Privacy Policy — p65.com

1 Introduction & Scope

This Privacy Policy ("Policy") describes how p65.com ("we," "us," or "our") collects, processes, stores, and discloses personal information relating to individuals ("you," "Player," or "User") who access or use the p65.com online casino and sports betting platform accessible at p65com.club, including all associated games, account services, payment processing, promotional programs, and customer support channels.

p65.com operates this platform primarily for Filipino players based in the Philippines and processes personal data in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. To the extent that personal data of individuals outside the Philippines is processed, p65.com also applies comparable international data protection standards.

This Policy applies to all personal data collected through: account registration, identity verification (KYC), payment processing, gameplay activity, customer support interactions, marketing communications, and general use of the p65.com website and platform interface.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, the personal information controller responsible for your data is p65.com, the operator of the p65com.club platform.

Where p65.com engages third parties to process personal data on its behalf (such as payment processors, identity verification providers, or cloud infrastructure operators), those parties act as personal information processors under written agreements that bind them to equivalent data protection standards.

3 Personal Data We Collect

p65.com collects personal data through several channels and for distinct operational purposes. The categories of personal data we collect include the following:

3.1 Registration and Account Data

When you create a p65.com account, we collect:

• Full legal name;
• Date of birth (to verify the 21+ age requirement);
• Email address;
• Mobile phone number (used for account verification and 2FA);
• Residential address (city and province, e.g., Makati, Quezon City, Cebu City, Davao);
• Username selected at registration.

3.2 Identity Verification (KYC) Data

Before enabling real-money play, p65.com requires submission of identity verification documents, which may include:

• Government-issued photo identification (Philippine National ID / PhilSys, passport, driver's license, UMID, PRC ID, or equivalent);
• A selfie or live photo for biometric liveness verification;
• Proof of address (utility bill, bank statement, or equivalent document) for accounts above specified transaction thresholds;
• Proof of source of funds for accounts processing high transaction volumes.

3.3 Financial and Transaction Data

• GCash mobile number, PayMaya account reference, or bank account details (BPI, BDO, Metrobank) used for deposits or withdrawals;
• USDT wallet address (where applicable);
• Full transaction history: deposits, withdrawals, amounts, timestamps, and associated payment method identifiers;
• Wagering history: game played, stake amount, outcome, and timestamp for every bet placed.

3.4 Technical and Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, model, and operating system;
• Browser type and version;
• Session start and end times, pages visited, game sessions initiated;
• Referral source (how you arrived at p65.com);
• Cookies and similar tracking technologies (see Section 9).

3.5 Customer Support Data

When you contact p65.com support via live chat or email, we collect and retain records of those interactions including chat transcripts and email correspondence, along with any personal information you provide in the course of those communications.

3.6 Data We Do Not Collect

4 How We Use Your Personal Data

p65.com processes personal data for the following specific purposes:

p65.com does not use your personal data for purposes incompatible with those stated in this Policy. Where we intend to use your data for a new or different purpose, we will update this Policy and, where required, seek your consent in advance.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, p65.com relies on the following legal bases when processing your personal data:

• Contractual necessity: Processing required to fulfill our obligations to you under the p65.com Terms & Conditions — including account management, payment processing, and providing gaming services;
• Legal obligation: Processing required to comply with applicable Philippine law, including anti-money laundering obligations, age verification requirements, and regulatory reporting duties;
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving our services, where such interests are not overridden by your fundamental rights;
• Consent: Processing for direct marketing communications, optional cookies and analytics beyond strictly necessary functions — where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

6 Disclosure & Data Sharing

p65.com does not sell your personal data to third parties. We may share your personal data with the following categories of recipients strictly for the purposes described in Section 4:

6.1 Service Providers (Personal Information Processors)

• Payment processors: GCash, PayMaya, and partner banks (BPI, BDO, Metrobank) receive only the data necessary to process your specific transaction;
• Identity verification providers: Third-party KYC vendors who verify government-issued IDs and conduct liveness checks — bound by contractual data processing agreements;
• Cloud infrastructure and hosting providers: Our platform is hosted on secure cloud infrastructure; infrastructure providers access server data only in the course of providing hosting services;
• Game content providers: Licensed game studios may receive anonymized or session-level gameplay data for technical integration and game performance purposes — not identifiable personal data.

6.2 Regulatory and Law Enforcement Authorities

p65.com may disclose personal data to Philippine government authorities, the National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), or law enforcement agencies where required by law, court order, or a valid regulatory demand. Where legally permitted to do so, p65.com will notify you of such a disclosure request.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of p65.com's assets, your personal data may be transferred to the acquiring entity, subject to the same data protection obligations as described in this Policy. You will be notified of any such transfer.

7 Data Retention

p65.com retains personal data only for as long as necessary for the purposes for which it was collected, taking into account applicable legal and regulatory retention obligations. The following general retention periods apply:

• Active account data: Retained for the lifetime of your p65.com account plus a minimum of five (5) years after account closure, in compliance with AML record-keeping requirements;
• KYC / identity verification documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Transaction and wagering records: Retained for a minimum of five (5) years in compliance with AMLC requirements;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained until consent is withdrawn plus one (1) year for compliance documentation;
• Technical / log data: Retained for twelve (12) months in rolling logs, except where required for active fraud or security investigations.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymized, or archived in a form that cannot reasonably be used to re-identify individuals.

8 Data Security Measures

p65.com implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include, without limitation:

• 256-bit SSL / TLS encryption on all data transmitted between your device and p65.com servers;
• Encryption at rest for sensitive data fields including passwords (bcrypt hashing), KYC document storage, and financial account references;
• Role-based access controls restricting staff access to personal data to those with a documented operational need;
• Multi-factor authentication on all internal administrative systems;
• Regular security audits and penetration testing by qualified third-party security assessors;
• Incident response procedures — in the event of a personal data breach affecting your rights, p65.com will notify affected players and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by NPC Circular No. 16-03.

While p65.com employs robust security measures, no digital platform is entirely immune to security risks. You are responsible for maintaining the security of your own login credentials and for notifying p65.com promptly if you suspect unauthorized access to your account.

9 Cookies & Tracking Technologies

p65.com uses cookies and similar tracking technologies on the p65com.club platform. A cookie is a small text file placed on your device by a website that you visit. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the platform to function — these enable secure login sessions, account authentication, and fraud prevention. These cookies cannot be disabled without affecting core platform functionality;
• Functional cookies: Remember your preferences such as language settings, display options, and game lobby configuration. These improve your experience but are not essential;
• Analytics cookies: Collect anonymized or aggregated data about how players use the platform — which games are popular, where users encounter difficulties — to improve our service. These are only placed with your consent;
• Marketing cookies: Used to track referral sources and measure the effectiveness of promotional campaigns. These are only placed with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use p65.com. You can withdraw consent to non-essential cookies at any time through the cookie preference settings accessible in the platform footer.

10 Minors & Age Policy

During account registration, p65.com collects date of birth and requires submission of valid government-issued identification confirming that the applicant is 21 years of age or older. Where p65.com discovers or has reasonable grounds to believe that an account has been created by or on behalf of a person under 21 years of age, the account will be immediately suspended, all balances will be withheld pending investigation, and any personal data of the minor will be deleted as soon as practicable after completion of necessary record-keeping obligations.

If you are a parent or guardian and believe your child has provided personal information to p65.com, please contact our support team via live chat immediately. We will take prompt action to investigate and, where confirmed, delete the data and close the account.

11 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by p65.com:

To exercise any of the above rights, contact p65.com support via live chat or email at support p65com.club with the subject line "Data Rights Request." We will respond within thirty (30) days. Complex requests may require an extension of up to an additional sixty (60) days, in which case we will notify you of the extension and the reasons for it.

12 Cross-Border Data Transfers

Some of the third-party service providers engaged by p65.com — including cloud infrastructure providers and international game studio partners — may be located outside the Philippines. Where personal data is transferred to entities in other jurisdictions, p65.com takes steps to ensure that the transfer is covered by appropriate safeguards, including:

• Contractual clauses requiring the recipient to apply equivalent data protection standards as required by the Philippine DPA;
• Transfer only to jurisdictions that the National Privacy Commission has recognized as providing an adequate level of data protection;
• Binding corporate rules where data is transferred within a corporate group.

You may request information about specific cross-border transfer safeguards by contacting our Data Protection contact as detailed in Section 14.

13 Changes to This Privacy Policy

p65.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. When material changes are made, we will:

• Update the "Last Updated" date at the top of this Policy;
• Notify registered players via email or an on-platform notification at least seven (7) days before the changes take effect;
• Where a change requires fresh consent (e.g., a new marketing channel), present a separate consent request before commencing the new processing.

Continued use of p65.com following the effective date of any amended Policy constitutes your acknowledgement of those changes. We recommend reviewing this page periodically to stay informed of current data practices.

14 Contact, Complaints & NPC

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data by p65.com, please contact us:

If you believe that p65.com has handled your personal data in a manner inconsistent with the Data Privacy Act of 2012 or this Policy, and your complaint has not been satisfactorily resolved through our internal process, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). The NPC is the supervisory authority responsible for enforcing the DPA in the Philippines.

p65.com takes data privacy complaints seriously and will cooperate fully with any NPC investigation. We aim to resolve all privacy-related complaints through direct engagement before formal regulatory escalation is necessary.