ph36 Privacy Policy

1. About This Privacy Policy

This Privacy Policy ("Policy") describes how ph36 ("ph36", "we", "us", "our"), the operator of the online gaming platform accessible at ph36.one and associated mobile applications, collects, uses, stores, shares, and protects the personal data of individuals ("you", "Player", "User") who access or use the ph36 platform.

This Policy is issued in compliance with the Data Privacy Act of 2012 of the Republic of the Philippines (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission ("NPC"). Where ph36 processes data of individuals in the European Economic Area, the General Data Protection Regulation (GDPR) also applies.

This Policy should be read alongside the ph36 Terms & Conditions. By creating a ph36 account or using ph36.one, you acknowledge that you have read and understood this Policy.

2. Data Controller

ph36 is the data controller responsible for the personal data processed in connection with ph36.one and ph36 mobile applications. For all data privacy inquiries, requests, and complaints, please contact ph36 through the channels listed in Section 13 of this Policy.

3. Personal Data We Collect

ph36 collects personal data through several means, including account registration, KYC verification, gameplay activity, payment processing, customer support interactions, and automated technical collection.

ph36 does not collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance (e.g., we do not collect information on religious beliefs, health records, or political affiliations).

4. How ph36 Uses Your Personal Data

ph36 processes your personal data for the following purposes:

• Account management: Creating, operating, and maintaining your ph36 account, including authentication at ph36 login.
• Payment processing: Processing deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, InstaPay, and other Philippine payment channels.
• Regulatory compliance: Satisfying PAGCOR licensing obligations, anti-money-laundering (AML) reporting requirements under the Anti-Money Laundering Act (AMLA), and age verification requirements (21+).
• Responsible gaming: Monitoring gaming activity to identify patterns indicative of problem gambling and to apply player-requested responsible gaming tools such as deposit limits and self-exclusion.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, bonus abuse, account takeover attempts, and other prohibited conduct.
• Customer support: Responding to inquiries, resolving disputes, and administering complaints received via ph36 live chat or email.
• Service improvement: Analysing aggregate gameplay and platform usage data (in anonymised or pseudonymised form) to improve ph36 products and user experience.
• Marketing communications: Sending promotional offers, bonus notifications, and VIP programme updates via SMS or in-platform notification — only where you have not opted out. You may opt out at any time via your account settings or by contacting ph36 support.

5. Legal Basis for Processing

ph36 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to fulfil ph36's obligations under the Terms & Conditions you accepted at account registration (e.g., account management, payment processing, game provision).
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions, AMLA reporting obligations, and NPC data privacy requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your fundamental privacy rights.
• Consent: Processing for direct marketing communications, where your prior consent has been obtained and not subsequently withdrawn.

6. Data Sharing and Disclosure

ph36 does not sell your personal data. ph36 may share your personal data with the following categories of third parties only to the extent strictly necessary:

• Payment processors: GCash (Mynt), Maya (Voyager Innovations), BancNet, and other Philippine payment partners, solely for the purpose of processing your deposit and withdrawal transactions.
• Game software providers: Third-party RNG and live casino game providers who may receive technical identifiers (not full identity data) to facilitate game delivery and RTP certification.
• KYC and identity verification partners: Third-party identity verification service providers engaged to perform digital document verification during account KYC.
• Regulatory authorities: PAGCOR and the Anti-Money Laundering Council (AMLC) as required by applicable Philippine law and ph36's operating licence conditions.
• Law enforcement: Philippine law enforcement authorities where ph36 is legally compelled to disclose data pursuant to a valid court order, subpoena, or lawful demand.
• Professional advisers: Lawyers, auditors, and compliance consultants bound by professional confidentiality obligations, where access to data is strictly necessary.

7. Cookies and Tracking Technologies

ph36.one uses cookies and similar tracking technologies to operate the platform, maintain your login session, detect fraud, analyse usage patterns, and deliver relevant in-platform content.

7.1 Types of Cookies Used

• Strictly necessary cookies: Required for core platform functionality including session management, ph36 login authentication, and security token validation. These cannot be disabled.
• Performance cookies: Collect anonymised data on how players navigate ph36.one to help identify and resolve technical issues and improve page performance.
• Functionality cookies: Remember your preferences such as language settings, responsible gaming tool configurations, and last-played game categories.
• Analytics cookies: Used to understand aggregate player behaviour patterns on the platform, including popular game categories and session length distributions.

You may configure your browser to block or delete cookies. Blocking strictly necessary cookies may impair ph36 platform functionality including the ability to complete ph36 login.

8. Data Retention

ph36 retains your personal data for as long as your account remains active and for such further periods as are required by applicable Philippine law and regulatory obligations. The following general retention guidelines apply:

• Account identity and financial records: minimum five (5) years following account closure, consistent with AMLA record-keeping requirements;
• Gaming activity logs: three (3) years from date of activity, or longer where required for active dispute resolution or regulatory investigation;
• Customer support communications: two (2) years from closure of the support interaction;
• Technical logs (IP addresses, session records): ninety (90) days for routine logs; extended retention where a security incident is under investigation.

Upon expiry of applicable retention periods, ph36 will securely delete or irreversibly anonymise your personal data.

9. Data Security

ph36 implements industry-standard 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 ph36 servers;
• Encrypted storage of sensitive account data including passwords (using bcrypt hashing) and payment credentials;
• Multi-factor authentication available for all ph36 accounts;
• Regular security audits and penetration testing of ph36 platform infrastructure;
• Access controls limiting ph36 staff access to personal data on a strict need-to-know basis;
• Incident response procedures with NPC notification protocols in the event of a personal data breach.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173) and applicable implementing regulations, you have the following rights with respect to your personal data held by ph36:

• Right to be informed: The right to know that your personal data is being collected and the purpose and scope of processing — addressed by this Policy.
• Right of access: The right to request a copy of the personal data ph36 holds about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data in your ph36 account.
• 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 ph36's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes. You may exercise this at any time via your ph36 account settings.
• Right to data portability: The right to receive your personal data in a structured, commonly used format to facilitate transfer to another service where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph if you believe ph36 has violated your data privacy rights.

To exercise any of the above rights, contact ph36 via the details in Section 13. ph36 will respond to all data privacy requests within fifteen (15) business days of receipt of a complete and verified request.

11. Minors and Age Restriction

The ph36 platform is strictly for adults aged 21 and above, consistent with PAGCOR's regulations for online gaming operators serving Filipino players. ph36 does not knowingly collect, process, or retain personal data of individuals under 21 years of age.

If ph36 discovers or is informed that personal data of a person under 21 has been collected — whether through account fraud, misrepresentation of age, or any other means — ph36 will immediately close the account, void any associated transactions, and permanently delete the personal data in question. Any parent or guardian who becomes aware that a minor has accessed ph36 should immediately contact ph36 support.

12. Changes to This Privacy Policy

ph36 reserves the right to amend or update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or ph36's data processing practices. Material changes will be communicated to registered Players via SMS notification to the registered Philippine mobile number at least fourteen (14) days before the changes take effect.

The version of this Policy published on ph36.one at the time of your most recent access governs ph36's data processing practices in relation to your account. Your continued use of the ph36 platform following notification of changes constitutes acknowledgement of the revised Policy.

13. Contact and Data Protection Officer

For all data privacy inquiries, requests to exercise your data subject rights, or complaints regarding ph36's handling of your personal data, please contact ph36 through the following: