Privacy Policy — 12ph

This Privacy Policy applies to all personal data collected and processed by 12ph in connection with the online gaming platform accessible at https://12ph.bet (the "Platform"). It covers data collected from registered users, visitors who browse the Platform without registering, applicants for employment or partnerships, and any other individual whose personal data is received by 12ph in the course of operating the Platform.

This Policy applies regardless of the device or channel through which you access the 12ph Platform — whether via a desktop web browser, a mobile browser, or any 12ph-branded mobile application made available in the future.

By creating a 12ph Account, depositing funds, or continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood its terms. If you do not agree with any part of this Policy, you should discontinue your use of the 12ph Platform and may close your Account in accordance with our Terms & Conditions.

12ph collects the following categories of personal data in connection with the operation of the Platform:

3.1 Directly From You. The majority of personal data we hold is provided directly by you when you: register for a 12ph Account; complete the KYC verification process; make a deposit or withdrawal; contact our support team; respond to a promotion or survey; or update your Account settings.

3.2 Automatically. When you visit or use the 12ph Platform, we automatically collect certain technical data through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, browser fingerprint, pages visited, and interaction events. See Section 9 for our full Cookies & Tracking disclosure.

3.3 From Third Parties. 12ph may receive personal data about you from the following third-party sources:

• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank, Visa/Mastercard networks) — to verify and process transactions;
• KYC and identity verification providers — to confirm the authenticity of identity documents;
• Fraud detection and anti-money laundering screening services — to identify suspicious activity;
• PAGCOR's national self-exclusion registry — to verify whether a prospective registrant is subject to a gaming exclusion order.

3.4 Publicly Available Sources. On occasion, 12ph may cross-reference information you provide against publicly available records — such as court records or national ID databases — strictly for KYC, fraud prevention, and regulatory compliance purposes.

12ph processes your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 12ph Account, including processing your registration, authenticating your identity at login, and administering your account preferences;
• Service Delivery: To provide you with access to 12ph's full range of gaming services — including sports betting, live casino, slot games, bingo, and promotional features — in accordance with our Terms & Conditions;
• Payment Processing: To process deposits, execute withdrawals to your verified payment method, and maintain accurate financial records of all transactions in PHP;
• KYC & Regulatory Compliance: To verify your identity and age (21+), comply with PAGCOR licence conditions, meet obligations under the Philippine AMLC Act, and respond to lawful requests from government authorities;
• Responsible Gaming: To monitor your gaming activity for signs of problem gambling, enforce deposit limits and self-exclusion requests, and comply with PAGCOR's responsible gaming requirements;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other security threats to the Platform and its users;
• Customer Support: To respond to your inquiries, resolve complaints, process account closure requests, and improve the quality of our support services;
• Marketing Communications: Where you have given your consent, to send you promotional emails, SMS notifications, and in-app messages about 12ph bonuses, new game releases, and special events. You may opt out at any time via Account Settings or by contacting support;
• Platform Improvement: To analyse usage patterns, conduct A/B testing, and improve the 12ph Platform's performance, usability, and game offering.

Under the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, 12ph processes your personal data on the following legal bases:

• Contractual Necessity: Processing that is necessary to perform our contract with you — i.e., to deliver the 12ph gaming services you have registered to access, to process your transactions, and to manage your Account;
• Legal Obligation: Processing that is required to comply with applicable Philippine law, including PAGCOR licence conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act itself, and other regulatory requirements;
• Legitimate Interests: Processing that is necessary for 12ph's legitimate business interests, such as fraud detection, platform security, and improving our services, provided that these interests are not overridden by your rights and freedoms;
• Consent: Processing for marketing communications and certain analytics activities, where we have obtained your express consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6.1 Service Providers. 12ph shares personal data with third-party service providers who assist in operating the Platform. These providers act as data processors on our behalf and are contractually bound to process your data only as instructed by 12ph and in accordance with RA 10173. Categories of service providers include: payment gateway operators (GCash, PayMaya, major Philippine banks), KYC verification technology providers, cloud hosting and data centre operators, fraud detection and risk management vendors, and customer support platform operators.

6.2 Regulatory Authorities. 12ph is required by law and by the conditions of its PAGCOR licence to share certain player data with regulatory and law enforcement authorities. This includes: PAGCOR (in connection with our gaming licence and player protection requirements), the Philippine Anti-Money Laundering Council (AMLC) (as required under RA 9160 and its amendments), the National Privacy Commission (NPC) (in the event of a data breach or regulatory inquiry), and other competent Philippine government agencies pursuant to a valid legal process.

6.3 Business Transfers. In the event of a merger, acquisition, or sale of all or part of 12ph's business, your personal data may be transferred to the successor entity as part of that transaction. You will be notified in advance of any such transfer and of any material change in the processing of your data.

6.4 What We Will Never Do. 12ph will never sell, rent, or trade your personal data to third-party marketers, advertising networks, or data brokers. We do not share your data with other gaming operators or affiliate networks without your explicit consent.

7.1 Retention Periods. 12ph retains your personal data for as long as necessary to fulfil the purposes for which it was collected, to comply with our legal and regulatory obligations, and to resolve any disputes that may arise. Specific retention periods are as follows:

7.2 Deletion. Once the applicable retention period has expired and there is no legal or regulatory requirement to retain your data further, 12ph will securely delete or anonymise your personal data so that it can no longer be associated with you as an individual.

8.1 Technical Measures. 12ph implements a range of technical security measures to protect your personal data, including: Transport Layer Security (TLS 1.3) encryption for all data transmitted between your device and 12ph servers; AES-256 encryption for personal and financial data stored at rest; hashed storage of account passwords using industry-standard algorithms; strict role-based access controls limiting employee access to personal data on a need-to-know basis; continuous intrusion detection and network monitoring; and regular third-party security audits and penetration testing.

8.2 Organisational Measures. In addition to technical controls, 12ph maintains organisational security practices including: mandatory data privacy training for all employees who handle personal data; a formal data breach response plan registered with the National Privacy Commission; non-disclosure agreements with all staff and service providers who have access to personal data; and a designated Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173.

8.3 Data Breach Notification. In the event of a personal data breach that poses a real risk of serious harm to affected data subjects, 12ph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected users within the timeframe prescribed by NPC regulations. Notification will be provided via email to the address associated with your 12ph Account.

8.4 Your Role in Security. While 12ph takes all reasonable steps to protect your data, you also play an important role in keeping your Account secure. You should use a strong, unique password for your 12ph Account, enable any available two-factor authentication, and never share your login credentials with anyone. Report any suspected unauthorised access to [email protected] immediately.

9.1 What Are Cookies. Cookies are small text files placed on your device by a website you visit. They are widely used to make websites work more efficiently, to remember your preferences, and to provide website operators with analytical information about how users interact with the site.

9.2 Cookies Used by 12ph. The 12ph Platform uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. You cannot opt out of these cookies and still use the Platform;
• Functional Cookies: Used to remember your preferences such as language settings, responsible gaming limits you have set, and your last-used payment method to improve your user experience;
• Analytical Cookies: Used by 12ph to understand how users interact with the Platform — which pages are visited most, where users encounter errors, and how session flows are completed. This data is used to improve the Platform and is processed in aggregated, anonymised form;
• Security and Fraud Prevention Cookies: Used to identify unusual login or transaction patterns that may indicate account takeover attempts or bonus abuse activity.

9.3 Managing Cookies. You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. However, blocking strictly necessary cookies will prevent you from logging in to and using the 12ph Platform. Instructions for managing cookies in popular browsers are available in each browser's help documentation.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 12ph:

• Right to Be Informed: You have the right to be informed of what personal data 12ph collects about you, why it is collected, and how it will be used. This Privacy Policy is our primary fulfilment of this right;
• Right of Access: You may request a copy of the personal data that 12ph holds about you at any time. We will provide a structured, readable copy within thirty (30) days of a verified request;
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update most account information directly through Account Settings;
• Right to Erasure: You may request that 12ph delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal and regulatory retention obligations under PAGCOR and AMLC rules;
• Right to Data Portability: You may request that 12ph provide your personal data in a commonly used, machine-readable format so that you can transfer it to another service provider;
• Right to Object: You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis, or to opt out of marketing communications at any time;
• Right to File a Complaint: If you believe that 12ph has violated your data privacy rights, you have the right to file a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will acknowledge your request within five (5) business days and fulfil it within the timeframe prescribed by RA 10173 and NPC regulations.

11.1 Strict 21+ Policy. The 12ph Platform is strictly intended for adults who are at least twenty-one (21) years of age, in compliance with PAGCOR's minimum age requirement for online gaming in the Philippines. We do not knowingly collect personal data from individuals under the age of 21.

11.2 Age Verification at Registration. During the registration process, 12ph requires all prospective users to declare their date of birth and to confirm that they are 21 years of age or older. Automated age verification checks are applied at the point of registration. Where automated checks are inconclusive, manual KYC review is initiated before account activation.

11.3 Discovery of Under-Age Accounts. If 12ph discovers — through our own monitoring, a report from a third party, or during KYC review — that a registered Account belongs to a person under the age of 21, the Account will be immediately closed, all gaming activity will be voided, and any funds held in the Account (including deposits and winnings) will be forfeited in accordance with PAGCOR regulations. The matter may be referred to PAGCOR's player protection division.

11.4 Parental Controls. If you are a parent or guardian and believe that your child may have registered on the 12ph Platform, please contact us immediately at [email protected]. We will investigate and, if confirmed, close the Account and take all required remedial steps.

12.1 Primary Processing in the Philippines. 12ph's primary data processing infrastructure is located within the Philippines. The majority of personal data collected from 12ph users is stored on servers physically located within Philippine territory.

12.2 Transfers to Third Countries. Certain service providers engaged by 12ph — such as cloud infrastructure providers and KYC technology vendors — may process or store data outside of the Philippines. Where such cross-border transfers occur, 12ph ensures that adequate safeguards are in place, including: contractual data processing agreements that meet NPC standards for cross-border data transfers; confirmation that the recipient country has been assessed as providing an adequate level of data protection; and, where required, registration of the cross-border transfer arrangement with the National Privacy Commission.

12.3 Your Acknowledgement. By registering for and using the 12ph Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines in the circumstances described above, subject to the safeguards outlined in this section.

13.1 Right to Update. 12ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, updates to NPC or PAGCOR regulations, changes in our data processing practices, or improvements to Platform operations. The revised Policy will be published on this page with an updated effective date.

13.2 Notification of Material Changes. Where changes to this Policy are material — meaning they significantly affect how we use your personal data or your rights under this Policy — 12ph will notify registered users by email to the address associated with their Account at least fourteen (14) days before the changes take effect. A prominent notice will also be displayed on the 12ph Platform during this notice period.

13.3 Continued Use as Acceptance. Your continued use of the 12ph Platform after the effective date of any updated Privacy Policy constitutes your acknowledgement and acceptance of the revised terms. If you do not agree with the updated Policy, you should cease using the Platform and may close your Account by contacting [email protected].

For any questions, concerns, or requests relating to this Privacy Policy or to your personal data rights under RA 10173, please contact the 12ph Data Protection Officer using the following details:

If you are not satisfied with 12ph's handling of your data privacy concern, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines, which is the competent supervisory authority for data protection matters under RA 10173.