36ph Privacy Policy

1. Who We Are and Scope of This Policy

This Privacy Policy is issued by 36ph, the operator of the online gaming platform accessible at https://36ph.asia (the "36ph Platform" or "Platform"). 36ph is a PAGCOR-authorized online gaming operator registered and operating under the laws of the Republic of the Philippines. References to "36ph," "we," "us," or "our" in this Policy refer to the 36ph Platform and its operating entity.

This Privacy Policy applies to all personal information collected by 36ph in connection with your use of the 36ph Platform, including account registration, deposits, withdrawals, gameplay, customer support interactions, and any marketing communications you receive from 36ph. It applies to all registered Players, visitors browsing 36ph.asia, and any other individuals whose personal information 36ph processes.

36ph is committed to protecting the personal information of its users in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines. As a PAGCOR-regulated entity, 36ph also processes personal data in compliance with applicable PAGCOR requirements and the Anti-Money Laundering Act (AMLA) of the Philippines.

2. Personal Information We Collect

36ph collects the following categories of personal information from its users:

2.1 Identity and Contact Information

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify you are 21 years of age or older, as required by PAGCOR)
• Email address (used as your primary 36ph account identifier and communications channel)
• Philippine mobile number (for two-factor authentication, SMS notifications, and support)
• Residential address within the Philippines
• Nationality and country of residence

2.2 Identity Verification Documents (KYC)

• Copy of a valid Philippine government-issued ID: Philippine Passport, Driver's License, UMID, SSS ID, PhilSys National ID, or equivalent
• Selfie or liveness check photograph for biometric identity matching, where required
• Proof of address documentation where required for enhanced due diligence

2.3 Financial Information

• GCash or Maya mobile wallet account number (linked for deposit and withdrawal processing)
• Philippine bank account details (BPI, BDO, Metrobank, UnionBank, or other supported banks) provided for withdrawal purposes
• Transaction history including deposits, withdrawals, wagers placed, game outcomes, and bonus claim records

2.4 Technical and Device Information

• IP address and geolocation data (country and region level) at the time of login and gameplay
• Device type, operating system, browser type and version
• Session identifiers and cookies
• Pages visited on 36ph.asia, time spent, click patterns, and navigation data

2.5 Communications Data

• Records of customer support interactions via live chat, email, or any other channel
• Records of your preferences regarding marketing communications from 36ph

3. How We Collect Your Information

36ph collects your personal information through the following means:

• Direct collection: Information you provide when registering your 36ph account, completing KYC verification, making deposits or withdrawal requests, contacting 36ph support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access or use the 36ph Platform, including via cookies, log files, and analytics tools operated by 36ph.
• Third-party sources: Identity verification and KYC data may be cross-referenced against third-party identity verification services and Philippine government databases as permitted by law. Payment processors (GCash, Maya, and banking partners) provide transaction confirmation data to 36ph.
• PAGCOR and regulatory sources: Information shared by PAGCOR or other competent Philippine authorities in the performance of regulatory oversight functions, including exclusion lists and compliance advisories.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its IRR, 36ph processes your personal information on the following legal bases:

• Contractual necessity: Processing required to fulfill the contract between you and 36ph — including account management, deposit and withdrawal processing, KYC verification, and game participation.
• Legal obligation: Processing mandated by Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (Republic Act No. 9160 as amended), the Data Privacy Act, and NPC issuances. This includes mandatory KYC, transaction monitoring, and suspicious transaction reporting.
• Legitimate interests: Processing necessary for 36ph's legitimate business interests where these do not override your rights, including fraud prevention, platform security, and analytics to improve the 36ph experience.
• Consent: Processing for optional purposes such as marketing communications, where 36ph will request and obtain your explicit consent. You may withdraw consent for marketing at any time by contacting [email protected].

5. How We Use Your Personal Information

36ph uses the personal information we collect for the following purposes:

• To create and manage your 36ph Player account and provide access to the Platform's services;
• To verify your identity and age (21+) as required by PAGCOR and the Data Privacy Act;
• To process deposits and withdrawals via GCash, Maya, and Philippine bank partners;
• To detect and prevent fraud, money laundering, collusion, bonus abuse, and other prohibited activities on the 36ph Platform;
• To comply with PAGCOR reporting obligations, AMLC suspicious transaction reporting requirements, and other mandatory disclosures under Philippine law;
• To provide customer support and respond to your enquiries, complaints, and disputes;
• To send you transactional notifications relating to your 36ph account (deposits received, withdrawals processed, login alerts, security notifications);
• To send you marketing communications about 36ph promotions, new games, and special offers — only where you have consented or where permitted under Philippine law;
• To analyze Platform usage patterns to improve the 36ph user experience, game selection, and payment services;
• To enforce the 36ph Terms and Conditions and this Privacy Policy.

6. Sharing and Disclosure of Personal Information

36ph does not sell your personal information to any third party. 36ph may share your personal information with the following categories of recipients only to the extent necessary and permitted by law:

• PAGCOR and Philippine regulatory authorities: 36ph is legally required to share certain player information with PAGCOR as part of its operating license obligations. This may include player account data, transaction records, and compliance reports.
• Anti-Money Laundering Council (AMLC): 36ph is a covered person under the AMLA and is required to file suspicious transaction reports (STRs) and covered transaction reports (CTRs) with the AMLC where applicable. This may involve sharing your identity and transaction information.
• KYC and identity verification providers: Third-party services that assist 36ph in verifying player identity documents against Philippine government databases, operating under data processing agreements with 36ph.
• Payment processors: GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, Metrobank, UnionBank, and other payment partners — only the transaction data necessary to process your deposit or withdrawal request.
• Technology and platform providers: Cloud hosting, game content providers, customer support platform operators, and cybersecurity vendors engaged by 36ph under strict data processing and confidentiality agreements.
• Law enforcement: Where 36ph is required by a valid court order, subpoena, or lawful direction from a Philippine government authority to disclose information.

All third parties with whom 36ph shares personal information are required to process that information only for the specified purpose and to maintain appropriate security standards consistent with the Data Privacy Act of 2012.

7. Data Retention

36ph retains your personal information for as long as is necessary to fulfill the purposes described in this Privacy Policy and to comply with applicable Philippine legal obligations. Specifically:

• Active accounts: Personal information associated with an active 36ph account is retained for the duration of the account's existence.
• Closed accounts: Following account closure, 36ph retains personal information and transaction records for a minimum of five (5) years as required by PAGCOR regulations and the AMLA. KYC documents are retained for the same minimum period.
• Legal proceedings: Where personal information is subject to or relevant to ongoing legal proceedings, regulatory investigations, or dispute resolution, 36ph will retain the relevant data until those proceedings are fully concluded.
• Marketing data: Consent to receive marketing communications from 36ph and records of that consent are retained until you withdraw consent, plus any applicable statutory period.

When personal information is no longer required, 36ph will securely destroy, delete, or anonymize it in accordance with the NPC's data disposal guidelines.

8. Data Security

36ph implements technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption (minimum TLS 1.2) on all data transmitted between your device and the 36ph Platform;
• Encryption of sensitive data at rest, including password hashing using industry-standard cryptographic algorithms;
• Access controls limiting internal access to personal data to authorized 36ph personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the 36ph Platform infrastructure;
• Intrusion detection and monitoring systems to identify and respond to security threats;
• Mandatory data privacy and security training for all 36ph staff handling personal information.

While 36ph takes all reasonable precautions to protect your personal information, no data transmission over the internet or electronic storage system is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, 36ph will notify affected individuals and the National Privacy Commission in accordance with the DPA's mandatory breach notification requirements.

9. Cookies and Tracking Technologies

36ph uses cookies and similar tracking technologies on 36ph.asia for the following purposes:

• Essential cookies: Required for the 36ph Platform to function — including session management, login state, and security tokens. These cannot be disabled without preventing access to the Platform.
• Functional cookies: Retain your language preferences, display settings, and recently played games to improve your experience on 36ph.
• Analytics cookies: Help 36ph understand how Players navigate the Platform — including pages visited, time spent, and features used — to improve platform design and performance.
• Security cookies: Used for fraud detection and prevention, including identifying suspicious login patterns and bot detection on the 36ph login page.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the 36ph Platform, though some personalization features may be reduced.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal information processed by 36ph:

• Right to be informed: The right to know whether 36ph holds personal information about you and how it is being processed — which this Privacy Policy provides.
• Right to access: The right to request a copy of the personal information 36ph holds about you. Submit your access request to [email protected] with the subject line "Data Access Request." 36ph will respond within fifteen (15) business days.
• Right to rectification: The right to request correction of any inaccurate, incomplete, or outdated personal information held by 36ph. You may update basic account information directly through your 36ph account settings; for KYC document corrections, contact [email protected].
• Right to erasure or blocking: The right to request that 36ph delete or block processing of your personal information where it is no longer necessary for the purpose collected, or where processing is unlawful — subject to 36ph's legal retention obligations under PAGCOR and AMLA regulations.
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller where technically feasible and legally permissible.
• Right to object: The right to object to the processing of your personal information for direct marketing purposes. You may opt out of 36ph marketing emails at any time via the unsubscribe link in any marketing email or by contacting [email protected].
• Right to lodge a complaint: If you believe 36ph has violated your data privacy rights under the DPA, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, contact the 36ph Data Privacy Officer at [email protected] with the subject line "Data Privacy Request." 36ph will acknowledge your request within three (3) business days and complete its response within the timelines prescribed by the DPA.

11. International Data Transfers

36ph's primary data processing operations are based in the Philippines. To the extent that personal information is transferred to processors or subprocessors located outside the Philippines (for example, cloud infrastructure providers with data centers outside the country), 36ph ensures that such transfers are subject to appropriate safeguards consistent with the Data Privacy Act of 2012 and NPC guidelines, including contractual data processing agreements that provide protections equivalent to those under Philippine law.

36ph does not transfer Philippine player data to jurisdictions that the NPC has determined provide an inadequate level of data protection without implementing appropriate contractual safeguards.

12. Children's Privacy

The 36ph Platform is strictly intended for individuals who are at least twenty-one (21) years of age, as mandated by PAGCOR. 36ph does not knowingly collect personal information from persons under the age of 21. If 36ph discovers that a registered account belongs to a person under 21, the account will be immediately suspended, all personal information will be deleted, and any deposited funds will be returned to the source payment method.

If you have reason to believe that a minor has registered a 36ph account, please notify us immediately at [email protected]. We take underage gambling prevention seriously and will act on all credible reports without delay.

13. Changes to This Privacy Policy

36ph reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR requirements, NPC guidance, or 36ph's data processing practices. When material changes are made, 36ph will notify registered Players by email at least seven (7) days before the updated Policy takes effect, unless a shorter period is required by legal obligation.

The "Last Updated" date at the top of this Privacy Policy will always reflect the most recent revision. Continued use of the 36ph Platform after the effective date of an updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree with any changes, you may request account closure by contacting [email protected].

14. Contact and Data Privacy Officer

For any questions, requests, or complaints relating to this Privacy Policy or 36ph's handling of your personal information, please contact the 36ph Data Privacy Officer:

• Email: [email protected] — Subject line: "Privacy Policy" or "Data Privacy Request"
• Platform: 36ph.asia — Live Chat (available 24/7 after login)
• Response time: 36ph acknowledges data privacy requests within three (3) business days and responds in full within fifteen (15) business days as required by the DPA.

To file a complaint with the Philippine National Privacy Commission:

• NPC Website: privacy.gov.ph (external government authority — not managed by 36ph)
• NPC Email: [email protected] (NPC official address — plain text, not a 36ph link)