PH369 Privacy Policy

PH369 ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every player who registers and plays on ph369.app. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy applies to all personal data collected through the ph369 website, mobile application, customer support channels, and any other service operated by ph369. By creating an account and using the ph369 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

PH369 acts as the Personal Information Controller (PIC) in respect of the personal data you provide to us. In certain circumstances where we process data on behalf of a third-party controller (such as a licensed game provider), ph369 acts as a Personal Information Processor (PIP) and is bound by the instructions of that controller.

PH369 collects the following categories of personal data from players and users of the ph369 platform:

PH369 collects personal data through the following means:

• Direct Collection: When you register a ph369 account, complete your profile, submit KYC documents, make a deposit or withdrawal, contact our support team, or participate in promotions, you provide personal data directly to ph369.
• Automated Collection: When you access and use the ph369 platform, we automatically collect technical data such as your IP address, device identifiers, browser information, and session activity through cookies, log files, and similar tracking technologies.
• Payment Providers: When you transact via GCash, PayMaya, BPI, BDO, or Metrobank, ph369 receives transaction confirmation data from these payment providers to verify and process your deposits and withdrawals.
• Identity Verification Partners: PH369 may use third-party KYC and identity verification services to validate the documents you submit. These partners process your data on our behalf under strict data processing agreements.
• Fraud Prevention Systems: PH369 uses automated fraud detection tools that analyze behavioral and technical data to identify suspicious activity and protect the integrity of the platform.

PH369 uses the personal data we collect for the following specific purposes:

• Account Management: To create, maintain, and manage your ph369 player account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Gaming Services: To provide you with access to ph369 games including Roulette, Mini Baccarat, Mine, Nine, Fishing Yi Lu Fa, Fortune Rabbit, and Ganesh Fortune, and to record and maintain accurate game history and transaction records.
• Payment Processing: To process deposits and withdrawals in Philippine Peso (₱) via your chosen payment method, and to maintain accurate financial records as required by law.
• Regulatory Compliance: To fulfill ph369's obligations under Philippine law, including KYC verification, anti-money laundering (AML) monitoring under RA 9160, and reporting obligations to PAGCOR and other relevant authorities.
• Responsible Gaming: To monitor gaming behavior and identify patterns that may indicate problem gambling, and to administer responsible gaming tools such as deposit limits, session limits, and self-exclusion at the player's request.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other conduct that violates ph369's Terms & Conditions.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance related to your ph369 account and gaming experience.
• Platform Improvement: To analyze aggregated usage data and improve the performance, features, and user experience of the ph369 platform.
• Marketing Communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications, and updates about new ph369 games and features. You may withdraw this consent at any time.

PH369 processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and ph369 — specifically, to provide you with access to the ph369 gaming platform and to process your financial transactions.
• Legal Obligation: Processing is required for ph369 to comply with applicable Philippine laws and regulations, including KYC requirements, AML obligations, and PAGCOR reporting requirements.
• Legitimate Interests: Processing is necessary for ph369's legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, security monitoring, and platform analytics — provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending you marketing communications or using non-essential cookies — ph369 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

PH369 does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors receive the financial data necessary to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• KYC & Identity Verification Partners: Third-party identity verification services that process your KYC documents on ph369's behalf under strict data processing agreements and confidentiality obligations.
• Game Technology Providers: Licensed game software providers whose games are available on the ph369 platform may receive anonymized or pseudonymized gaming data necessary for game operation and integrity monitoring.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where disclosure is required by law, court order, or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required in connection with the investigation or prosecution of criminal activity, including fraud and money laundering.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by ph369, subject to professional confidentiality obligations.

PH369 uses cookies and similar tracking technologies on the ph369 platform to enhance your experience, maintain session security, and analyze platform usage. The following types of cookies are used by ph369:

• Strictly Necessary Cookies: These cookies are essential for the ph369 platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance & Analytics Cookies: These cookies collect anonymized information about how players use the ph369 platform — such as which pages are visited most frequently and how long sessions last — to help ph369 improve the platform experience.
• Functional Cookies: These cookies remember your preferences on ph369, such as your preferred language, display settings, and responsible gaming configurations, to provide a more personalized experience.
• Security Cookies: PH369 uses security cookies to detect and prevent fraudulent activity, unauthorized access attempts, and bot activity on the platform.

PH369 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active ph369 account, plus a minimum of five (5) years following account closure, as required by applicable AML and gaming regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with the Anti-Money Laundering Act (RA 9160) and its amendments.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Gaming History: Retained for a minimum of three (3) years from the date of the relevant gaming session, for dispute resolution and regulatory compliance purposes.
• Support Communications: Retained for a minimum of two (2) years from the date of the communication, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of your consent and for a reasonable period thereafter as evidence of consent, in accordance with NPC guidelines.

Upon expiry of the applicable retention period, ph369 will securely delete or anonymize your personal data in accordance with our data disposal procedures.

PH369 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and the ph369 platform is protected by TLS (Transport Layer Security) encryption. Personal data stored on ph369 servers is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within ph369 is restricted on a strict need-to-know basis. All ph369 staff with access to personal data are subject to confidentiality obligations and regular security training.
• Intrusion Detection: PH369 operates continuous network monitoring and intrusion detection systems to identify and respond to potential security threats in real time.
• Penetration Testing: PH369 conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in our systems.
• Incident Response: PH369 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, ph369 will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by ph369:

• Right to Be Informed: You have the right to be informed about how ph369 collects, uses, and processes your personal data — which is the primary purpose of this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data ph369 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data ph369 holds about you. You may update certain account details directly through your ph369 account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph369's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to ph369's overriding legitimate grounds.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe ph369 has processed your personal data in violation of the Data Privacy Act.

The ph369 platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. PH369 does not knowingly collect personal data from individuals under the age of 21.

If ph369 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any deposits made by an underage player will be returned to the payment source where technically feasible, and any winnings will be forfeited.

PH369 strongly encourages parents and guardians to use parental control software to prevent minors from accessing online gaming platforms. For more information on protecting young people from online gambling, please visit our Responsible Gaming page.

The ph369 platform integrates with certain third-party services to deliver a complete gaming experience. These include payment processors, game software providers, identity verification services, and analytics tools. Please note the following:

• Third-party service providers engaged by ph369 are required to process personal data only in accordance with ph369's instructions and applicable data protection law. All third-party processors are bound by data processing agreements that include appropriate data protection obligations.
• PH369 is not responsible for the privacy practices of third-party payment providers such as GCash, PayMaya, BPI, BDO, or Metrobank. When you interact with these services, their own privacy policies apply to the data they collect and process independently.
• The ph369 platform does not contain links to external third-party websites. Any reference to third-party services in this Privacy Policy is for informational purposes only.

PH369 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. The "Last Updated" date at the top of this page will be revised whenever a change is made.

For material changes to this Privacy Policy — that is, changes that significantly affect your rights or how ph369 processes your personal data — ph369 will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect.

PH369 has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph369, please contact our DPO using the details below:

• Data Protection Officer: PH369 Data Protection Office
• Privacy Inquiries: [email protected]
• General Support: [email protected]
• Platform: ph369.app
• Response Time: Within 15 business days as required by RA 10173

PH369 takes all privacy inquiries seriously and is committed to resolving any concerns you may have about the handling of your personal data in a timely and transparent manner.