Privacy Policy

Introduction

125phdream ("125phdream," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the 125phdream online gaming platform, accessible at https://125phdream.org (the "Platform"). This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations.

This Policy applies to all personal data collected through the 125phdream Platform, including data provided during account registration, gameplay, financial transactions, customer support interactions, and any other use of our services. It applies to all registered players, prospective players, and visitors to the Platform.

125phdream acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for our DPO are provided in Section 14 of this Policy.

Data We Collect

125phdream collects the following categories of personal data from users of the Platform:

2.1 Identity & Contact Data

• Full legal name as it appears on a government-issued identification document
• Date of birth (for age verification — players must be 21 years of age or older)
• Nationality and country of residence
• Residential address, including barangay, city or municipality, province, and postal code
• Email address and Philippine mobile number
• Government-issued identification numbers (e.g., PhilSys ID, passport, driver's licence, SSS, GSIS, TIN) submitted for KYC verification

2.2 Financial Data

• Payment method details, including GCash account numbers, PayMaya account details, bank account information (BPI, BDO, Metrobank, and other Philippine banks), and e-wallet identifiers
• Transaction history, including deposit amounts, withdrawal requests, and dates
• Source of funds documentation where required by anti-money laundering regulations

2.3 Gaming & Activity Data

• Game history, including games played, wagers placed, outcomes, and session durations
• Bonus and promotion usage history
• Responsible gaming tool settings, including deposit limits, session limits, and self-exclusion status
• Customer support interaction records, including chat transcripts and support ticket history

2.4 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type and version
• Unique device identifiers
• Login timestamps and session activity logs
• Cookie and tracking technology data (see Section 7)

How We Collect Data

125phdream collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. This includes technical and device data as described in Section 2.4.
• Third-Party Sources: Data received from payment processors (such as GCash, PayMaya, and Philippine banking partners), identity verification service providers, fraud prevention services, and regulatory databases, where permitted by applicable law.
• Publicly Available Sources: In limited circumstances, data from publicly available sources such as government registries or public records, where relevant to KYC or compliance obligations.

How We Use Your Data

125phdream uses the personal data it collects for the following purposes:

Purpose	Data Categories Used
Account registration and management	Identity, contact, technical data
Age and identity verification (KYC)	Identity, contact, financial data
Processing deposits and withdrawals	Identity, financial, technical data
Providing gaming services and personalisation	Gaming, activity, technical data
Fraud prevention and security monitoring	All categories
Anti-money laundering compliance	Identity, financial, activity data
Responsible gaming monitoring and intervention	Gaming, activity, identity data
Customer support and dispute resolution	Identity, contact, activity data
Marketing and promotional communications (with consent)	Identity, contact, activity data
Platform analytics and improvement	Technical, gaming, activity data
Legal and regulatory compliance	All categories as required

125phdream will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

Legal Basis for Processing

125phdream processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and 125phdream, including account management, payment processing, and the provision of gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including the Anti-Money Laundering Act, PAGCOR licensing requirements, and the Data Privacy Act itself.
• Legitimate Interests: Processing is necessary for the legitimate interests of 125phdream, including fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided such interests are not overridden by your rights and freedoms.
• Consent: Where processing is based on your consent, such as for direct marketing communications, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Disclosure

125phdream does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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 deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged to assist with age verification and anti-money laundering compliance.
• Game Software Providers: Licensed game providers whose software is integrated into the 125phdream Platform, to the extent necessary for the provision of gaming services.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine regulatory authorities, where disclosure is required by law or regulatory obligation.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process.
• Professional Advisers: Legal counsel, auditors, and other professional advisers engaged by 125phdream, subject to professional confidentiality obligations.

Cookies & Tracking Technologies

The 125phdream Platform uses cookies and similar tracking technologies to enhance your user experience, maintain session security, and gather analytics data. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the Platform, including session management, authentication, and security. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences and settings, such as language selection and responsible gaming tool configurations.
• Analytics Cookies: Collect anonymised data about how users interact with the Platform, helping 125phdream improve its services. This data does not identify you personally.
• Security Cookies: Used to detect and prevent fraudulent activity, protect account security, and monitor for suspicious login behaviour.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 125phdream Platform. A full cookie preference centre is accessible via the cookie banner displayed on your first visit to the Platform.

Data Retention

125phdream retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account & KYC Data: Retained for a minimum of five (5) years following account closure, in accordance with anti-money laundering regulations under Republic Act No. 9160.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable Philippine financial regulations.
• Gaming Activity Data: Retained for three (3) years following account closure, or longer where required for dispute resolution or regulatory compliance.
• Customer Support Records: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 125phdream's data disposal procedures.

Data Security

125phdream implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 125phdream Platform
• Encryption of sensitive data at rest, including financial data and government identification numbers
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Multi-factor authentication requirements for administrative access to systems containing personal data
• Regular penetration testing and vulnerability assessments conducted by independent security specialists
• 24/7 security monitoring and intrusion detection systems
• Formal data breach response procedures, including notification to the National Privacy Commission (NPC) within 72 hours of becoming aware of a breach that poses a real risk of serious harm

Your Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 125phdream:

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data 125phdream holds about you, together with information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by 125phdream.
• 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 applicable legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14. 125phdream will respond to all valid requests within thirty (30) days of receipt, in accordance with the Data Privacy Act.

Children's Privacy

The 125phdream Platform is strictly intended for adults aged 21 years and above. 125phdream does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the account registration and KYC process to enforce this requirement.

If 125phdream becomes aware that personal data has been collected from a person under the age of 21 without appropriate parental or guardian consent, such data will be deleted immediately and the associated account will be closed. If you believe that a minor has registered on the Platform, please contact our support team immediately.

International Data Transfers

125phdream primarily processes and stores personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers or partners located outside the Philippines, including game software providers and technology infrastructure partners.

Where such international transfers occur, 125phdream ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012 and the standards prescribed by the National Privacy Commission. 125phdream will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or other lawful basis.

Changes to This Policy

125phdream 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. The date of the most recent revision is displayed at the top of this page.

Where changes are material, 125phdream will provide reasonable advance notice by posting a prominent notice on the Platform and, where practicable, notifying registered players by email. Your continued use of the Platform following the effective date of any amended Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how 125phdream protects your data.

Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 125phdream, please contact our Data Protection Officer:

• Data Protection Officer: 125phdream Privacy Team
• Email: [email protected]
• Support Email: [email protected]
• Office: Manila, Philippines

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data protection rights have not been adequately addressed by 125phdream.