36ph Privacy
Policy

1. Introduction

This Privacy Policy ("Policy") is issued by 36ph (the "Platform," "we," "us," or "our"), the operator of the online casino and sports betting services available at 36ph.cam and its associated subdomains. It applies to all users ("you," "your," or "Player") who register an account, visit the Platform, or interact with any 36ph service.

36ph is committed to protecting the personal information of Filipino players and all individuals who engage with our platform. We recognize that privacy is a fundamental right, and we have designed our data practices to be transparent, proportionate, and compliant with applicable law.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your relationship with 36ph.

2. Information We Collect

36ph collects personal information in several categories, each serving a specific and lawful purpose:

2.1 Registration and Identity Information

When you create a 36ph account, we collect the information you provide directly, including:

• Full legal name
• Date of birth (to verify you are at least 21 years of age)
• Residential address (including barangay, city/municipality, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted account password
• Nationality and country of residence

2.2 Identity Verification Documents

To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements, 36ph may request and retain copies of:

• Government-issued photo identification (Philippine passport, driver's license, SSS ID, UMID, or national ID)
• Proof of address (utility bill, bank statement, or barangay certificate dated within three months)
• Payment method verification (photograph or statement confirming ownership of the payment method used)

2.3 Financial and Transaction Information

• Deposit and withdrawal amounts, dates, and payment methods (GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven)
• Betting history, including bet amounts, outcomes, and winnings
• Bonus claims and wagering activity
• Account balance history

2.4 Technical and Device Information

• IP address and approximate geographic location derived from IP
• Device type, model, and operating system
• Browser type and version
• Session timestamps, login history, and duration of use
• Referring URL and navigation paths within the Platform

2.5 Communications Data

• Customer support inquiries and correspondence (email, live chat transcripts)
• Survey responses and feedback submissions
• Records of complaints and our responses

3. How We Collect Your Data

36ph collects personal information through the following means:

• Directly from you — when you register, complete KYC verification, make deposits or withdrawals, place bets, contact customer support, or respond to surveys.
• Automatically — through cookies, log files, and similar tracking technologies when you visit or interact with the 36ph Platform.
• From third-party service providers — including payment processors, identity verification services, fraud detection providers, and analytics partners who supply information necessary to operate the Platform securely.
• From regulatory and government authorities — where required by law, including PAGCOR or other gaming regulators.

4. How We Use Your Personal Information

36ph uses your personal information for clearly defined purposes. The table below summarizes the primary uses and their legal basis:

5. Legal Basis for Processing Personal Data

36ph processes your personal information under the following legal bases:

• Performance of a Contract: Processing is necessary to create and manage your account, facilitate betting activity, and process payments.
• Legal Obligation: Processing is required to comply with AML regulations, KYC requirements, PAGCOR licensing conditions, and other applicable laws.
• Legitimate Interests: Processing is necessary for fraud prevention, security monitoring, and improving the Platform — provided these interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, where we rely on your freely given, specific, and informed consent.

6. Data Sharing and Disclosure

36ph does not sell, rent, or trade your personal information to third parties for commercial purposes. We may share your data only in the following limited circumstances:

6.1 Service Providers and Partners

We engage trusted third-party service providers to perform specific functions on our behalf, including payment processing (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification, fraud detection, IT infrastructure and hosting, and customer support platforms. These providers are contractually bound to process your data only as instructed by 36ph and in accordance with this Policy.

6.2 Regulatory and Law Enforcement Authorities

36ph may disclose your personal information to PAGCOR, Philippine government agencies, law enforcement bodies, financial intelligence units, or courts where required by applicable law, a court order, or a legitimate regulatory request. We will only disclose the minimum information necessary to satisfy the lawful request.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets involving 36ph, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

6.4 Responsible Gaming Referrals

With your consent, or where required to protect your welfare, 36ph may share limited information with responsible gaming support organizations to facilitate access to self-exclusion schemes or problem gambling counseling services.

7. Cookies and Tracking Technologies

36ph uses cookies and similar tracking technologies (including pixel tags and local storage) to operate the Platform, remember your preferences, and analyze usage patterns. Cookies are small text files placed on your device when you visit 36ph.

7.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function correctly, including session management, authentication, and security. These cannot be disabled.
• Functional Cookies: Store your preferences such as language settings, display preferences, and previously viewed game categories.
• Analytics Cookies: Collect aggregated and anonymized information about how users interact with the 36ph Platform to help us improve performance and usability.
• Marketing Cookies: Used to deliver relevant promotions and bonus offers based on your activity on the Platform. These are only set with your consent.

7.2 Managing Cookies

You may control and manage cookie settings through your browser preferences. Note that disabling strictly necessary cookies may affect the functionality of the 36ph Platform. For marketing and analytics cookies, you may withdraw consent at any time through your account settings or by contacting customer support.

8. Data Retention

36ph retains your personal information for as long as is necessary to fulfill the purposes outlined in this Policy, or as required by applicable law. The following general retention periods apply:

• Account information and KYC documents: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in accordance with AML and regulatory requirements.
• Transaction and betting records: Retained for a minimum of five (5) years from the date of the transaction for financial compliance and audit purposes.
• Customer support communications: Retained for three (3) years from the date of the last communication.
• Marketing consent records: Retained for as long as your consent remains valid, plus one (1) year following withdrawal of consent.
• Self-exclusion records: Retained indefinitely to prevent re-registration during an exclusion period.

When your data is no longer required, 36ph will securely delete or anonymize it in accordance with our internal data destruction procedures.

9. Data Security

36ph implements a comprehensive set of technical and organizational security measures to protect your personal information against unauthorized access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 36ph Platform.
• Encrypted storage of sensitive personal and financial data on secure servers with restricted access controls.
• Multi-factor authentication options for Player accounts.
• Regular security audits, vulnerability assessments, and penetration testing conducted by qualified third parties.
• Access controls ensuring that only authorized 36ph personnel can access personal data, on a strictly need-to-know basis.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While 36ph takes all reasonable steps to protect your data, no method of electronic storage or transmission over the internet is 100% secure. If you believe your 36ph account has been compromised, contact our customer support team immediately.

10. Your Data Rights

As a 36ph player, you have the following rights regarding your personal information. To exercise any of these rights, contact 36ph customer support with your account details and a description of your request:

• Right to Access: You have the right to request a copy of the personal information 36ph holds about you, along with information about how it is used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal information associated with your account.
• Right to Erasure: In certain circumstances, you have the right to request deletion of your personal information. This right is subject to our legal and regulatory retention obligations, which may require us to retain certain data even after account closure.
• Right to Restriction of Processing: You have the right to request that 36ph temporarily restrict processing of your personal data while a dispute is being resolved.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes at any time. You may opt out of marketing communications through your account settings or by contacting support.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

36ph will respond to data rights requests within 30 days of receipt. In complex cases, we may extend this period by an additional 60 days, in which case we will notify you of the extension and the reasons for it.

11. Children's Privacy and the 21+ Requirement

The 36ph Platform is strictly intended for adults aged 21 years and above, in line with PAGCOR's minimum age requirements for online gambling in the Philippines. 36ph does not knowingly collect personal information from individuals under the age of 21.

If 36ph becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the personal data collected, and report the matter to relevant authorities where required. If you believe that a minor has registered on 36ph, please contact our customer support team immediately.

12. International Data Transfers

The 36ph Platform is primarily operated for and within the Philippines. However, some of our third-party service providers — including cloud hosting, payment processing, and fraud detection partners — may process data in jurisdictions outside the Philippines.

Where personal data is transferred internationally, 36ph takes steps to ensure that adequate safeguards are in place to protect your information, including contractual data protection clauses with service providers and ensuring that any recipient jurisdiction provides an adequate level of data protection. By using the 36ph Platform, you consent to such transfers where they are necessary to provide the service.

13. Third-Party Services and Links

The 36ph Platform incorporates services provided by third-party game developers, payment processors, and technology partners. While these integrations are essential to the operation of 36ph, they are governed by their own privacy policies which are separate from this document.

36ph is not responsible for the privacy practices of third-party service providers and encourages you to review their policies independently. This Policy applies solely to data collected and processed by 36ph in connection with your use of the Platform.

14. Changes to This Privacy Policy

36ph reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the services we offer. When material changes are made, we will notify you via email to the address registered on your 36ph account and/or by posting a prominent notice on the Platform.

The "Last Updated" date at the top of this Policy reflects when the most recent changes were made. We encourage you to review this Policy periodically. Your continued use of the 36ph Platform following the posting of changes constitutes acceptance of those changes.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 36ph handles your personal information, please contact us through our customer support team. We are committed to addressing your privacy concerns promptly and transparently.

You may also reach our Data Protection contact by email. Our support team will direct your inquiry to the appropriate person within 36ph who can assist you with data protection matters.

This Privacy Policy forms part of the agreement between you and 36ph. By registering an account and using the Platform, you acknowledge that you have read, understood, and agreed to the collection and use of your personal information as described in this document. This Policy is effective as of the date of your registration and will remain in force for the duration of your use of 36ph.