Privacy Policy for 36php Casino

1 Introduction

36php ("36php," "we," "us," or "our") operates the online gaming platform accessible at 36php.net (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered players, visitors, and prospective users ("you" or "data subject").

This Privacy Policy ("Policy") describes how 36php collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform. This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines ("NPC").

By registering an account on the 36php Platform or by continuing to use the Platform, you acknowledge that you have read, understood, and consent to the collection and processing of your personal data as described in this Policy. If you do not agree with this Policy, please discontinue your use of the Platform immediately.

2 Personal Data We Collect

36php collects the following categories of personal data from players and Platform users:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., Philippine passport number, SSS/GSIS number, driver's license number, PhilSys ID number).
• Contact Data: Philippine mobile number, email address, and residential address (including barangay, city/municipality, province, and ZIP code).
• Account Data: Username, encrypted password, account registration date, account status, and player preferences.
• Financial Data: GCash account number, Maya account number, bank account details (bank name, account number, account name), transaction history, deposit and withdrawal records, and account balance information.
• Gaming Data: Game history, wagering records, win/loss data, session duration, game preferences, and bonus usage history.
• KYC Verification Data: Copies of government-issued identification documents, selfie photographs submitted for identity verification, and proof of address documents.
• Technical Data: IP address, device type, operating system, browser type and version, device identifiers, and geolocation data (country/region level).
• Usage Data: Pages visited on the Platform, features used, links clicked, session timestamps, and referral source data.
• Communications Data: Records of your communications with 36php customer support, including chat logs, email correspondence, and support ticket history.

36php does not intentionally collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) unless specifically required by law or regulatory obligation.

3 How We Collect Your Data

36php collects your personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically through cookies, web beacons, log files, and similar tracking technologies when you access and use the Platform.
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud and AML screening services; payment data from GCash, Maya, and banking partners in connection with transaction processing.
• Regulatory Sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations.

4 How We Use Your Personal Data

36php processes your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 36php player account, including authentication and account security.
• Service Delivery: To provide you with access to the games, features, and services available on the 36php Platform.
• Payment Processing: To process deposits, withdrawals, and other financial transactions through your chosen payment method.
• KYC & Identity Verification: To verify your identity and age (21+) as required by PAGCOR regulations and Philippine law.
• AML Compliance: To monitor transactions and player activity for suspicious patterns in compliance with Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• Responsible Gaming: To implement and manage responsible gaming tools such as deposit limits, self-exclusion, and session reminders, and to identify players who may be at risk of problem gambling.
• Customer Support: To respond to your inquiries, complaints, and support requests.
• Marketing & Promotions: 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 analyze usage patterns, conduct research, and improve the features, performance, and security of the 36php Platform.
• Legal Compliance: To comply with applicable Philippine laws, PAGCOR regulations, court orders, and lawful requests from government authorities.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the Platform.

5 Legal Basis for Processing

36php processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and 36php (i.e., the Terms and Conditions governing your use of the Platform), including account management, game access, and payment processing.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AML obligations under RA 9160, and tax reporting requirements.
• Legitimate Interests: Processing is necessary for the legitimate interests of 36php, including fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

36php 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, Maya, and Philippine banking partners, for the purpose of processing your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services used to conduct KYC checks as required by PAGCOR regulations.
• AML & Fraud Prevention Services: Third-party screening services used to detect and prevent money laundering, fraud, and other prohibited activities.
• Game Software Providers: Licensed game developers and providers whose games are available on the 36php Platform, to the extent necessary for game functionality and audit purposes.
• IT & Cloud Service Providers: Technology partners who provide hosting, data storage, and platform infrastructure services, subject to strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory directive.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors engaged by 36php, subject to professional confidentiality obligations.

Any third party with whom 36php shares your personal data is required to handle such data in accordance with applicable Philippine data protection laws and is prohibited from using your data for any purpose other than the specific purpose for which it was shared.

7 Cookies & Tracking Technologies

36php uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and improve your experience on the Platform.

36php uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts on the Platform.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 36php Platform. For more information on managing cookies, refer to your browser's help documentation.

8 Data Retention

36php retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with 36php, and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Financial & Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine AML regulations (RA 9160) and tax laws.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Technical & Usage Data: Retained for up to twelve (12) months from collection, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, 36php will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless retention is required by a specific legal obligation or ongoing legal proceedings.

9 Data Security

36php implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and 36php servers is encrypted using 256-bit SSL/TLS technology. Sensitive data stored in our databases, including passwords and financial information, is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to authorized 36php personnel and service providers on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data privacy training.
• Two-Factor Authentication: 36php supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Regular Security Audits: The 36php Platform undergoes regular security assessments, penetration testing, and vulnerability scans conducted by qualified security professionals.
• Incident Response: 36php maintains a data breach response plan. In the event of a personal data breach that poses a real risk to your rights and freedoms, 36php will notify the National Privacy Commission and affected data subjects within the timeframes prescribed by the DPA and NPC regulations.

While 36php takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying 36php immediately if you suspect unauthorized access to your account.

10 Your Data Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 36php:

• Right to Be Informed: The right to be informed of how your personal data is collected, used, stored, and shared, as described in this Policy.
• Right of Access: The right to request a copy of the personal data that 36php holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data held by 36php.
• 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 36php's legal retention obligations.
• Right to Data Portability: The right to receive a copy of 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 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 Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that 36php has violated your data privacy rights.

To exercise any of the above rights, please contact 36php's Data Protection Officer at [email protected]. 36php will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. We may require you to verify your identity before processing your request.

11 Children's Privacy

The 36php Platform is strictly intended for individuals who are at least 21 years of age, as required by Philippine law and PAGCOR regulations. 36php does not knowingly collect personal data from individuals under the age of 21.

If 36php becomes aware that personal data has been collected from an individual under 21 years of age, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the 36php Platform, please contact us immediately at [email protected].

12 Updates to This Privacy Policy

36php reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made to this Policy, 36php will notify registered players via email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the 36php Platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically to stay informed about how 36php protects your personal data.

13 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 36php, please contact our Data Protection Officer:

Email: [email protected]

36php aims to respond to all data privacy inquiries within fifteen (15) business days. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through its official channels.