365ph.com Privacy Policy

1. Data Controller

365ph.com acts as the Data Controller for all personal information collected through the platform. As Data Controller, 365ph.com determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

365ph.com has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection strategy and implementation. Contact details for the DPO are provided in Section 14 of this Privacy Policy.

2. Personal Data We Collect

365ph.com collects the following categories of personal data from registered players and platform visitors:

2.1 Identity and Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth and age verification information
• Residential address (barangay, city/municipality, province, ZIP code)
• Email address and mobile phone number
• Government-issued ID type and number (e.g., passport, driver's license, SSS, PhilHealth, UMID)
• Selfie or photograph submitted for identity verification purposes

2.2 Financial Data

• GCash or PayMaya (Maya) mobile wallet account details
• Philippine bank account details (bank name, account number) for withdrawal processing
• Debit card details where applicable
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method references

2.3 Gaming Activity Data

• Game session logs including games played, wager amounts, win/loss outcomes, and session duration
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Account login history including timestamps and IP addresses

2.4 Technical and Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform interaction data (pages visited, features used, click patterns)

2.5 Communications Data

• Records of customer support interactions via live chat, email, or other channels
• Feedback, complaints, and dispute correspondence
• Marketing communication preferences and opt-in/opt-out records

Data Category	Examples	Required for Account?
Identity & Contact	Name, DOB, address, email, ID documents	Yes — mandatory for KYC
Financial	GCash number, bank account, transaction history	Yes — required for deposits/withdrawals
Gaming Activity	Game logs, wager history, session data	Yes — generated automatically
Technical & Device	IP address, device type, cookies	Partially — some optional via cookie settings
Communications	Support chat logs, email correspondence	Only when you contact us

3. How We Collect Your Data

365ph.com collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or participating in a promotion.
• Automated collection: Technical data collected automatically when you access the 365ph.com platform, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from anti-fraud partners; payment confirmation data from GCash, Maya, and banking partners.
• Regulatory sources: Information shared with 365ph.com by PAGCOR or other regulatory bodies in connection with licensing compliance, responsible gaming programs, or self-exclusion registries.

4. Purpose and Legal Basis for Processing

365ph.com processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

4.1 Account Registration and Management

Purpose: To create and manage your 365ph.com account, verify your identity, and provide access to the platform's services.
Legal Basis: Performance of a contract (your account agreement with 365ph.com).

4.2 Payment Processing

Purpose: To process deposits and withdrawals via GCash, Maya, and Philippine bank transfers; to verify payment method ownership; and to maintain accurate financial records.
Legal Basis: Performance of a contract; compliance with legal obligations under anti-money laundering regulations.

4.3 Regulatory Compliance and KYC

Purpose: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws, including age verification (21+) and source-of-funds checks.
Legal Basis: Compliance with a legal obligation.

4.4 Responsible Gaming

Purpose: To monitor gaming activity for signs of problem gambling; to enforce deposit limits, session limits, and self-exclusion requests; and to comply with PAGCOR's responsible gaming requirements.
Legal Basis: Compliance with a legal obligation; legitimate interests of 365ph.com in promoting safe gaming.

4.5 Fraud Prevention and Security

Purpose: To detect, investigate, and prevent fraudulent activity, bonus abuse, money laundering, and unauthorized account access.
Legal Basis: Legitimate interests of 365ph.com; compliance with legal obligations.

4.6 Customer Support

Purpose: To respond to your inquiries, resolve disputes, and improve the quality of our support services.
Legal Basis: Performance of a contract; legitimate interests.

4.7 Marketing Communications

Purpose: To send you promotional offers, bonus notifications, and platform updates where you have provided consent.
Legal Basis: Your consent. You may withdraw consent at any time by updating your communication preferences in your account settings or by contacting support.

5. Data Sharing and Disclosure

365ph.com does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

5.1 Service Providers and Data Processors

• KYC and identity verification providers — to verify your identity documents and age;
• Payment processors — GCash, Maya, and banking partners to facilitate deposits and withdrawals;
• Fraud detection and anti-money laundering service providers;
• Cloud hosting and infrastructure providers — to store and process platform data securely;
• Customer support platform providers — to manage live chat and email support interactions;
• Game content providers — limited technical data shared to facilitate game session management.

All third-party service providers engaged by 365ph.com are required to process personal data only on our documented instructions and to implement appropriate technical and organizational security measures.

5.2 Regulatory and Law Enforcement Authorities

365ph.com may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts where required to do so by applicable Philippine law, regulatory directive, or valid legal process.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of the assets of 365ph.com, personal data held by 365ph.com may be transferred to the acquiring entity, subject to the same privacy protections described in this Privacy Policy. Affected users will be notified of any such transfer in advance.

6. Data Retention

365ph.com retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and its implementing rules.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the session, for regulatory audit and dispute resolution purposes.
• Customer support records: Retained for two (2) years from the date of the last interaction, unless the matter is subject to ongoing dispute or legal proceedings.
• Marketing consent records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent, whichever is later.
• Cookie and technical data: Retained in accordance with the cookie retention periods described in Section 7.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents re-identification, unless retention is required by a specific legal obligation or ongoing regulatory proceeding.

7. Cookies and Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 365ph.com platform. They allow the platform to recognize your device, remember your preferences, maintain your session, and collect analytical data about how the platform is used. 365ph.com also uses similar technologies such as web beacons, pixel tags, and local storage objects.

7.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations. Disabling these may affect your user experience.
• Analytical Cookies: Collect aggregated, anonymized data about how users interact with the platform, which pages are visited most frequently, and where errors occur. This data helps us improve the platform.
• Marketing and Targeting Cookies: Used to deliver relevant promotional content and to measure the effectiveness of marketing campaigns. These are only placed with your consent.

7.3 Managing Cookies

You can manage your cookie preferences through the cookie consent banner displayed when you first visit the 365ph.com platform, or through your browser settings. Please note that disabling strictly necessary cookies will prevent you from accessing the platform. Most modern browsers allow you to view, manage, and delete cookies through the browser's settings menu.

8. Data Security

365ph.com implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the 365ph.com platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data protection training.
• Two-Factor Authentication: 365ph.com supports two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Penetration Testing and Security Audits: The platform undergoes regular security assessments, including penetration testing by independent security professionals, to identify and remediate vulnerabilities.
• Incident Response: 365ph.com maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, 365ph.com will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the Data Privacy Act of 2012.

9. Your Data Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 365ph.com. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

365ph.com will respond to all data privacy rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice provided to you. There is no fee for exercising your data privacy rights, unless requests are manifestly unfounded or excessive.

10. Children's Privacy and Age Restriction

The 365ph.com platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 365ph.com does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the account registration process, and 365ph.com reserves the right to request documentary proof of age at any time.

If 365ph.com becomes aware that personal data has been collected from an individual under the age of 21, the account will be immediately suspended, all funds will be handled in accordance with applicable regulations, and the personal data will be deleted as soon as practicable. If you believe that a minor has registered on the 365ph.com platform, please contact our Data Protection Officer immediately.

11. Cross-Border Data Transfers

Some of 365ph.com's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded by Philippine law, 365ph.com will implement appropriate safeguards to protect your personal data, including contractual clauses approved by the National Privacy Commission or equivalent data protection authorities.

By using the 365ph.com platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above. 365ph.com will not transfer your personal data to jurisdictions that do not provide adequate protection without your explicit consent or a valid legal basis.

12. Third-Party Links and Services

The 365ph.com platform may contain references to third-party services, including payment providers such as GCash and Maya. This Privacy Policy applies solely to personal data collected and processed by 365ph.com. Third-party services have their own privacy policies, and 365ph.com is not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party services you use in connection with your 365ph.com account.

13. Amendments to This Privacy Policy

365ph.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered users via email or a prominent notice on the platform at least seven (7) days prior to the effective date of the change. The "Last Updated" date at the top of this page will always reflect the most recent revision.

Your continued use of the 365ph.com platform after the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy. If you do not agree with the amended Privacy Policy, you should cease using the platform and may request account closure in accordance with the Terms & Conditions.

14. Contact and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 365ph.com, please contact our Data Protection Officer:

• Data Protection Officer: 365ph.com Data Privacy Office
• Email: [email protected]
• General Support: [email protected]
• Response Time: We aim to acknowledge all data privacy requests within 5 business days and resolve them within 30 calendar days.

If you are not satisfied with our response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through their official channels.