ph36 Privacy Policy

This Privacy Policy ("Policy") describes how ph36 ("ph36," "we," "us," or "our") collects, uses, stores, shares, and protects personal information obtained from users ("you," "your," or "Player") of the ph36 online gaming platform, including the website located at ph36.app and any associated mobile applications or services (collectively, the "Platform").

By accessing or using the ph36 Platform, creating an account, or providing any personal information to us, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Policy, you must immediately cease using the Platform and refrain from providing any personal information to ph36.

This Privacy Policy should be read in conjunction with ph36's Terms and Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of the Platform. In the event of any conflict between this Policy and other documents, this Privacy Policy shall prevail with respect to matters concerning personal data and privacy.

ph36 collects various types of personal information to provide, maintain, and improve our services. The information we collect falls into the following categories:

2.1 Information You Provide Directly

When you register for a ph36 account or use our services, you voluntarily provide us with personal information, including:

• Account Registration Information: Full name, date of birth, email address, phone number, residential address, username, and password;
• Identity Verification Documents: Government-issued identification such as Philippine National ID, passport, driver's license, or other acceptable proof of identity and age;
• Financial Information: Payment method details including bank account information, GCash or PayMaya account details, credit/debit card numbers, and transaction history;
• Communication Data: Information you provide when contacting customer support, including chat transcripts, emails, and any attachments or documents you submit;
• Responsible Gaming Preferences: Deposit limits, loss limits, session time preferences, and self-exclusion requests.

2.2 Information Collected Automatically

When you access or use the ph36 Platform, we automatically collect certain technical and usage information, including:

• Device Information: Device type, operating system, browser type and version, unique device identifiers, mobile network information;
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, click patterns, and navigation paths;
• Location Data: IP address, geographic location (country, region, city), and time zone;
• Log Data: Access times, error logs, system activity, and hardware settings.

2.3 Information from Third Parties

ph36 may receive information about you from third-party sources, including:

• Payment processors and financial institutions for transaction verification and fraud prevention;
• Identity verification services for age and identity confirmation;
• Marketing partners and affiliates (only if you have consented to such sharing);
• Publicly available sources and databases for compliance and regulatory purposes.

ph36 uses the personal information we collect for the following purposes:

3.1 Providing and Managing Our Services

• Creating and managing your ph36 account;
• Processing deposits, withdrawals, and other financial transactions;
• Verifying your identity and age in compliance with regulatory requirements;
• Providing access to games, promotions, and other Platform features;
• Delivering customer support and responding to your inquiries.

3.2 Security and Fraud Prevention

• Detecting, investigating, and preventing fraudulent transactions, cheating, and other prohibited activities;
• Monitoring for suspicious account activity and unauthorized access;
• Complying with anti-money laundering (AML) and Know Your Customer (KYC) obligations;
• Protecting the integrity and security of the ph36 Platform.

3.3 Legal and Regulatory Compliance

• Complying with applicable Philippine laws, regulations, and licensing requirements;
• Responding to lawful requests from government authorities and law enforcement agencies;
• Enforcing our Terms and Conditions and other policies;
• Maintaining records as required by applicable law.

3.4 Improving Our Platform

• Analyzing usage patterns to improve the functionality and user experience of the Platform;
• Conducting research and development to introduce new features and services;
• Personalizing your gaming experience based on your preferences and activity.

3.5 Marketing and Communications

• Sending you promotional offers, bonuses, and updates about ph36 services — only where you have provided your consent;
• Delivering transactional communications such as deposit confirmations, withdrawal notifications, and account alerts;
• Conducting surveys and gathering feedback to improve our services.

ph36 processes your personal information on the following legal grounds in accordance with applicable data protection laws, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173):

• Contractual Necessity: Processing is necessary to perform our contract with you, including providing gaming services, processing transactions, and managing your account;
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including AML, KYC, and gaming licensing requirements;
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, and improving our services, provided these interests are not overridden by your rights and interests;
• Consent: Where required by law, we will obtain your explicit consent before processing your personal information, particularly for marketing communications and certain types of data sharing.

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, please contact our Customer Support team or update your account preferences.

ph36 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information with the following categories of recipients only as described in this Policy:

5.1 Service Providers

We engage trusted third-party service providers to assist in operating the ph36 Platform, including payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank partner services), identity verification providers, cloud hosting services, customer support platforms, and analytics providers. These service providers are contractually bound to process your data only on our instructions and in accordance with this Privacy Policy.

5.2 Regulatory and Law Enforcement Authorities

ph36 may disclose your personal information to government agencies, regulatory bodies, law enforcement authorities, or other public authorities where required or permitted by applicable law, including in response to lawful requests, court orders, or to comply with our regulatory obligations under Philippine gaming and financial regulations.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ph36's business assets, your personal information may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and any changes to this Privacy Policy that may result.

5.4 With Your Consent

We may share your personal information with other third parties where you have provided your explicit consent to such sharing. You may withdraw this consent at any time by contacting our Customer Support team.

ph36 takes the security of your personal information seriously and implements a comprehensive range of technical and organizational measures to protect your data against unauthorized access, loss, destruction, or alteration. Our security measures include:

• SSL/TLS Encryption: All data transmitted between your device and the ph36 Platform is encrypted using industry-standard Secure Socket Layer (SSL) and Transport Layer Security (TLS) protocols;
• Data Encryption at Rest: Sensitive personal and financial information stored in our systems is encrypted using AES-256 encryption;
• Access Controls: Strict role-based access controls ensure that only authorized ph36 personnel can access personal data, and only to the extent necessary for their job functions;
• Two-Factor Authentication: ph36 supports and encourages the use of two-factor authentication (2FA) to protect your account from unauthorized access;
• Regular Security Audits: Our systems and security practices are regularly audited by independent third-party security experts to identify and address vulnerabilities;
• Incident Response: ph36 maintains a comprehensive data breach response plan and will notify affected users and relevant authorities in the event of a security incident as required by law.

ph36 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. A cookie is a small text file placed on your device when you visit our Platform.

We use the following types of cookies:

• Essential Cookies: Strictly necessary for the Platform to function correctly. These cookies enable core features such as account login, session management, and security. They cannot be disabled without affecting Platform functionality;
• Performance Cookies: Collect anonymous information about how visitors use the Platform, such as which pages are visited most frequently and any error messages encountered. This data helps us improve Platform performance;
• Functionality Cookies: Remember your preferences and settings, such as language preferences and game settings, to provide a more personalized experience;
• Analytics Cookies: Used to understand user behavior and improve our services. Analytics data is aggregated and anonymized where possible.

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling certain cookies may affect the functionality of the ph36 Platform and your ability to access certain features. For more information on managing cookies, please refer to your browser's help documentation.

Under the Philippine Data Privacy Act of 2012 and other applicable data protection laws, you have the following rights with respect to your personal information held by ph36:

• Right to Access: You have the right to request a copy of the personal information ph36 holds about you, along with information about how it is being used;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal information we hold about you;
• Right to Erasure: You have the right to request deletion of your personal information where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to request that we transmit this data to another service provider where technically feasible;
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes or where processing is based on our legitimate interests;
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information in certain circumstances;
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Data Privacy Officer through the contact details provided in Section 14 of this Policy. We will respond to your request within thirty (30) days. In some cases, we may need to verify your identity before processing your request.

If you believe that ph36 has not adequately addressed your privacy concerns, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).

ph36 retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, including providing our services, complying with legal obligations, resolving disputes, and enforcing our agreements. The specific retention periods we apply are as follows:

• Account Information: Retained for the duration of your account and for a period of five (5) years following account closure, in accordance with Philippine gaming and financial regulations;
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years as required by anti-money laundering regulations;
• Identity Verification Documents: Retained for the duration of your account and for five (5) years following account closure;
• Customer Support Communications: Retained for three (3) years from the date of the communication;
• Marketing Preferences: Retained until you withdraw your consent or request deletion;
• Technical and Usage Data: Typically retained for up to two (2) years for analytics and security purposes.

Upon expiry of the applicable retention period, ph36 will securely delete or anonymize your personal information in accordance with our data disposal procedures. Where anonymization is not possible, we will ensure that the data is securely destroyed.

ph36 operates primarily within the Philippines and processes most personal data within Philippine territory. However, some of our service providers and technology partners may be located in other countries, which may result in your personal information being transferred to and processed in jurisdictions outside the Philippines.

Where such international transfers occur, ph36 ensures that appropriate safeguards are in place to protect your personal information, including:

• Transferring data only to countries that provide an adequate level of data protection as recognized by the National Privacy Commission of the Philippines;
• Implementing contractual clauses with service providers that require them to protect your data to the same standard as required under Philippine law;
• Conducting due diligence on all international service providers to verify their data protection practices and security measures.

By using the ph36 Platform, you acknowledge and consent to the transfer of your personal information to other countries as described in this section, subject to the safeguards outlined above.

The ph36 Platform is strictly intended for adults aged 21 years and above. ph36 does not knowingly collect, use, or store personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal information from a person under 21 years of age, we will take immediate steps to delete that information from our systems and close the associated account.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal information to ph36, please contact our Customer Support team immediately. We will investigate and take appropriate action as quickly as possible.

The ph36 Platform may integrate with or reference third-party services, including payment gateways, game providers, and analytics platforms. These third-party services operate under their own privacy policies and data practices, which are independent of ph36's Privacy Policy.

ph36 is not responsible for the privacy practices or content of any third-party services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the ph36 Platform. Our inclusion of or reference to third-party services does not constitute an endorsement of their privacy practices.

All third-party service providers engaged by ph36 are carefully vetted and are required to enter into data processing agreements that obligate them to handle your personal information in accordance with applicable data protection laws and this Privacy Policy.

ph36 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. The "Last Updated" date at the top of this document indicates when the Policy was most recently revised.

For material changes that significantly affect your privacy rights or how we handle your personal information, ph36 will provide advance notice via email to your registered address or through a prominent notice on the Platform at least fourteen (14) days before the changes take effect. For minor or non-material changes, the updated Policy will be posted on the Platform without prior notice.

Your continued use of the ph36 Platform following the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure by contacting our Customer Support team.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way ph36 handles your personal information, please contact our Data Privacy Officer:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. ph36 takes all privacy complaints seriously and will cooperate fully with any NPC investigation.