ph361 Casino — Privacy Policy

1. Data Controller Identity

The data controller responsible for your personal information collected through the ph361 Platform (ph361.asia) is ph361, a company incorporated and operating under the laws of the Republic of the Philippines, with its principal place of business in Metro Manila, Philippines.

For all data privacy matters, including data subject requests, complaints, and inquiries regarding this Privacy Policy, you may contact our designated Data Protection Officer (DPO) at:

2. Personal Data We Collect

ph361 collects personal data in the following categories:

2.1 Registration Data

When you create a ph361 account, we collect: full legal name, date of birth, email address, Philippine mobile number, and residential address within the Philippines. This data is mandatory to establish and verify your account.

2.2 Identity Verification (KYC) Data

To comply with PAGCOR requirements and the Anti-Money Laundering Act (AMLA), ph361 may collect government-issued identification documents (e.g., PhilSys ID, Passport, Driver's License), selfie photographs for liveness verification, and proof of address documents. KYC data is processed strictly for identity verification and regulatory compliance purposes.

2.3 Financial Data

ph361 collects transaction data including deposit amounts, withdrawal requests, GCash reference numbers, bank account details provided for withdrawal processing, and transaction histories. ph361 does not store full card numbers or complete payment credentials — payment processing is handled by PCI-DSS compliant third-party payment processors.

2.4 Usage and Gameplay Data

ph361 collects game activity data including bets placed, games played, win/loss records, session durations, bonus usage, and responsible gaming limit settings. This data is used to operate the Platform, comply with PAGCOR reporting requirements, and provide personalised gaming experiences where consented.

2.5 Technical Data

ph361 automatically collects technical information including IP address, browser type and version, device type and operating system, referring URLs, and session timestamps. This data is used for platform security, fraud prevention, and analytical purposes.

2.6 Communications Data

When you contact ph361 support or respond to promotions, we collect the content of those communications and any personal data you include therein.

3. Purposes and Legal Bases for Processing

Purpose	Legal Basis (RA 10173)	Data Used
Account creation and management	Performance of contract	Registration data
Age and identity verification	Legal obligation (PAGCOR, AMLA)	KYC documents, registration data
Processing deposits and withdrawals	Performance of contract	Financial data, KYC data
Fraud prevention and security	Legitimate interest / Legal obligation	Technical data, financial data
Regulatory reporting to PAGCOR	Legal obligation	Gameplay data, financial data
Responsible gaming monitoring	Legal obligation / Legitimate interest	Gameplay data, limit settings
Customer support	Performance of contract	Communications data, account data
Promotional communications	Consent	Registration data, gameplay data
Platform analytics and improvement	Legitimate interest	Technical data, gameplay data

4. Data Sharing and Third Parties

ph361 does not sell, rent, or trade your personal data to any third party for commercial purposes. ph361 may share your personal information with the following categories of recipients, strictly on a need-to-know basis and subject to binding data processing agreements:

• Payment Processors: GCash (GXI), PayMaya (Maya Bank), and partner banking institutions (BPI, BDO, Metrobank) for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: PAGCOR-accredited KYC service providers for identity document verification and liveness checks.
• Game Software Providers: Licensed game studios whose titles are available on the ph361 Platform. Game providers receive session tokens but not full personal profiles.
• PAGCOR and Philippine Regulatory Authorities: ph361 is legally required to share certain player and transaction data with PAGCOR and, where applicable, the Anti-Money Laundering Council (AMLC) as mandated by Philippine law.
• Cloud and Infrastructure Providers: Hosting and cloud infrastructure partners operating under binding data processing agreements that restrict the use of data to service provision only.
• Legal and Fraud Prevention: Law enforcement or courts of competent jurisdiction where disclosure is required by valid legal process.

ph361 does not transfer personal data outside the Philippines except where required by the operation of the Platform (e.g., cloud infrastructure) and where adequate safeguards are in place as required by RA 10173 and NPC guidelines.

5. Cookies and Tracking Technologies

ph361 uses cookies and similar tracking technologies on its Platform to maintain login sessions, remember preferences, prevent fraud, and collect analytics data. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These cannot be disabled without breaking core functionality such as login sessions and game access.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming limit configurations.
• Analytics Cookies: Collect anonymized usage data to help ph361 understand how players interact with the Platform and improve the user experience.
• Security Cookies: Used for fraud detection, bot prevention, and session integrity verification.

You may manage cookie preferences through your browser settings. Note that disabling cookies may impair Platform functionality. ph361 does not use advertising or cross-site tracking cookies for third-party advertising networks.

6. Data Retention

ph361 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and KYC Data: Retained for the duration of the account relationship and for a minimum of five (5) years after account closure, as required by AMLA regulations.
• Transaction and Financial Data: Retained for a minimum of five (5) years in accordance with AMLA and BIR record-keeping requirements.
• Gameplay and Betting Records: Retained for a minimum of three (3) years for PAGCOR compliance purposes.
• Communications Data: Retained for two (2) years from the date of communication or account closure, whichever is later.
• Technical Logs: Retained for twelve (12) months for security and fraud investigation purposes.

Upon expiration of the applicable retention period, personal data is securely deleted or irreversibly anonymized.

7. Your Data Subject Rights

Under the Philippine Data Privacy Act (RA 10173), as a data subject you have the following rights with respect to your personal data held by ph361:

• Right to Be Informed: To be notified of how your personal data is being collected and processed by ph361.
• Right to Access: To obtain a copy of the personal data ph361 holds about you and information about how it is being processed.
• Right to Rectification: To request correction of inaccurate or incomplete personal data in your ph361 account.
• Right to Erasure or Blocking: To request deletion or blocking of your personal data where processing is no longer necessary, where consent has been withdrawn, or where processing violates RA 10173. Note that ph361 may be unable to honor erasure requests where retention is required by law (e.g., AMLA).
• Right to Object: To object to processing of your personal data based on legitimate interests, including for direct marketing purposes.
• Right to Data Portability: To receive a structured, machine-readable copy of personal data you have provided to ph361.
• Right to File a Complaint: To lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "DATA PRIVACY REQUEST" and include your registered account username and a copy of a valid Philippine government-issued ID for identity verification. ph361 will respond within the timeframes prescribed by RA 10173 and NPC regulations.

8. Data Security Measures

ph361 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Security measures in place include:

• SSL/TLS encryption for all data in transit between users and ph361 servers.
• Encryption of sensitive data fields (including passwords and financial identifiers) in ph361 databases.
• Role-based access controls ensuring that ph361 personnel can only access personal data on a strict need-to-know basis.
• Regular security vulnerability assessments and penetration testing of the Platform.
• Intrusion detection and monitoring systems that flag and respond to suspicious access patterns.
• Two-factor authentication available to all registered ph361 players and required for platform administrative access.

In the event of a personal data breach affecting your information, ph361 will notify you and the National Privacy Commission within the timeframes required by RA 10173, providing details of the nature of the breach, the data affected, and the steps ph361 has taken in response.

9. Children and Minors

The ph361 Platform is strictly for persons aged twenty-one (21) years and above, as required by PAGCOR. ph361 does not knowingly collect personal data from minors. If ph361 becomes aware that personal data has been collected from a person below the age of 21, that data will be deleted and the associated account will be closed immediately.

If you believe a minor has registered an account on ph361, please contact [email protected] immediately.

10. Changes to This Privacy Policy

ph361 may update this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR regulations, NPC guidelines, or ph361's data processing practices. When material changes are made, ph361 will notify registered players via the registered email address and will update the "Last Updated" date at the top of this Policy.

Continued use of the ph361 Platform after the effective date of a revised Privacy Policy constitutes acceptance of the updated terms. If you do not agree to the revised Policy, you should close your ph361 account and discontinue use of the Platform.

11. Contact and Complaints

For privacy-related inquiries, data subject requests, or complaints, contact ph361's Data Protection Officer:

If you are not satisfied with ph361's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). Information about filing complaints with the NPC is available on the NPC's official website.