quenph Privacy Policy —
How We Handle Your Personal Data

This Privacy Policy is issued by quenph, the operator of the online gaming platform accessible at quenph.app (the "Platform"). quenph is the data controller responsible for your personal data collected through the Platform, including through account registration, deposits, gameplay, customer support interactions, and any other service we provide to you.

quenph operates under the regulatory authority of the Philippine Amusement and Gaming Corporation (PAGCOR) and in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations as enforced by the National Privacy Commission (NPC) of the Philippines.

quenph collects personal data from you in several ways — directly through information you provide during registration and account operation, automatically through your use of the Platform, and from third-party providers involved in payment processing and fraud prevention.

quenph does not intentionally collect sensitive personal information as defined under the Data Privacy Act — such as biometric data, health information, or political affiliations — unless specifically required and consented to as part of an enhanced KYC process mandated by PAGCOR or AMLA regulations.

quenph processes your personal data only for clearly defined purposes. We do not use your data for undisclosed purposes, and we do not sell personal data to any third party for commercial gain.

• Account management: Creating, maintaining, and securing your quenph Account, including authentication and password recovery.
• Service delivery: Enabling access to casino games, sports betting, bingo, and all other quenph Platform features.
• Payment processing: Processing deposits via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted channels; processing approved withdrawals back to your verified payment method.
• Identity verification (KYC): Verifying your identity and age in compliance with PAGCOR regulations before processing first withdrawals.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other prohibited conduct on the Platform.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problematic gambling behaviour; facilitating deposit limits, session controls, cooling-off periods, and self-exclusion requests.
• Regulatory compliance: Meeting obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the quenph user experience, game curation, and payment flows.
• Marketing communications (consent-based only): Sending promotional offers, bonus notifications, and event updates to players who have explicitly opted in to such communications.

Under the Data Privacy Act of 2012, quenph processes your personal data on the following lawful bases:

• Contractual necessity: Processing required to provide the quenph service you have contracted for — including account management, game access, and payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, AMLA obligations, KYC mandates, and other applicable Philippine legal obligations.
• Legitimate interests: Processing necessary for quenph's legitimate business interests — including fraud prevention, platform security, and abuse prevention — where those interests are not overridden by your rights.
• Consent: Processing for optional purposes such as marketing communications, for which quenph obtains your explicit, freely given consent at the time of collection. Consent may be withdrawn at any time without prejudice to your Account.

quenph shares personal data only where there is a lawful basis to do so and only to the extent necessary for the stated purpose. We do not sell, rent, or trade your personal data. Data sharing by quenph is limited to the following categories of recipients:

5.1 Payment Processors

quenph shares relevant financial data — including your GCash or PayMaya mobile number and transaction amounts — with payment processing partners solely for the purpose of completing your deposit or withdrawal request. Payment processors operating with quenph are contractually bound to process your data only as instructed and to maintain appropriate security standards.

5.2 Game Providers

quenph shares a pseudonymised player identifier (not your name or contact details) with licensed game providers — including JILI, Pragmatic Play, PG Soft, and others — to enable gameplay, record game outcomes, and facilitate live dealer sessions. Game providers do not receive your payment data or KYC documents.

5.3 Regulatory and Legal Authorities

quenph discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or any other Philippine government authority when required by law, regulation, court order, or lawful government request. Such disclosures are made only to the extent required and are logged internally.

5.4 Identity Verification Providers

quenph may use third-party KYC technology providers to assist with identity document verification. These providers process your ID documents only for the purpose of verification and are contractually prohibited from retaining or repurposing your data.

5.5 Fraud Prevention Services

quenph may share technical data — such as device fingerprints and IP addresses — with fraud detection service providers to identify and prevent fraudulent account activity. No financial or identity documents are shared with fraud detection providers.

quenph uses cookies and similar tracking technologies to operate the Platform, remember your session, analyse usage patterns, and — with your consent — deliver relevant promotional content. A cookie is a small text file stored on your device by your browser.

6.1 Essential Cookies

These cookies are strictly necessary to operate the quenph Platform — maintaining your login session, remembering your language preference, and ensuring secure navigation. You cannot opt out of essential cookies without affecting Platform functionality.

6.2 Analytics Cookies

quenph uses first-party analytics to understand how the Platform is used in aggregate — which game categories are most visited, where navigation drop-off occurs, and how payment flows perform. Analytics data is aggregated and does not identify individual players.

6.3 Preference Cookies

These cookies remember your Platform preferences — such as your last-visited game lobby section or display settings — to personalise your experience on return visits.

You may manage cookie preferences through your browser settings at any time. Restricting cookies may affect some Platform features, particularly session persistence and personalisation functions.

quenph retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, to comply with legal and regulatory obligations, and to resolve any disputes or enforce our agreements. Retention periods by data category are as follows:

Upon expiry of the applicable retention period, quenph securely deletes or anonymises personal data so that it can no longer be attributed to any individual.

quenph implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and the quenph Platform.
• Encrypted data storage for sensitive personal data, including KYC documents and payment identifiers.
• Role-based access controls restricting internal access to personal data to staff whose role genuinely requires it.
• Two-factor authentication for both player accounts (opt-in) and all internal quenph staff accounts accessing personal data systems.
• Regular security audits and penetration testing by qualified third-party security firms.
• Incident response procedures aligned with NPC notification requirements under the Data Privacy Act — including mandatory notification to affected players and the NPC within 72 hours of discovering a breach affecting sensitive personal information.

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data processed by quenph. quenph will respond to verified requests within 30 calendar days of receipt.

To exercise any of these rights, submit a written request to quenph's Data Protection Officer at the contact details provided in Section 13. quenph may require identity verification before processing your request to ensure data security.

The quenph Platform is strictly intended for use by individuals who are 21 years of age or older, in compliance with PAGCOR's age requirements for online gaming in the Philippines. quenph does not knowingly collect personal data from individuals under 21 years of age.

During account registration, quenph collects date of birth information and verifies age through KYC documentation submitted before first withdrawal processing. Where quenph becomes aware that an account has been registered by a person under 21, the account is immediately suspended, all data associated with the account is reviewed, and any balance is returned to the source payment method in accordance with PAGCOR protocols.

quenph's primary operations and data infrastructure are based in the Philippines. However, some of quenph's service providers — including game developers, security service providers, and technical infrastructure partners — may process or host data outside the Philippines.

Where personal data is transferred outside the Philippines, quenph ensures that appropriate safeguards are in place consistent with the requirements of the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers. Such safeguards include contractual obligations on recipient parties to maintain data protection standards no less protective than those applicable under Philippine law.

quenph does not transfer KYC identity documents to entities located outside the Philippines except where required by applicable law or where the relevant service provider is a PAGCOR-approved identity verification partner operating under equivalent data protection standards.

quenph may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or Platform features. Where changes are material — affecting how we use your personal data, who we share it with, or your rights — quenph will notify you in advance via:

• An email notification to your registered address; and/or
• A prominent notice displayed upon your next login to the quenph Platform.

The effective date at the top of this page reflects the date of the most recent revision. The current version of this Privacy Policy is always available at quenph.app/privacy-policy. Your continued use of the Platform after the effective date of any update constitutes your acknowledgement of the revised Policy. Where updates require fresh consent (e.g., a new category of processing), quenph will seek that consent separately before commencing the relevant processing.

For any question, concern, or formal request relating to this Privacy Policy or the handling of your personal data by quenph, please contact our Data Protection Officer (DPO):

quenph is committed to resolving all privacy concerns raised by Filipino players in good faith and within the timeframes required under the Data Privacy Act of 2012. If you are not satisfied with quenph's response to your privacy concern, you have the right to escalate the matter to the National Privacy Commission (NPC).