ph36 Privacy Policy

1. Introduction

ph36 ("ph36", "we", "us", "our") operates the online gaming platform accessible at ph36.asia. We act as a personal information controller under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its implementing rules and regulations issued by the National Privacy Commission ("NPC").

This Privacy Policy describes how ph36 collects, uses, stores, shares, and protects personal data provided by or collected about users ("Player", "you", "your") in connection with your use of the ph36 platform, including account registration, deposits and withdrawals, gameplay, customer support interactions, and marketing communications.

By registering an account with ph36 or continuing to use the ph36 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use ph36.

2. Personal Data We Collect

ph36 collects the following categories of personal data:

Identity & Contact Information:

• Full legal name, date of birth, and nationality
• Government-issued identification document number (e.g., Philippine national ID, passport, driver's license)
• Email address, mobile number, and residential address
• Selfie or photograph submitted for facial identity verification

Financial Information:

• GCash or Maya account number linked to your ph36 account
• Bank account details (BPI, BDO, Metrobank) where used for transactions
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment methods
• Wallet balance and bonus balance records

Gaming Activity Data:

• Game sessions, bet history, wagering records, wins, and losses
• Responsible gaming settings and limit configurations
• Self-exclusion status and duration where applicable

Technical & Device Data:

• IP address, device type and model, operating system version, and browser type
• Login timestamps, session duration, and navigation patterns within ph36
• Geolocation data (country and region level) derived from IP address

Communications Data:

• Customer support chat transcripts and email correspondence with ph36
• Survey responses and feedback submitted to ph36
• Marketing preference settings (opt-in/opt-out records)

3. How We Collect Personal Data

ph36 collects personal data through the following means:

• Direct provision: Information you submit when registering an account, completing KYC verification, making deposits or withdrawals, or contacting ph36 support.
• Automated collection: Technical data collected automatically when you access ph36.asia, including through cookies, web beacons, and server log files.
• Third-party sources: Identity verification and fraud screening data received from KYC/AML service providers; payment transaction data from GCash, Maya, BPI, BDO, and other payment processors; and device risk signals from security providers.
• Publicly available sources: Sanctions lists, politically exposed persons (PEP) databases, and adverse media sources consulted as part of our AML compliance obligations.

4. Purposes of Processing

ph36 processes your personal data for the following purposes:

• To verify your identity and age (21+) as required by PAGCOR regulations and Philippine law
• To create and manage your ph36 account and provide access to platform services
• To process deposits, withdrawals, and other financial transactions
• To detect and prevent fraud, money laundering, unauthorized account access, and other illegal or prohibited activities
• To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations, including filing suspicious transaction reports where required by the Anti-Money Laundering Council (AMLC)
• To provide responsible gaming tools and enforce deposit limits, self-exclusion, and cooling-off periods
• To personalize your ph36 experience and recommend games or promotions relevant to your activity
• To send transactional communications (account confirmations, payment receipts, security alerts)
• To send marketing and promotional communications where you have provided consent, and to honor opt-out requests
• To respond to customer support inquiries and resolve disputes
• To analyze platform usage, improve ph36 services, and conduct internal reporting
• To comply with all applicable laws, regulations, and court or regulatory orders

5. Legal Basis for Processing

ph36 processes personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations under the ph36 Terms & Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with KYC/AML laws, PAGCOR regulations, tax reporting requirements, and other applicable Philippine legal obligations.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform analytics, and responsible gaming enforcement, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and optional personalization features, where you have provided explicit consent. You may withdraw consent at any time by updating your communication preferences in your ph36 account settings.

6. Data Sharing & Disclosure

ph36 does not sell your personal data to third parties. We share personal data only in the following circumstances and only to the extent necessary:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, and other payment service providers to facilitate your deposits and withdrawals.
• KYC and identity verification providers: Third-party services engaged to verify the authenticity of identity documents and perform age and sanctions screening.
• Fraud and security service providers: Services that help ph36 detect unauthorized access, suspicious transactions, and platform abuse.
• Game providers: Where technically necessary, limited session and account data may be shared with licensed game software providers to enable gameplay. Game providers are contractually prohibited from using this data for any other purpose.
• Regulatory and law enforcement authorities: The Anti-Money Laundering Council (AMLC), National Privacy Commission (NPC), PAGCOR, and Philippine law enforcement agencies where disclosure is required by law, court order, or regulatory direction.
• Professional advisors: ph36's legal, audit, and compliance advisors, under strict confidentiality obligations.

All third-party service providers engaged by ph36 are contractually required to process personal data only for the specified purpose and to maintain data security standards consistent with or exceeding those required under the DPA.

7. Data Retention

ph36 retains personal data for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with applicable legal obligations. Specific retention periods include:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, as required by AML regulations applicable to online gaming operators in the Philippines.
• Transaction records: Retained for a minimum of five (5) years following the date of each transaction.
• Customer support communications: Retained for two (2) years following the resolution of each inquiry.
• Marketing consent records: Retained for the duration of your account and for three (3) years following account closure or consent withdrawal.

When personal data is no longer required for any lawful purpose, ph36 will securely delete or anonymize it in accordance with industry-standard data disposal practices.

8. Data Security

ph36 implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph36 servers
• Encryption of sensitive data at rest, including identity documents and payment information
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• Multi-factor authentication for ph36 internal systems that handle personal data
• Regular penetration testing and security audits of ph36 infrastructure
• Incident response procedures for detecting and responding to personal data breaches

In the event of a personal data breach that poses a risk to your rights and freedoms, ph36 will notify the National Privacy Commission and affected individuals in accordance with NPC Circular 16-03 and applicable DPA requirements.

9. Cookies & Tracking Technologies

ph36.asia uses cookies and similar tracking technologies to operate the platform, maintain your login session, and improve user experience. The types of cookies used include:

• Essential cookies: Required for the basic functioning of ph36, including session management and security features. These cannot be disabled without impairing platform functionality.
• Analytics cookies: Used to collect anonymized usage data to help ph36 understand how players navigate the platform and identify areas for improvement.
• Preference cookies: Used to remember your display preferences and language settings across sessions.

You may control cookie preferences through your browser settings. Blocking essential cookies may impair your ability to use ph36. ph36 does not use third-party advertising or behavioral tracking cookies.

10. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data processed by ph36:

• Right to be informed: The right to know what personal data ph36 holds about you and how it is processed.
• Right of access: The right to request a copy of the personal data ph36 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure or blocking: The right to request deletion or blocking of personal data that is unlawfully processed or no longer necessary, subject to ph36's legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to damages: The right to be compensated for damages suffered as a result of inaccurate, incomplete, outdated, or unlawfully obtained personal data.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission at privacy.gov.ph if you believe ph36 has violated your data privacy rights.

To exercise any of these rights, contact ph36's Data Protection Officer by sending a written request to [email protected]. ph36 will respond to verified requests within fifteen (15) working days.

11. Children's Privacy

ph36 is strictly an adult online gaming platform. Access is prohibited to individuals under 21 years of age in accordance with PAGCOR regulations and Philippine gambling law. ph36 does not knowingly collect personal data from individuals under the age of 21.

If ph36 discovers that personal data has been collected from a person below the minimum age requirement, such data will be immediately deleted and the associated account will be permanently closed. If you believe a minor has registered with ph36, please contact us immediately at [email protected].

12. Cross-Border Data Transfers

ph36 may transfer personal data to service providers and infrastructure located outside the Philippines. Where such transfers occur, ph36 ensures that the recipient country or organization provides an adequate level of protection consistent with the standards of the Data Privacy Act of 2012, or that appropriate contractual safeguards (such as standard contractual clauses) are in place prior to the transfer.

ph36 will not transfer your personal data to jurisdictions that do not meet applicable data protection standards without your explicit consent, except where required to do so by law.

13. Updates to This Privacy Policy

ph36 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform services. Any material changes will be communicated to registered players via email or an in-platform notification prior to taking effect.

The "Last updated" date at the top of this Privacy Policy will be revised whenever changes are published. Continued use of ph36 following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

14. Contact & Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or ph36's data processing practices, please contact ph36's Data Protection Officer:

Data Protection Officer, ph36
Email: [email protected]
Response time: Within 15 working days for formal privacy requests
Support available: 24/7 via live chat for general account and data queries

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are dissatisfied with ph36's handling of your personal data.