ph363 Privacy Policy

1. Introduction

ph363 ("ph363", "we", "us", or "our") is committed to protecting the privacy and personal data of every player who uses the ph363 online gaming platform (the "Platform"). This Privacy Policy ("Policy") describes how we collect, use, disclose, store, and protect your personal information when you access or use the Platform, including through our website at ph363.one and any associated mobile-optimised interfaces.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering an account or using the ph363 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with the ph363 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Personal Data We Collect

ph363 collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., Philippine passport number, driver's licence number, UMID number).
• Contact Data: Residential address (including city, province, and postal code), email address, and mobile phone number.
• Account Data: Username, encrypted password, account preferences, and communication preferences.
• Financial Data: GCash account details, PayMaya/Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details, transaction history, deposit and withdrawal records, and account balance information.
• Gaming Data: Game history, wagering activity, session duration, game preferences, bonus usage, and responsible gaming tool settings.
• Technical Data: IP address, browser type and version, device type and operating system, time zone, and pages visited on the Platform.
• Verification Data: Copies of government-issued identification documents and proof of address submitted during Know Your Customer (KYC) verification.
• Communications Data: Records of your correspondence with ph363 customer support, including live chat transcripts and email exchanges.

We do not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect information relating to your health, political opinions, or religious beliefs.

3. How We Collect Your Data

ph363 collects your personal data through the following means:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs. See Section 8 for more information on cookies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering screening services; and payment data from payment processors (GCash, PayMaya/Maya, and partner banks).
• Regulatory Sources: Data received from PAGCOR or other regulatory authorities in connection with our licensing obligations, including exclusion register data.

4. How We Use Your Personal Data

ph363 uses your personal data for the following purposes:

• Account Management: To register and maintain your ph363 account, verify your identity, and manage your account settings and preferences.
• Service Delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and deliver the core gaming services of the ph363 Platform.
• Legal and Regulatory Compliance: To comply with our obligations under Philippine law, including the Data Privacy Act, Anti-Money Laundering Act, and PAGCOR licensing requirements. This includes verifying your age (21+), conducting KYC checks, and reporting suspicious transactions.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit and loss limits, process self-exclusion requests, and provide responsible gaming support.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and security of the ph363 Platform.

5. Legal Basis for Processing

ph363 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform our contract with you (i.e., the ph363 Terms & Conditions), including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, anti-money laundering obligations, and age verification requirements.
• Legitimate Interests: Processing necessary for ph363's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

ph363 does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya/Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and anti-money laundering screening services engaged to verify player identities and comply with regulatory requirements.
• Game Software Providers: Licensed game developers and live dealer studios whose games are hosted on the ph363 Platform, to the extent necessary to deliver gaming services.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or regulatory obligation.
• Law Enforcement: Philippine law enforcement agencies, where required by a valid court order, subpoena, or other legal process.
• Professional Advisers: Legal counsel, auditors, and other professional advisers engaged by ph363, subject to confidentiality obligations.

All third parties with whom ph363 shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and ph363's data processing standards.

7. Data Retention

ph363 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and anti-money laundering obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure.
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period thereafter for record-keeping purposes.
• Technical and Log Data: Retained for up to twelve (12) months, unless required for longer periods for security or legal purposes.

Upon expiry of the applicable retention period, ph363 will securely delete or anonymise your personal data.

8. Cookies and Tracking Technologies

ph363 uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device when you visit the ph363 website.

We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Performance Cookies: Used to collect anonymised information about how players use the Platform, helping us identify and fix issues and improve performance.
• Functionality Cookies: Used to remember your preferences, such as language settings and game preferences, to provide a more personalised experience.
• Analytics Cookies: Used to understand aggregate player behaviour and improve the ph363 Platform's features and content.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph363 Platform. For more information on managing cookies, refer to your browser's help documentation.

9. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph363:

• Right to Be Informed: The right to be informed of how your personal data is collected, used, and processed by ph363.
• Right of Access: The right to request a copy of the personal data ph363 holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to ph363's legal and regulatory 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 format and to transmit it to another data controller, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact ph363's Data Protection Officer using the contact details in Section 14. We will respond to all verified requests within thirty (30) days, in accordance with NPC guidelines.

10. Data Security

ph363 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the ph363 Platform;
• Encryption of sensitive data at rest, including financial information and identification documents;
• Access controls limiting personal data access to authorised ph363 personnel on a strict need-to-know basis;
• Regular security assessments and penetration testing of the Platform infrastructure;
• Staff training on data privacy obligations and secure data handling practices;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph363 will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

While ph363 takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your ph363 account credentials.

11. Children's Privacy

The ph363 Platform is strictly intended for persons aged 21 years and above, in accordance with Philippine gaming regulations. ph363 does not knowingly collect personal data from persons under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account and delete the data.

If you believe that a person under 21 has registered an account on the ph363 Platform, please contact us immediately at [email protected].

12. Third-Party Links

The ph363 Platform may contain links to third-party websites or services for informational purposes. ph363 is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Policy applies solely to the ph363 Platform.

13. Updates to This Policy

ph363 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The updated Policy will be posted on this page with a revised "Last Updated" date. Where changes are material, ph363 will notify registered players by email.

Your continued use of the ph363 Platform following the posting of an updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or ph363's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 within your ph363 account dashboard
• Response Time: We aim to respond to all data privacy requests within 30 days

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have not been adequately addressed by ph363.