Privacy Policy

This Privacy Policy ("Policy") governs the collection, processing, storage, and use of personal data by 368ph in connection with the operation of the 368ph online gaming platform at 368ph.club. It applies to all registered players, prospective players who interact with the platform without completing registration, and any other individuals whose personal information is processed by 368ph in connection with its services.

368ph is committed to handling personal data with integrity, transparency, and in accordance with its obligations under Philippine law — in particular, Republic Act No. 10173, known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and applicable circulars and advisories issued by the National Privacy Commission (NPC) of the Philippines.

This Policy should be read alongside the 368ph Terms & Conditions, which govern the overall relationship between 368ph and registered players. By registering a 368ph account and using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules, 368ph — the operator of the 368ph.club platform — acts as the personal information controller with respect to all personal data collected from players and other individuals in connection with the platform's services.

As personal information controller, 368ph determines the purposes and means of processing your personal data, and bears primary responsibility for ensuring that such processing complies with the requirements of the DPA and other applicable Philippine data protection regulations. 368ph has appointed a Data Protection Officer (DPO) whose contact details are set out in Section 16 of this Policy.

368ph collects personal data that is adequate, relevant, and limited to what is necessary for the purposes described in this Policy. The categories of personal data we collect about registered players include the following:

368ph does not collect sensitive personal information as defined under the DPA (such as health data, political opinions, or religious beliefs) unless specifically required by applicable law or regulatory directive, and never as a routine matter of account operation.

368ph collects personal data through the following channels and mechanisms:

• Direct Registration: Information you provide when creating your 368ph account — name, date of birth, mobile number, email, and chosen credentials.
• KYC Verification: Identity documents and verification images you submit to complete account verification, either at registration or upon request before withdrawal processing.
• Payment Transactions: Financial data generated or provided when you make deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, or UnionBank.
• Platform Activity: Data generated automatically as you use the 368ph platform — game sessions, bets, navigation patterns, session durations, and responsible gaming tool usage.
• Cookies and Tracking Technologies: Technical data collected via cookies, local storage, and similar technologies as described in Section 8 of this Policy.
• Customer Support: Information exchanged during live chat sessions, email correspondence, or any other communication with the 368ph support team.
• Third-Party Verification Services: Identity and address verification data received from contracted identity verification providers in connection with KYC processing.

368ph uses the personal data we collect for the following specific purposes, each of which is described in relation to its legal basis in Section 6:

• Account Creation and Management: Creating and maintaining your 368ph account, authenticating your identity at login, and managing your account settings and preferences.
• Identity Verification (KYC): Verifying your identity and age to satisfy 368ph's obligations under PAGCOR requirements, the Philippine Anti-Money Laundering Act (AMLA), and the DPA. KYC verification is mandatory and non-negotiable for all registered players.
• Payment Processing: Processing deposits and withdrawals via your registered Philippine payment methods (GCash, PayMaya, bank transfer) and maintaining transaction records.
• Gaming Services Delivery: Providing access to the 368ph game library, maintaining game session records, applying stake and win limits, and processing bonus eligibility and usage.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling indicators, applying player-configured deposit and session limits, processing self-exclusion requests, and facilitating cooling-off periods.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, account compromise, bonus abuse, money laundering, and other prohibited conduct.
• Legal and Regulatory Compliance: Fulfilling 368ph's obligations under PAGCOR regulations, AMLA and its implementing rules, the DPA, and any other applicable Philippine law or regulatory directive.
• Customer Support: Responding to your queries, complaints, and account-related requests through live chat, email, and other support channels.
• Platform Improvement: Analyzing aggregated, de-identified usage data to improve platform performance, game selection, user interface, and service quality.
• Marketing Communications (Opt-in Only): Sending promotional communications about 368ph offers, new games, and bonuses — but only where you have explicitly consented to receive such communications. You may withdraw marketing consent at any time via account settings.

Under the Philippine Data Privacy Act of 2012, 368ph processes your personal data on the following legal bases, which apply to the corresponding processing activities:

• Contractual Necessity: Processing required to enter into and perform the contract between 368ph and you as a registered player — specifically, account management, payment processing, gaming service delivery, and customer support.
• Legal Obligation: Processing required to comply with 368ph's obligations under applicable Philippine law — specifically, KYC/identity verification, AMLA transaction monitoring and reporting, PAGCOR compliance, and responsible gaming regulatory requirements.
• Legitimate Interest: Processing carried out to pursue 368ph's legitimate operational interests, where such interests are not overridden by your rights and interests — specifically, fraud detection, security monitoring, platform improvement using aggregated analytics, and abuse prevention.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — specifically, marketing communications and any optional features requiring explicit data collection consent. Consent-based processing is only initiated where you have actively opted in, and may be withdrawn at any time without affecting the lawfulness of prior processing.

368ph does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial purposes. Your personal data may be shared with third parties only in the following circumstances:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment processors receive the minimum data necessary to execute your deposit and withdrawal transactions. These providers operate under their own privacy policies and are contractually obligated to protect your data.
• Identity Verification Providers: Third-party KYC and identity verification service providers who process identity documents and verification images on 368ph's behalf, under data processing agreements that bind them to DPA-consistent data protection standards.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine regulatory or law enforcement bodies, where disclosure is required by applicable law, court order, or regulatory directive.
• Game Technology Providers: Third-party game studios and live casino platform providers who supply the gaming software accessed through 368ph may receive session-level technical data necessary for game delivery. These providers do not receive personally identifiable information beyond what is technically required.
• Fraud Prevention Networks: Industry-standard fraud prevention and anti-abuse platforms that process technical identifiers (IP addresses, device fingerprints) to identify and block malicious actors, operating under confidentiality obligations.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by 368ph, who are bound by professional confidentiality obligations.

368ph uses cookies and similar technologies on the 368ph.club platform to support essential site functionality, security, and optional analytics. The following types of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, security tokens, load balancing identifiers, and cookies that maintain your login state. These cookies cannot be disabled without breaking core platform functionality.
• Functional Cookies: Enable enhanced features such as remembering your display preferences, language settings, and game lobby filters. These improve your experience but are not essential to basic platform access.
• Analytics Cookies: Used to collect aggregated, de-identified information about how players navigate and use the 368ph platform, helping us identify usability issues and improve platform design. No personally identifiable information is passed to analytics processors through these cookies.
• Security Cookies: Used for fraud detection, bot identification, and account security monitoring. These cookies may record technical identifiers such as IP address and device fingerprint for security assessment purposes.

You may configure your browser to block or delete cookies, but please note that disabling strictly necessary cookies will impair your ability to log in to and use the 368ph platform. 368ph does not use third-party advertising or retargeting cookies.

368ph retains personal data for no longer than is necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active 368ph account, and for a minimum of five (5) years following account closure. This period is mandated by AMLA record-keeping requirements applicable to licensed gaming operators in the Philippines.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA and applicable tax record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the conclusion of any investigation or regulatory matter in which the documents are relevant.
• Gaming Activity Data: Retained for the duration of your account and for three (3) years following account closure, for responsible gaming monitoring, dispute resolution, and regulatory audit purposes.
• Customer Support Records: Retained for three (3) years following the resolution of the relevant support interaction, or longer where records relate to a pending dispute or regulatory matter.
• Marketing Consent Records: Retained for the duration of your active account and for three (3) years following account closure, as evidence of consent or withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification, in accordance with 368ph's data disposal procedures and NPC guidelines.

368ph implements technical, organizational, and administrative security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and the 368ph platform is encrypted using industry-standard TLS/SSL protocols. The padlock indicator in your browser confirms this encryption is active.
• Encryption at Rest: Sensitive personal data, including identity documents and financial data, is encrypted at rest in 368ph's data storage infrastructure.
• Access Controls: Internal access to personal data is restricted on a need-to-know basis. 368ph staff access to personal data is logged, audited, and subject to role-based access control policies.
• Two-Factor Authentication: 368ph offers 2FA for all player accounts and strongly encourages its activation. 2FA significantly reduces the risk of unauthorized account access even in the event of password compromise.
• Penetration Testing and Vulnerability Management: The 368ph platform undergoes periodic security assessments to identify and remediate technical vulnerabilities.
• Incident Response: 368ph maintains a data breach incident response protocol consistent with NPC notification requirements under the DPA. In the event of a breach affecting your personal data, you will be notified in accordance with applicable NPC timelines and guidelines.

As an online gaming platform, 368ph may work with technology service providers, game studios, and infrastructure partners whose systems are located outside the Republic of the Philippines. Where personal data is transferred to a country outside the Philippines, 368ph takes the following steps to ensure your data remains protected:

• Personal data is transferred to countries that provide an adequate level of data protection, as recognized by the NPC or under applicable international data protection frameworks.
• Where transfers are made to countries without a formal NPC adequacy finding, 368ph enters into contractual data processing agreements with the recipient that incorporate data protection obligations consistent with the DPA and its Implementing Rules.
• The minimum necessary personal data is transferred for any given cross-border processing purpose. Bulk transfers of Philippine player data for purposes unrelated to platform operations are not conducted.

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 368ph. These rights may be exercised by contacting the 368ph Data Protection Officer as described in Section 16.

Rights requests will be acknowledged within five (5) business days and substantively responded to within thirty (30) calendar days, or such other period as required by applicable NPC guidelines. Responses will be provided free of charge for the first request within any 12-month period.

The 368ph platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations applicable to online gaming in the Philippines. 368ph does not knowingly collect personal data from individuals under 21 years of age.

If 368ph becomes aware that personal data has been collected from a person under the age of 21, such data will be immediately deleted and the associated account closed. Age verification is conducted at registration and may be required again at subsequent points in the account lifecycle.

The 368ph platform may reference or integrate with third-party service providers for game delivery, payment processing, and identity verification, as described in Section 7. While 368ph implements contractual data protection obligations with these providers, this Privacy Policy does not govern the data practices of third-party providers operating under their own terms and privacy policies.

368ph does not embed third-party social media plugins, advertising networks, or external tracking pixels on the 368ph.club platform that would allow third parties to independently collect data about your gaming sessions. Where third-party tools are used for analytics, they are configured to operate in an anonymized, aggregate-only mode.

368ph 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 NPC guidance. Material changes will be communicated to registered players via the email address or mobile number on file, and/or via a prominent notice on the 368ph platform, at least seven (7) days prior to the effective date of the amendment.

The "Effective Date" at the top of this Policy indicates when the current version took effect. Your continued use of the 368ph platform after the effective date of any amendment constitutes acceptance of the revised Policy. If you do not agree with material changes to this Policy, you have the right to close your account and request processing under the prior Policy version up to its expiry date. Please contact our Data Protection Officer to exercise this right.

For any questions, concerns, or formal requests regarding this Privacy Policy, your personal data, or the exercise of your data privacy rights under the DPA, please contact the 368ph Data Protection Officer through the following channels:

• Data Protection Officer Email: [email protected] — Please include your registered 368ph username, a description of your request, and, where applicable, the right you wish to exercise. Responses will be provided within 30 calendar days.
• General Support (Non-Privacy Queries): [email protected] — For account queries, payment issues, and gaming support. Available 24/7 via live chat on the platform.
• Formal Privacy Complaints: If you believe 368ph has not adequately addressed your data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC).