Privacy Policy

1. Introduction

ph367 ("ph367," "we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you," "Player," or "User") who access or use the ph367 platform at ph367.club and all associated services (collectively, the "Platform").

This Privacy Policy describes how ph367 collects, uses, stores, shares, and protects your personal data in connection with your use of the Platform. It also explains the rights available to you under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

This Privacy Policy forms part of and should be read together with ph367's Terms & Conditions. By registering an account or using the 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.

2. Personal Data We Collect

ph367 collects personal data that you provide directly, data generated through your use of the Platform, and data obtained from third parties where permitted by law.

2.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, gender, nationality, Philippine mobile number, email address, and username.
• Identity verification (KYC) data: Government-issued ID (e.g., PhilSys ID, passport, driver's licence, UMID, SSS ID, voter's ID), selfie or liveness check image, and proof of address.
• Payment data: GCash mobile number, PayMaya/Maya account details, bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), or debit card details. Full payment credentials are processed by our PCI-DSS compliant payment partners — ph367 does not store full card numbers.
• Communications: Messages, complaints, and support requests you send to ph367 via live chat, email, or any other channel.
• Responsible gaming data: Deposit limits, self-exclusion requests, and cooling-off period preferences you set on your account.

2.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, games played, session duration, click-stream data, search queries within the Platform, and feature interactions.
• Transaction data: Deposit and withdrawal history, wager amounts, game results, bonus usage, and account balance history.
• Location data: General geographic location derived from your IP address, used for regulatory compliance and fraud prevention. ph367 does not collect precise GPS location data.
• Cookie and tracking data: As described in Section 6 below.

2.3 Data from Third Parties

• Identity verification and fraud screening data from KYC/AML service providers.
• Payment verification data from payment processors and banking partners.
• Publicly available information used for fraud prevention and regulatory compliance.

3. How We Use Your Personal Data

ph367 uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your ph367 account, including authentication and security.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the features of the Platform.
• Identity verification: To verify your identity and age (21+) as required by PAGCOR regulations and Philippine AML laws.
• Payment processing: To process deposits, withdrawals, and bonus payments via GCash, PayMaya, bank transfer, and debit card.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct.
• Regulatory compliance: To comply with PAGCOR licensing requirements, Philippine AML laws, tax obligations, and orders from competent authorities.
• Responsible gaming: To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of gambling-related harm.
• Customer support: To respond to your enquiries, complaints, and support requests.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and security of the Platform.
• Marketing communications: To send you promotional offers, bonuses, and updates about ph367 — only where you have provided consent or where permitted by applicable law. You may opt out at any time.

4. Legal Basis for Processing

ph367 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to perform our contract with you (i.e., to provide the Platform and its services).
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AML laws, and tax obligations.
• Legitimate interests: Processing for fraud prevention, security, and Platform improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

ph367 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 processors: GCash, PayMaya/Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals.
• KYC/AML providers: Identity verification and anti-money laundering screening service providers.
• Game providers: Third-party game studios and platform providers who supply games available on ph367, to the extent necessary for game operation and fairness auditing.
• IT and hosting providers: Cloud infrastructure and data hosting providers who process data on ph367's behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other competent Philippine authorities, where required by law or court order.
• Professional advisers: Legal, accounting, and auditing firms, subject to professional confidentiality obligations.

6. Cookies & Tracking Technologies

ph367 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit ph367.

6.1 Types of Cookies Used

• Strictly necessary cookies: Essential for the Platform to function, including session management, authentication, and security. These cannot be disabled.
• Performance cookies: Collect anonymous data about how players use the Platform (pages visited, errors encountered) to help ph367 improve performance and user experience.
• Functional cookies: Remember your preferences such as language settings, game lobby filters, and responsible gaming limits.
• Analytics cookies: Used to analyse aggregate usage patterns and measure the effectiveness of Platform features. Data is anonymised where possible.

6.2 Managing Cookies

You may control non-essential cookies through your browser settings or the ph367 cookie preference centre. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate.

7. Data Retention

ph367 retains your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable Philippine law.

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and Philippine AML laws.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Transaction records: Retained for a minimum of five (5) years in accordance with AMLC and BIR requirements.
• Support communications: Retained for three (3) years from the date of the last communication.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

Upon expiry of the applicable retention period, ph367 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8. Data Security

ph367 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the ph367 Platform.
• Encryption of sensitive data at rest, including KYC documents and payment information.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning.
• Multi-factor authentication for administrative access to systems containing personal data.
• Staff training on data privacy and security obligations under Philippine law.

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 ph367:

• Right to be informed: The right to know what personal data ph367 collects and how it is processed — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data ph367 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to ph367's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph367 has violated your data privacy rights.

To exercise any of these rights, please contact ph367's Data Protection Officer using the contact details in Section 13. ph367 will respond to verified requests within thirty (30) days as required by the DPA.

10. Children's Privacy

ph367 is strictly an adults-only platform. The minimum age to register and use ph367 is 21 years, in accordance with Philippine gaming regulations. ph367 does not knowingly collect personal data from any person under 21 years of age.

If ph367 discovers that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all data will be deleted, and the matter will be reported to the appropriate authorities. If you believe a minor has registered on ph367, please contact us immediately at the details in Section 13.

11. International Data Transfers

ph367 primarily stores and processes your personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines (for example, cloud infrastructure providers or international game studios), ph367 ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses consistent with the requirements of the Philippine Data Privacy Act and NPC regulations.

ph367 will not transfer your personal data to any jurisdiction that does not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.

12. Changes to This Privacy Policy

ph367 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. Where changes are material, ph367 will notify registered players via email or a prominent notice on the Platform at least fourteen (14) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised. Your continued use of the ph367 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

13. Contact & Data Protection Officer

ph367 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy, please contact:

ph367 aims to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within thirty (30) days. If you are not satisfied with ph367's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.