363ph Privacy Policy

1 Introduction and Scope

363ph is committed to protecting the privacy and personal data of every individual who interacts with our platform. This Policy has been prepared in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission ("NPC"). Where 363ph is subject to additional data protection obligations arising from its PAGCOR regulatory framework, those obligations are also reflected in our data handling practices described herein.

This Policy applies to personal data collected from:

• Registered 363ph account holders and applicants;
• Visitors to the 363ph website or mobile interface who have not completed registration;
• Individuals who contact 363ph customer support via live chat, email, or any other channel; and
• Individuals whose data 363ph receives from third parties in connection with payment processing, identity verification, fraud prevention, or regulatory compliance.

This Policy does not apply to third-party websites, applications, or services that may be linked to or from the 363ph platform. 363ph has no control over and accepts no responsibility for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party services you access in connection with your 363ph account.

2 Data Controller Information

363ph acts as the data controller in respect of the personal data described in this Policy — meaning 363ph determines the purposes and means by which your personal data is processed. If you have questions, concerns, or requests relating to the handling of your personal data, you may contact our Data Protection Officer at:

Please note that email addresses and contact details displayed on the 363ph platform are provided for written correspondence only and do not constitute clickable or callable links.

3 Personal Data We Collect

363ph collects personal data from you directly (information you provide when registering or contacting support), automatically (data generated when you use the platform), and from third parties (data received from payment providers, identity verification services, and regulatory bodies). The categories of personal data we process are set out in the table below.

4 How We Use Your Data

363ph processes your personal data for the following purposes:

4.1 Account Registration and Management

To create and maintain your 363ph account, verify your identity and age (21+ requirement), authenticate your login sessions via OTP and device recognition, and communicate account-related notifications including security alerts and transaction confirmations.

4.2 Provision of Gaming Services

To operate the 363ph gaming platform, process your wagers, credit winnings to your account, manage bonus eligibility and wagering progress, maintain game integrity, and resolve game disputes where applicable.

4.3 Payment Processing

To process your deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and bank transfer in Philippine Peso; to verify that payment accounts are registered in your name; and to comply with anti-money laundering obligations when processing transactions that meet prescribed thresholds.

4.4 Regulatory and Legal Compliance

To fulfill 363ph's obligations under PAGCOR regulations, Republic Act No. 9160 (Anti-Money Laundering Act), Republic Act No. 10173 (Data Privacy Act), and other applicable Philippine laws. This includes mandatory record-keeping, suspicious transaction reporting, and cooperation with lawful requests from regulatory or law enforcement authorities.

4.5 Responsible Gaming

To monitor gaming patterns that may indicate problematic gambling behavior, to administer player-requested responsible gaming tools (deposit limits, loss limits, self-exclusion), and to comply with any PAGCOR-mandated responsible gaming protocols applicable to the 363ph platform.

4.6 Fraud Prevention and Security

To detect, investigate, and prevent fraudulent account activity, unauthorized login attempts, payment fraud, multi-account abuse, and other security threats to the 363ph platform and its player community.

4.7 Platform Improvement and Analytics

To analyze aggregated and anonymized usage data to improve platform performance, game selection, user interface design, and the overall 363ph player experience. Where analytics involve personal data at the individual level, this processing is conducted on the basis of our legitimate interests and is subject to appropriate safeguards.

4.8 Marketing and Promotions

To send you promotional communications about 363ph offers, bonuses, and new game releases, where you have provided your consent or where permitted by law. You may opt out of marketing communications at any time by contacting 363ph support or using the unsubscribe mechanism included in each marketing message.

5 Legal Bases for Processing

Under the Data Privacy Act of 2012, 363ph processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing required to perform 363ph's obligations under your account agreement, including account management, game operation, and payment processing;
• Legal obligation: Processing required to comply with PAGCOR regulations, AML law, tax obligations, court orders, or other binding Philippine legal requirements;
• Legitimate interests: Processing necessary for purposes that are in 363ph's or a third party's legitimate interests, including fraud prevention, platform security, and analytics, provided those interests are not overridden by your privacy rights; and
• Consent: Where none of the above bases apply, 363ph will seek your express consent before processing your data for that purpose. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing and Disclosure

363ph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances and only to the extent necessary for the stated purpose:

6.1 Service Providers and Data Processors

363ph engages third-party service providers who process personal data on our behalf under written data processing agreements that bind them to confidentiality and data protection obligations equivalent to those under this Policy. These include payment processors (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank), identity verification and KYC service providers, AML and sanctions screening providers, game software providers operating live dealer studios, and cloud infrastructure and hosting providers.

6.2 Regulatory and Law Enforcement Authorities

363ph is required by law to disclose certain personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies in connection with our regulatory obligations. 363ph may also disclose personal data in response to a valid court order, subpoena, or other lawful process issued by a competent Philippine authority.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a substantial part of 363ph's business assets, your personal data may be transferred to the acquiring entity as part of the transaction, subject to the acquiring entity assuming the obligations of this Policy with respect to your personal data.

7 Cookies and Tracking Technologies

363ph uses cookies and similar tracking technologies on its web and mobile interfaces to provide, secure, and improve the Services. A cookie is a small text file placed on your device by the 363ph platform when you access the site. The categories of cookies used by 363ph are as follows:

You may manage or disable non-essential cookies through your browser or device settings at any time. Please be aware that disabling functional or analytics cookies may affect the performance or personalization of certain features within your 363ph account. 363ph does not use cookies to serve third-party advertising.

8 Data Retention

363ph retains personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law, whichever is longer. The key retention periods applicable to 363ph player data are as follows:

• Account and identity data are retained for the duration of the active account relationship and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML obligations under RA 9160;
• Transaction and financial data are retained for a minimum of five (5) years from the date of each transaction, in compliance with AML law and PAGCOR audit requirements;
• Customer support communications are retained for two (2) years from the date of the final communication in a support thread, or longer where the matter is subject to an ongoing dispute or regulatory inquiry;
• Technical and analytics data are retained in anonymized or aggregated form indefinitely for platform improvement purposes, and in identifiable form for no longer than thirteen (13) months; and
• Marketing consent records are retained for the duration of the consent and for three (3) years following withdrawal of consent or account closure, whichever occurs first.

Upon expiry of the applicable retention period, 363ph will securely delete or anonymize your personal data in accordance with NPC-approved data disposal procedures, unless retention is required by a specific legal obligation or active regulatory proceeding.

9 Data Security

363ph implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 363ph's servers;
• Encryption of sensitive data at rest, including hashed password storage using industry-standard cryptographic algorithms;
• Role-based access controls limiting 363ph staff access to personal data to those with a legitimate operational need;
• Multi-factor authentication for all internal staff access to systems containing player personal data;
• Regular penetration testing and vulnerability assessments of the 363ph platform infrastructure;
• Continuous monitoring for unauthorized access attempts, unusual data access patterns, and potential data breach indicators; and
• Formal data breach response procedures aligned with the NPC's mandatory breach notification requirements under the DPA.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms as a data subject, 363ph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach and will notify affected data subjects without undue delay in accordance with NPC breach notification guidelines.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 363ph:

10.1 Right to Be Informed

You have the right to be informed of the personal data 363ph collects about you, the purposes and legal bases for processing, the identity of recipients to whom your data may be disclosed, and your rights as a data subject — all of which are set out in this Policy.

10.2 Right of Access

You have the right to obtain a copy of the personal data 363ph holds about you and information about how that data is processed. Requests for access will be fulfilled within fifteen (15) business days, subject to identity verification. 363ph may charge a reasonable administrative fee for multiple or repetitive access requests.

10.3 Right to Rectification

You have the right to request the correction of inaccurate or incomplete personal data held by 363ph. Basic account details such as your contact number and email address may be updated directly from your 363ph account settings. Corrections to identity data (name, date of birth) require submission of supporting documentation and are processed within fifteen (15) business days.

10.4 Right to Erasure

You have the right to request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn your consent and there is no other legal basis for processing, or where the data has been processed unlawfully. This right is subject to overriding legal retention obligations under PAGCOR regulations and AML law, which may require 363ph to retain certain data for the minimum periods described in Section 8 of this Policy.

10.5 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing carried out on the basis of 363ph's legitimate interests where your interests, rights, or freedoms override those interests. Objections to marketing can be submitted at any time via [email protected] or through the unsubscribe link in any 363ph marketing communication.

10.6 Right to Data Portability

Where processing is based on your consent or on contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format, and to request that this data be transmitted to another controller where technically feasible.

10.7 Right to Lodge a Complaint

If you believe 363ph has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. We encourage you to contact 363ph's Data Protection Officer first so that we have an opportunity to address your concern directly.

11 Children's Privacy

363ph's gaming services are strictly restricted to individuals who are twenty-one (21) years of age or older. 363ph does not knowingly collect, process, or retain personal data from persons under the age of 21. If 363ph discovers that personal data has been collected from or in relation to a person under the age of 21, we will take immediate steps to delete that data, close the associated account, and report the incident to PAGCOR in accordance with our regulatory obligations.

If you have reason to believe that a person under the age of 21 has registered an account with 363ph or provided personal data to 363ph, please notify us immediately at [email protected] so that we can investigate and act promptly.

12 Changes to this Policy

363ph reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes to this Policy will be communicated to registered 363ph players by notification to the mobile number or email address on record, and the revised Policy will be published on this page with an updated effective date.

Your continued use of the 363ph platform following the publication of a revised Privacy Policy constitutes your acknowledgment of and agreement to the updated terms. If you do not agree with a material change, you should discontinue use of the Services and contact 363ph to exercise your right to account closure and data erasure where applicable under Section 10 of this Policy.