369ph Privacy Policy

369ph ("we," "us," "our") is committed to protecting the privacy and personal data of all users of the 369ph platform, accessible at 369ph.club. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR).

This policy applies to all personal data collected through: the 369ph website and mobile web application; account registration and KYC processes; deposits, withdrawals, and payment transactions; customer support communications; and any other interaction between you and 369ph.

By registering for and using a 369ph account, you acknowledge that you have read this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree, please discontinue use of the 369ph platform.

369ph is the personal information controller responsible for your personal data processed through the 369ph platform. 369ph operates under PAGCOR authorization and is registered in the Philippines. For all data privacy matters, the designated Data Protection Officer (DPO) can be reached at [email protected].

369ph collects the following categories of personal data, depending on how you use the platform:

369ph does not collect sensitive personal information as defined under the DPA (such as health data, political beliefs, or religious affiliation) unless specifically required for responsible gaming compliance purposes (e.g., problem gambling assessments), in which case explicit consent will be obtained.

369ph collects personal data through the following means:

• Directly from you: Information you provide during registration, KYC submission, deposit/withdrawal requests, customer support inquiries, and any voluntary communications with 369ph;
• Automatically: Technical data collected through cookies, session tracking, and server logs when you access the 369ph platform;
• From third parties: Identity verification data from KYC service providers; fraud prevention signals from payment processors; geolocation data from IP resolution services. All third-party data processors used by 369ph are contractually bound to handle your data in compliance with the DPA.

369ph processes your personal data for the following purposes, each supported by a lawful basis under the DPA:

• Account creation and management — necessary for the performance of the contract between you and 369ph;
• Payment processing (deposits and withdrawals) — necessary for contract performance and compliance with financial regulations;
• Identity verification and KYC compliance — necessary to comply with PAGCOR licensing requirements and Republic Act No. 9160 (Anti-Money Laundering Act);
• Age verification (21+ enforcement) — necessary to comply with PAGCOR regulations and protect minors;
• Fraud prevention and security monitoring — necessary for 369ph's legitimate interests in protecting the platform and its users;
• Responsible gaming monitoring — necessary to comply with PAGCOR responsible gaming obligations and protect vulnerable users;
• Customer support — necessary for the performance of the service contract;
• Marketing and promotional communications — based on your consent, which may be withdrawn at any time;
• Platform analytics and improvement — based on 369ph's legitimate interests in improving the platform experience.

369ph does not sell, rent, or trade your personal data to third parties for marketing purposes. We share personal data only in the following circumstances:

• Payment processors: GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, Metrobank, Coins.ph, and USDT network processors receive financial data necessary to process your transactions;
• KYC and identity verification providers: Third-party identity verification services that assist 369ph in complying with PAGCOR and AMLA requirements;
• Game software providers: Game studios (such as Pragmatic Play, Jili, PG Soft) receive anonymized or pseudonymized session data necessary to operate their game software;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities where disclosure is required by law or court order;
• Legal and professional advisors: Law firms, auditors, and compliance consultants engaged by 369ph, bound by professional confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of 369ph's assets, personal data may be transferred to the acquiring entity, subject to the same privacy protections.

All third-party data processors engaged by 369ph are subject to data processing agreements that require them to process your personal data only as instructed by 369ph and in compliance with applicable Philippine data protection laws.

369ph retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Account and identity data: Retained for the duration of your Account plus a minimum of five (5) years post-closure, as required by AMLA;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA and PAGCOR requirements;
• Gaming history: Retained for up to three (3) years from the date of the activity, unless a longer period is required for compliance or dispute resolution purposes;
• Customer support records: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained for the duration of your Account plus two (2) years, to document consent history.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be linked to an identifiable individual.

369ph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 369ph servers;
• Encrypted storage of passwords using industry-standard hashing algorithms (bcrypt);
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Intrusion detection and monitoring systems;
• Regular security audits and penetration testing;
• Two-factor authentication available for all user accounts.

In the event of a personal data breach that is likely to result in harm to your rights and freedoms, 369ph will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected users without undue delay, as required under the DPA.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 369ph:

• Right to be Informed: You have the right to know how your data is collected, used, and processed — which this policy fulfills;
• Right to Access: You may request a copy of the personal data 369ph holds about you;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data;
• Right to Erasure / Right to be Forgotten: You may request deletion of your personal data, subject to legal retention obligations (e.g., AMLA requirements);
• Right to Object: You may object to the processing of your data for direct marketing or where processing is based on legitimate interests;
• Right to Data Portability: You may request your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: If you believe 369ph has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, submit a written request to the 369ph Data Protection Officer at [email protected]. We will respond within fifteen (15) business days of receiving a verified request.

369ph uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the 369ph website. We use the following types of cookies:

• Strictly necessary cookies: Required for the platform to function — e.g., session management, authentication tokens, fraud prevention. These cannot be disabled;
• Performance cookies: Anonymized analytics data (page views, navigation paths, load times) used to improve platform performance;
• Functionality cookies: Remember your preferences (e.g., language, last game played, account settings);
• Marketing cookies: Used to deliver relevant promotional content. These are only placed with your consent.

You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the 369ph platform. By continuing to use 369ph after being presented with the cookie notice, you consent to the use of performance, functionality, and marketing cookies.

If you are a parent or guardian and believe that a minor has submitted personal data to 369ph, please contact us immediately at [email protected] so that we may take appropriate action.

Some of 369ph's third-party service providers — including game software providers, KYC verification services, and cloud infrastructure providers — may be located outside the Philippines and may process your personal data in other jurisdictions. In all such cases, 369ph ensures that appropriate safeguards are in place, including contractual data transfer agreements that require third parties to provide a level of data protection equivalent to the DPA requirements.

By using the 369ph platform, you consent to the transfer of your personal data to service providers in other jurisdictions where necessary for the operation of the platform, subject to the safeguards described above.

369ph may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered users via email notification and/or a prominent notice on the 369ph platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this policy reflects the date of the most recent revision. We encourage you to review this policy periodically. Your continued use of the 369ph platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

For all data privacy inquiries, requests to exercise your rights, or complaints, please contact the 369ph Data Protection Officer:

• Email: [email protected]
• Response time: Within 15 business days for formal data subject requests
• Live Chat: Available 24/7 on the 369ph platform for general queries

If you are not satisfied with 369ph's response to a data privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through its official channels.