ph361 Privacy Policy

ph361 operates the online gaming platform accessible at ph361.club (the "Platform"). For the purposes of this Privacy Policy, ph361 is the data controller responsible for the personal data of registered players and visitors to the Platform.

ph361 is committed to protecting the privacy and personal data of all individuals who interact with our Platform, in accordance with the Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines and its implementing rules and regulations issued by the National Privacy Commission (NPC).

If you have any questions about this Privacy Policy or about how ph361 handles your personal data, please contact our Data Protection Officer using the contact details provided in Section 13 of this policy.

ph361 collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we may collect include:

ph361 does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless strictly required for regulatory compliance, in which case such collection will be subject to additional safeguards and your explicit consent where required.

ph361 collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs. Please refer to Section 7 for more information on our use of cookies.
• Third-Party Sources: Identity and fraud-screening data received from KYC verification service providers, payment processors (such as GCash and Maya), and financial institutions, where you have authorised such sharing.
• Regulatory Sources: Information received from PAGCOR or other regulatory authorities in connection with licensing, compliance, or investigation requirements.

ph361 will always inform you at the point of collection what data is being collected and for what purpose, to the extent required by applicable law.

ph361 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your ph361 account, process deposits and withdrawals, and provide gaming services.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including PAGCOR licensing requirements, anti-money laundering (AML) obligations under Republic Act No. 9160 (as amended), and tax reporting requirements.
• Legitimate Interests: Processing is necessary for ph361's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided such interests are not overridden by your rights and interests.
• Consent: Where ph361 relies on your consent as the legal basis for processing (for example, for certain marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ph361 uses the personal data we collect for the following purposes:

• To create, verify, and manage your ph361 player account.
• To process deposits and withdrawals through your chosen payment method (GCash, Maya, bank transfer, or debit card).
• To verify your identity and age (21+) in compliance with PAGCOR regulations and applicable Philippine law.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited conduct on the Platform.
• To monitor your gaming activity for responsible gaming purposes, including identifying patterns that may indicate problem gambling behaviour.
• To communicate with you about your account, transactions, promotions, and important platform updates.
• To provide customer support and resolve disputes.
• To comply with our legal and regulatory obligations, including reporting to PAGCOR and other competent authorities where required.
• To improve the ph361 Platform through analytics and user research.
• To send you marketing communications about ph361 promotions and offers, where you have provided your consent or where we have a legitimate interest in doing so and you have not opted out.

ph361 will not use your personal data for any purpose that is incompatible with the purposes described in this Privacy Policy without first obtaining your consent or establishing another lawful basis for such use.

ph361 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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:

• Payment Processors: GCash, PayMaya / Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud Prevention & Security Providers: Service providers who assist ph361 in detecting and preventing fraudulent activity on the Platform.
• IT & Hosting Providers: Cloud infrastructure and hosting providers who store and process Platform data on ph361's behalf, subject to strict data processing agreements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulation.
• Legal & Professional Advisers: Lawyers, auditors, and other professional advisers engaged by ph361, subject to professional confidentiality obligations.

All third parties with whom ph361 shares personal data are required to handle such data in accordance with applicable data protection laws and ph361's data protection standards. ph361 remains responsible for ensuring that such third parties provide adequate protection for your personal data.

ph361 uses cookies and similar tracking technologies to enhance your experience on the Platform, to ensure the Platform functions correctly, and to gather analytics data that helps us improve our services.

The types of cookies used on the ph361 Platform include:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences (such as language settings and display preferences) to provide a more personalised experience.
• Analytics Cookies: Collect anonymised data about how visitors use the Platform, including pages visited, time spent, and navigation paths. This data helps ph361 improve the Platform.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and IP reputation monitoring.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph361 Platform. For more information on managing cookies, refer to your browser's help documentation.

ph361 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML obligations.
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and related regulations.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Gaming History: Retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes.
• Support Communications: Retained for two (2) years from the date of the last communication, for quality assurance and dispute resolution purposes.
• Technical & Usage Data: Retained for up to twelve (12) months for security and analytics purposes.

Upon expiry of the applicable retention period, ph361 will securely delete or anonymise your personal data in accordance with our data disposal procedures.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by ph361:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data ph361 holds about you, together with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data ph361 holds about you.
• 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 ph361's legal 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 ph361's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that ph361 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact ph361's Data Protection Officer using the contact details in Section 13. ph361 will respond to all valid data subject requests within the timeframes prescribed by applicable law. We may need to verify your identity before processing your request.

ph361 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• AES-256 encryption for data stored at rest on ph361 servers.
• TLS 1.3 encryption for all data transmitted between your device and the ph361 Platform.
• Multi-factor authentication (MFA) options for player accounts.
• Regular security audits and penetration testing of the Platform infrastructure.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Continuous monitoring of Platform systems for suspicious activity and potential security incidents.
• A documented data breach response procedure, including notification to the National Privacy Commission and affected data subjects within the timeframes required by law.

While ph361 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your ph361 account credentials. Please refer to Section 5 of our Terms & Conditions for your account security obligations.

The ph361 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with the minimum legal age for casino-style gambling in the Philippines under applicable PAGCOR regulations.

ph361 does not knowingly collect personal data from individuals under the age of 21. If ph361 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the ph361 Platform or provided personal data to ph361, please contact our support team immediately so that we can investigate and take appropriate action.

ph361 employs age verification procedures at the point of registration and reserves the right to request documentary proof of age at any time. Providing false information about your age constitutes a material breach of our Terms & Conditions.

ph361 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, ph361 will notify registered players via email or an on-Platform notification prior to the changes taking effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how ph361 protects your personal data.

Your continued use of the ph361 Platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with any amendment, you may request account closure in accordance with Section 12 of our Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or to ph361's handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 through the ph361 Platform
• Response Time: ph361 aims to respond to all privacy-related enquiries within five (5) business days.

If you are not satisfied with ph361's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph (please visit the NPC website directly — ph361 does not link to external sites).