating in other jurisdictions.

Where personal data is transferred outside the Philippines, 19ph ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012. These safeguards may include contractual data protection clauses, adequacy assessments, or other mechanisms recognised under Philippine data privacy law.

By using the 19ph Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

14. Third-Party Services

The 19ph Platform may integrate with or link to third-party services, including payment processors such as GCash and PayMaya. These third-party services operate under their own privacy policies, which are independent of this Privacy Policy.

19ph is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services you use in connection with your 19ph account. Our integration with third-party payment providers is limited to what is necessary to process your financial transactions and does not involve sharing your gaming data with those providers.

15. Policy Amendments

19ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered users via the email address associated with their account or through a prominent notice on the Platform.

The date of the most recent revision is displayed at the top of this page. We recommend that you review this Privacy Policy periodically. Your continued use of the 19ph Platform following any amendment constitutes your acknowledgment of the updated Privacy Policy.

16. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 19ph, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC is the government authority responsible for administering and implementing the Data Privacy Act of 2012 in the Philippines.