p444 Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") describes how p444 ("p444," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who access or use the p444 online gaming platform at p444.club (the "Platform").

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines. It applies to all personal data processed by p444 in connection with the Platform, regardless of the medium or format in which that data is held.

2. Data Controller

For the purposes of the DPA and this Policy, p444 acts as the personal information controller ("PIC") in respect of the personal data it collects and processes in connection with the Platform. p444 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

p444 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with the DPA and this Policy. Contact details for the DPO are set out in Section 15 of this Policy.

3. Personal Data We Collect

p444 collects the following categories of personal data in connection with the Platform:

4. How We Collect Your Data

p444 collects personal data through the following means:

4.1 Direct Collection

• Account registration and profile completion forms.
• KYC verification document submissions.
• Deposit and withdrawal transaction forms.
• Responsible gaming tool requests (deposit limits, self-exclusion).
• Customer support enquiries submitted via live chat or email.
• Promotional opt-in forms and survey responses.

4.2 Automated Collection

• Cookies, web beacons, and similar tracking technologies placed on your device when you access the Platform (see Section 8).
• Server logs that automatically record technical data such as IP address, browser type, and pages accessed.
• Session monitoring tools that record gameplay activity for security and fairness purposes.

4.3 Third-Party Sources

• Identity verification and KYC service providers who confirm the authenticity of documents you submit.
• Payment processors (e.g., GCash, PayMaya, partner banks) who provide transaction confirmation data.
• Fraud prevention and anti-money laundering screening services.

5. Legal Basis for Processing

p444 processes your personal data on the following legal bases under the DPA:

• Consent: Where you have given clear, informed, and freely given consent — for example, when opting in to receive promotional communications from p444.
• Contractual Necessity: Where processing is necessary to perform the contract between you and p444 — including account creation, game operation, payment processing, and customer support.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to p444 — including anti-money laundering (AMLA) reporting, KYC requirements, and regulatory disclosures to PAGCOR-aligned authorities.
• Legitimate Interests: Where processing is necessary for p444's legitimate interests — including fraud prevention, Platform security, responsible gaming monitoring, and service improvement — provided those interests are not overridden by your rights and freedoms.

6. How We Use Your Personal Data

p444 uses the personal data it collects for the following purposes:

• To create, verify, and manage your p444 account.
• To process deposits, withdrawals, and other financial transactions on the Platform.
• To conduct KYC and identity verification in compliance with Philippine regulatory requirements.
• To operate, maintain, and improve the p444 Platform and its features.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity.
• To enforce the p444 Terms & Conditions and other applicable policies.
• To provide customer support and respond to your enquiries.
• To send you transactional communications — such as deposit confirmations, withdrawal notifications, and security alerts — that are necessary for the operation of your account.
• To send you promotional communications about p444 offers and events, where you have consented to receive such communications.
• To monitor gaming activity for responsible gaming purposes and to apply player protection measures where appropriate.
• To comply with applicable Philippine laws, regulations, and court orders.
• To conduct analytics and research to understand how the Platform is used and to improve the player experience.

7. Sharing Your Personal Data

p444 does not sell, rent, or trade 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:

7.1 Service Providers

p444 engages trusted third-party service providers to assist in operating the Platform. These include payment processors (GCash, PayMaya, partner banks), KYC and identity verification providers, cloud hosting and infrastructure providers, customer support platform providers, and analytics service providers. All service providers are contractually bound to process personal data only on p444's instructions and in accordance with the DPA.

7.2 Regulatory and Law Enforcement Authorities

p444 may disclose personal data to Philippine government agencies, regulatory bodies, law enforcement authorities, or courts where required to do so by law, court order, or regulatory direction — including disclosures required under the Anti-Money Laundering Act (AMLA) and its amendments.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of p444's business, personal data held by p444 may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Policy that result from it.

8. Cookies & Tracking Technologies

p444 uses cookies and similar tracking technologies to operate and improve the Platform, to remember your preferences, and to analyse how the Platform is used. The following types of cookies may be placed on your device:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform — such as pages visited and features used — to help p444 improve the player experience.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the p444 Platform. p444 does not use cookies to serve third-party advertising.

9. Data Retention

p444 retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AMLA record-keeping requirements.
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Gaming Activity Data: Retained for a minimum of three (3) years from the date of the relevant gaming session.
• Customer Support Records: Retained for 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.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with p444's data disposal procedures.

10. Data Security

p444 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• TLS (Transport Layer Security) encryption for all data transmitted between your device and the p444 Platform.
• Encryption of sensitive data at rest using industry-standard algorithms.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Staff training on data protection obligations and security best practices.

While p444 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your p444 account credentials. If you suspect that your account has been compromised, please contact p444 support immediately.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by p444:

• 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 obtain a copy of the personal data p444 holds about you and information about how it is processed.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or updated.
• 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 p444's legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe that p444 has processed your personal data in violation of the DPA.

To exercise any of these rights, please contact p444's Data Protection Officer using the contact details in Section 15. p444 will respond to all data subject requests within thirty (30) days of receipt, in accordance with the DPA and NPC regulations.

12. Children & Minors

The p444 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling laws. p444 does not knowingly collect personal data from individuals under the age of 21.

If p444 becomes aware that personal data has been collected from an individual under 21 years of age, that account will be immediately closed, all associated data will be deleted, and any funds will be handled in accordance with applicable law. If you believe that a minor has registered an account on the p444 Platform, please contact our support team immediately.

13. Cross-Border Data Transfers

Some of p444's service providers — including cloud infrastructure and technology partners — may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to the Philippines, p444 will ensure that appropriate safeguards are in place, such as contractual clauses approved by the NPC or equivalent data protection agreements, to protect your personal data in accordance with the DPA.

p444 will not transfer your personal data to a foreign jurisdiction unless it has taken all reasonable steps to ensure that your data will be afforded the same level of protection as it receives under Philippine law.

14. Changes to This Privacy Policy

p444 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. When material changes are made, p444 will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The updated Policy will be published on this page with a revised "Last Updated" date. Your continued use of the p444 Platform following the publication of an updated Policy constitutes your acceptance of the changes. We encourage you to review this page periodically to stay informed about how p444 protects your personal data.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by p444, please contact our Data Protection Officer:

• Data Protection Officer, p444
• Email: [email protected]
• Support Email: [email protected]
• Live Chat: Available daily, 8:00 AM – 12:00 MN (GMT+8), via the p444 Platform.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data subject rights have been violated. The NPC can be reached at [email protected] (plain text — not a link).