Privacy Policy

1. Introduction

ph336 ("we," "us," "our") operates the online gaming platform accessible at ph336.org and associated mobile applications. We are a PAGCOR-licensed online gaming operator serving Filipino players across the Philippines.

This Privacy Policy describes how ph336 collects, processes, stores, discloses, and protects the personal information of individuals who access or use our platform ("you," "your," "Player"). This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering a ph336 Account or using the ph336 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein. If you do not agree with this Policy, please discontinue use of the Platform and contact us to close your Account.

2. Personal Data We Collect

ph336 collects personal data through multiple touchpoints, including the registration process, account usage, payment transactions, customer support interactions, and technical platform activity. The categories of data we collect include:

• Identity Data: Full legal name, date of birth, government-issued ID type and number (e.g., PhilSys ID, passport, driver's license), nationality, and gender — collected during KYC verification as required by PAGCOR and AMLA regulations.
• Contact Data: Email address, Philippine mobile number, and mailing address (for correspondence and verification purposes).
• Account Data: Username, encrypted password, account creation date, login history, session timestamps, and device identifiers.
• Financial Data: Deposit and withdrawal transaction records, payment method identifiers (GCash mobile number, Maya account, bank account last four digits), transaction amounts in PHP, and balance history. Full payment account numbers and card numbers are never stored by ph336 — these are processed directly by certified payment processors.
• Gaming Data: Wagering history, game participation records, bet amounts, win/loss records, bonus utilization, and session duration data.
• Communications Data: Records of live chat conversations, support ticket content, and email correspondence with ph336 support.
• Technical Data: IP address, browser type and version, operating system, device model, screen resolution, referring URL, and pages visited on the ph336 Platform.
• Responsible Gaming Data: Self-imposed limits, self-exclusion elections, and any information voluntarily provided in connection with responsible gaming support requests.

3. How We Use Your Personal Data

ph336 uses collected personal data for the following purposes:

• Account Registration and Management: To create, maintain, verify, and manage your ph336 Account;
• Identity and Age Verification (KYC): To verify that you meet the 21-year minimum age requirement mandated by PAGCOR and to comply with anti-money laundering (AMLA) obligations;
• Payment Processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, 7-Eleven CLiQQ, Coins.ph, GrabPay, and USDT TRC20;
• Service Delivery: To provide access to games, process Wagers, calculate and distribute winnings, and operate the ph336 Platform;
• Customer Support: To respond to queries, resolve disputes, and provide assistance through live chat and email;
• Security and Fraud Prevention: To detect, investigate, and prevent unauthorized access, fraudulent activity, money laundering, and other illegal conduct;
• Legal and Regulatory Compliance: To fulfil obligations under Philippine law, PAGCOR regulations, and AMLC requirements, including transaction reporting and player activity monitoring;
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates — only where you have provided explicit consent, with an unsubscribe option in every communication;
• Platform Improvement: To analyze aggregated, anonymized usage data for purposes of improving game selection, platform performance, and user experience;
• Responsible Gaming: To monitor gaming patterns, enforce player-set limits, and identify behaviors potentially indicative of problem gambling.

4. Legal Basis for Processing

ph336 processes your personal data under the following lawful bases as recognized by the Data Privacy Act of 2012:

• Contract Performance: Processing necessary to fulfill our obligations under the Terms and Conditions you accepted upon registration, including account management, game operation, and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLA obligations, NPC directives, and other applicable Philippine law;
• Legitimate Interest: Processing for fraud prevention, platform security, and responsible gaming monitoring, balanced against your privacy rights;
• Consent: Processing for optional marketing communications, where you have provided explicit, informed, and freely given consent, which may be withdrawn at any time.

5. Data Sharing and Disclosure

5.1 Internal Sharing. Personal data is shared within ph336's operational teams (compliance, finance, customer support, technical operations) on a strict need-to-know basis, governed by internal data access controls and confidentiality obligations.

5.2 Service Providers. ph336 engages third-party processors to assist in platform operation, including payment processors (GCash/Gcash API, Maya, BancNet, InstaPay), game software providers, cloud hosting providers, identity verification services, and customer support platform vendors. All processors are engaged under data processing agreements that impose obligations consistent with the DPA.

5.3 Regulatory and Legal Disclosure. ph336 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities when required by law, court order, or regulatory directive. ph336 cooperates fully with lawful law enforcement requests.

5.4 No Commercial Data Sales. ph336 does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. This restriction is absolute and without exception.

5.5 Business Transfers. In the event of a merger, acquisition, or transfer of the ph336 business or its assets, personal data held by ph336 may be transferred to the successor entity, subject to equivalent privacy protections and notification to affected Players.

6. Data Retention

ph336 retains personal data for the minimum period necessary to fulfill the purposes for which it was collected, subject to the following retention standards:

• Account Data: Retained for the duration of the active Account relationship, plus five (5) years following Account closure, in compliance with PAGCOR record-keeping requirements;
• Transaction and Financial Records: Retained for ten (10) years following the transaction date, as required by the AMLA and associated AMLC regulations;
• KYC Documentation: Retained for five (5) years following Account closure or the completion of a transaction to which the KYC relates;
• Marketing Consent Records: Retained for the duration of the consent plus three (3) years, to demonstrate compliance with consent obligations;
• Technical and Log Data: Typically retained for twelve (12) months, unless required for ongoing security investigations.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with ph336's data lifecycle management procedures.

7. Security Measures

ph336 implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

• Transport Layer Security (TLS 1.3) encryption for all data transmitted between your device and ph336 servers;
• AES-256 encryption at rest for all stored personal and financial data;
• Role-based access controls limiting data access to authorized personnel with a documented business need;
• Multi-factor authentication requirements for all ph336 administrative and operational system access;
• Regular third-party penetration testing and vulnerability assessments;
• Intrusion detection and prevention systems monitoring for anomalous access patterns;
• Incident response procedures compliant with NPC breach notification requirements under the DPA.

While ph336 employs industry-standard security measures, no data transmission over the internet can be guaranteed as 100% secure. You are responsible for maintaining the security of your ph336 login credentials and for reporting any suspected unauthorized Account access to support@ph336.org immediately.

8. Cookies & Tracking Technologies

8.1 Types of Cookies. ph336 uses the following categories of cookies and similar tracking technologies on the Platform:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without impacting your ability to use ph336.
• Functional Cookies: Store your preferences (e.g., language, game view settings) to improve your experience on return visits.
• Analytical Cookies: Collect aggregated, anonymized data about how Players use the Platform to help ph336 improve functionality and game selection. No personally identifiable information is transmitted through these cookies.
• Marketing Cookies: Used only where you have consented to receive personalized promotional content. You may withdraw this consent at any time.

8.2 Cookie Management. You may manage and delete cookies through your browser settings. Disabling non-essential cookies will not prevent you from using the ph336 Platform, though some preference-based features may not function optimally.

9. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph336:

10. Children and Minors

The ph336 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing real-money online gaming in the Philippines. ph336 does not knowingly collect personal data from individuals under the age of 21.

If ph336 becomes aware that personal data has been collected from an individual under 21, that Account will be immediately suspended, all associated data will be deleted, and any deposited funds will be returned to the payment source. If you have reason to believe that a minor has accessed or registered on the ph336 Platform, please contact us immediately at support@ph336.org.

11. Cross-Border Data Transfers

ph336's primary data infrastructure is hosted on servers located within or connected to the Asia-Pacific region. Certain service providers engaged by ph336 — including game software providers and cloud infrastructure vendors — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, ph336 ensures that appropriate safeguards are in place, including contractual obligations on recipient parties that are consistent with the requirements of the Data Privacy Act. ph336 does not transfer personal data to jurisdictions without an adequate level of data protection without contractual protections in place.

12. Third-Party Links

The ph336 Platform may contain links to game providers' information pages or related content operated by third parties. ph336 is not responsible for the privacy practices of those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. ph336's Privacy Policy applies solely to personal data collected and processed by ph336 itself.

13. Updates to This Privacy Policy

ph336 may update this Privacy Policy from time to time to reflect changes in our data practices, the services we offer, or applicable legal requirements. When material changes are made, we will notify registered Players via email to the address on file and through a prominent notice on the ph336 Platform, no less than fourteen (14) days before the updated Policy takes effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Continued use of the ph336 Platform after the effective date of an updated Policy constitutes your acceptance of the revised terms.

14. Contact Us & Data Protection Officer

ph336 has designated a Data Protection Officer (DPO) in compliance with the requirements of the Data Privacy Act. For any privacy-related inquiries, requests to exercise your data rights, or concerns about ph336's data practices, please contact:

• Data Protection Officer, ph336
• Email: support@ph336.org (subject line: "Privacy / DPO Request")
• Response Time: ph336 will acknowledge DPO requests within three (3) business days and provide a substantive response within fifteen (15) business days of receipt.
• NPC Complaints: If you are not satisfied with ph336's response to a privacy concern, you may file a complaint with the National Privacy Commission of the Philippines.