123ph7 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by 123ph7 ("Company," "we," "us," or "our") and applies to all personal data processed in connection with your use of the 123ph7 online gaming platform accessible at 123ph7.club and all associated mobile-optimised interfaces and services (the "Platform").

123ph7 is committed to protecting the privacy and personal data of all Filipino players and visitors to the Platform. We process personal data only for legitimate, specified purposes, and we maintain technical and organisational measures appropriate to the sensitivity of the data we handle.

This Policy is drafted in accordance with Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines. It should be read alongside the 123ph7 Terms & Conditions and Responsible Gaming Policy.

By registering an account with 123ph7 or by continuing to access the Platform after this Policy has been published, you acknowledge that you have read and understood how we handle your personal data as described herein.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and its IRR, the personal information controller in respect of data collected through the 123ph7 Platform is:

Questions about this Policy or your personal data rights may be directed to our Data Protection Officer via the contact email above. Please include "Data Privacy" in your message subject.

3 Personal Data We Collect

3.1 Identity and Contact Data

When you register a 123ph7 account, we collect: your full legal name as it appears on your government-issued ID; your Philippine mobile number; your date of birth; and, where applicable, your residential address and email address. This information forms the basis of your account identity and is required for KYC compliance.

3.2 Identity Verification (KYC) Documents

In compliance with PAGCOR licence conditions and the Anti-Money Laundering Act (RA 9160 as amended), we collect copies of government-issued photographic identification (e.g., PhilSys National ID, Philippine passport, UMID, driver's licence) and, where required, proof of residential address (e.g., utility bill, bank statement dated within 90 days). KYC documents are processed and stored with enhanced security controls.

3.3 Financial and Transaction Data

We collect records of all deposits, withdrawals, and in-platform transactions associated with your 123ph7 account, including payment method identifiers (e.g., GCash registered mobile number, bank account details), transaction amounts in PHP, transaction timestamps, and transaction reference numbers. This data is retained for AML compliance and audit purposes.

3.4 Gaming Activity Data

We collect detailed records of your gaming activity on the 123ph7 Platform, including: game sessions; wager amounts; game outcomes; bonus transactions; and session durations. This data is used for game integrity purposes, dispute resolution, responsible gaming monitoring, and to personalise your experience.

3.5 Technical and Device Data

We automatically collect certain technical data when you access the Platform, including: your IP address; device type and operating system; browser type and version; session timestamps; pages visited and navigation path; and referring URL. This data is collected via server logs and, where applicable, cookies and similar technologies.

3.6 Communications Data

We retain records of communications between you and 123ph7 customer support, including live chat transcripts, support ticket correspondence, and any feedback or survey responses you submit. These records are used for quality assurance, training, and dispute resolution.

4 How We Collect Your Data

123ph7 collects personal data through the following means:

• Directly from you — during account registration, KYC submission, deposit and withdrawal requests, support interactions, and survey participation;
• Automatically — via server logs, session tracking, and cookie technologies as you navigate the Platform;
• From third parties — from identity verification partners (for KYC), payment processors (for transaction data), and fraud prevention service providers, where necessary and where we have a lawful basis for such receipt.

5 Legal Bases for Processing

Under the Data Privacy Act of 2012, 123ph7 processes your personal data on the following legal bases:

• Contractual necessity — processing required to fulfil our contractual obligations to you under the 123ph7 Terms & Conditions, including account management, game delivery, deposits, and withdrawals;
• Legal obligation — processing required to comply with applicable Philippine laws, including PAGCOR licence conditions, the Anti-Money Laundering Act, and NPC data protection requirements;
• Legitimate interest — processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests are not overridden by your privacy interests;
• Consent — processing for optional marketing communications (SMS, email), where we have obtained your prior, informed, and freely given consent. You may withdraw this consent at any time by contacting support.

6 How We Use Your Personal Data

123ph7 uses the personal data it collects for the following purposes:

• To create, verify, and manage your 123ph7 account;
• To process deposits, withdrawals, and in-platform transactions via GCash, Maya, BPI, BDO, and other listed payment methods;
• To verify your identity and age in compliance with PAGCOR licence conditions and the 21+ age restriction;
• To comply with AML obligations and file Suspicious Transaction Reports (STRs) with the AMLC where required;
• To deliver and maintain the games, features, and services available on the Platform;
• To administer bonus offers, promotions, and loyalty programmes;
• To monitor gaming activity for responsible gaming purposes, including identifying patterns indicative of problem gambling;
• To detect, investigate, and prevent fraud, cheating, collusion, and other prohibited conduct;
• To provide customer support and resolve disputes;
• To send service communications (account alerts, transaction confirmations, security notifications) via SMS or email;
• Where consent has been given: to send marketing communications about 123ph7 promotions and new game launches.

7 Disclosure of Personal Data to Third Parties

123ph7 does not sell, rent, or trade your personal information. We disclose personal data to third parties only in the following circumstances and only to the extent strictly necessary:

• Identity verification providers — for KYC document processing as required by PAGCOR;
• Payment processors — GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), BancNet, and other payment service providers, solely for processing your financial transactions;
• Game providers — licensed game software suppliers (e.g., JILI, PG Soft, Pragmatic Play, Evolution) may receive session data necessary to deliver their games under data processing agreements with 123ph7;
• PAGCOR and AMLC — as required under 123ph7's licence conditions and the Anti-Money Laundering Act;
• Law enforcement and courts — in response to lawful orders, subpoenas, or warrants issued by competent Philippine authorities;
• Fraud prevention services — anonymised or pseudonymised data may be shared with fraud intelligence platforms to detect and prevent account fraud.

All third parties who process data on behalf of 123ph7 are bound by data processing agreements requiring them to maintain the confidentiality and security of your data and to process it only for the specified purpose.

8 Cookies and Tracking Technologies

123ph7 uses cookies and similar tracking technologies (web beacons, pixel tags, local storage) to operate the Platform effectively. The categories of cookies we use are:

• Strictly necessary cookies — required for session management, authentication, and security. These cannot be disabled without impairing Platform functionality;
• Functional cookies — used to remember your preferences such as language settings and last-visited game lobby;
• Analytical cookies — used to understand aggregate Platform usage patterns (page load times, error frequencies, navigation flows). These do not identify you personally;
• Marketing cookies — used only with your prior consent, to deliver relevant promotional content based on your Platform activity.

You may manage non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of certain Platform features. 123ph7 does not use third-party social media tracking pixels.

9 Data Security

123ph7 implements a layered security architecture appropriate to the nature and sensitivity of the personal data we process. Security measures include:

• SSL/TLS 256-bit encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial data;
• Role-based access controls ensuring that staff access to personal data is limited to what is necessary for their specific function;
• Multi-factor authentication for all 123ph7 staff with access to personal data systems;
• Regular penetration testing and vulnerability assessments of the Platform infrastructure;
• Intrusion detection and 24/7 security monitoring.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, 123ph7 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay, as required by the Data Privacy Act of 2012.

10 Data Retention

123ph7 retains personal data for the following periods, after which data is securely deleted or anonymised:

11 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its IRR, you have the following rights in respect of your personal data held by 123ph7:

• Right to be informed — you have the right to know how your personal data is being collected and processed, as described in this Policy;
• Right of access — you may request a copy of the personal data 123ph7 holds about you;
• Right to rectification — you may request correction of inaccurate or incomplete personal data;
• Right to erasure — you may request deletion of personal data that is no longer necessary for its collection purpose, subject to overriding legal retention obligations;
• Right to object — you may object to processing of your personal data for direct marketing purposes at any time;
• Right to data portability — you may request a machine-readable copy of personal data you have provided to 123ph7;
• Right to lodge a complaint — you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, contact 123ph7's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." We will respond within 15 business days of receiving a verified request. Identity verification will be required before processing access or portability requests.

12 Children's Privacy and the 21+ Requirement

The 123ph7 Platform is strictly restricted to individuals aged 21 years and above, in accordance with applicable Philippine gaming regulations administered by PAGCOR. 123ph7 does not knowingly collect personal data from any person under the age of 21.

If 123ph7 discovers that personal data has been collected from an individual under 21, the relevant account will be immediately suspended, all associated funds will be returned (less applicable deductions for any AML review requirements), and the personal data will be securely deleted to the extent permitted by law.

Parents and guardians who believe that a minor has registered an account with 123ph7 should contact support immediately with documentary evidence.

13 Cross-Border Data Transfers

Some of 123ph7's service providers — including licensed game providers such as JILI, PG Soft, Pragmatic Play, and Evolution — operate servers outside the Philippines. Where personal data is transferred to processors in other jurisdictions, 123ph7 ensures that:

• The transfer is made only to jurisdictions that provide an adequate level of protection for personal data, or
• Appropriate contractual safeguards (standard contractual clauses equivalent to NPC-approved data sharing agreements) are in place, and
• The transfer is limited to data strictly necessary for service delivery (typically pseudonymised session identifiers rather than full identity data).

Your gaming session data transmitted to game providers does not include your full name, Philippine ID number, or financial account details. Those categories of data remain within Philippine-hosted infrastructure except where required by law.

14 Changes to This Privacy Policy

123ph7 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, NPC guidance, or PAGCOR requirements. When material changes are made, we will provide notice via a prominent notification on the Platform displayed at your next login, or via SMS or email to your registered contact details, at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We recommend reviewing this Policy periodically. Continued use of the 123ph7 Platform after the effective date of a revised Policy constitutes your acceptance of the updated terms.

15 Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 123ph7, please contact us:

If you are not satisfied with our response to a data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines — the competent supervisory authority under the Data Privacy Act of 2012. Information on filing a complaint with the NPC is available on the NPC's official website.