ph361 Casino Privacy Policy

01 Who We Are and Scope of This Policy

This Privacy Policy ("Policy") is issued by ph361 ("ph361," "we," "us," or "the Company"), the operator of the online gaming platform located at ph361.cam ("the Platform"). ph361 is the data controller for personal data collected through the Platform and is responsible for ensuring that such data is handled in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR").

This Policy applies to all personal data collected from Filipino players and other users who visit, register on, or interact with the ph361 Platform, whether through a web browser, mobile device, or any other access method. It covers data collected from the moment you first visit ph361.cam through the entire lifecycle of your account, including post-closure data retention where required by law.

By accessing the ph361 Platform, creating an account, or continuing to use our services, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy.

02 Personal Data We Collect

ph361 collects personal data through several means: directly from you when you register or interact with the Platform, automatically through the operation of the Platform, and from third-party sources where required for identity verification and compliance purposes.

ph361 does not intentionally collect special categories of sensitive personal data (such as health data, religious beliefs, or political opinions) unless specifically required by applicable law or regulatory obligation. Where such data is incidentally disclosed (for example, through a responsible gaming self-assessment), ph361 will handle it with heightened care and use it solely for the stated lawful purpose.

03 How ph361 Uses Your Personal Data

ph361 uses the personal data collected from Filipino players for the following specific purposes. Each use is tied to a lawful basis as described in Section 4 of this Policy:

• Account management: Creating, maintaining, and managing your ph361 player account, including processing registration, verifying your identity, and maintaining your account preferences and settings.
• Service delivery: Providing access to casino games, sports betting, bingo, live casino, and all other features of the ph361 Platform, including processing deposits and withdrawals through GCash, PayMaya, and Philippine bank channels.
• Identity and age verification: Verifying that you are aged 21 years or above and confirming your identity through KYC procedures, as required by Philippine gaming regulations and our internal compliance obligations.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account takeover attempts, money laundering, and other prohibited activities that could harm you, other players, or the ph361 platform.
• Regulatory compliance: Meeting our obligations under PAGCOR's regulatory framework, the Philippine Anti-Money Laundering Act (AMLA), the Data Privacy Act, and any other applicable Philippine laws and regulations.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviors, operating deposit limit and self-exclusion tools, and fulfilling our duty of care to Filipino players.
• Customer support: Responding to your inquiries, resolving disputes, handling complaints, and providing assistance with account issues through our 24/7 live chat and email support channels.
• Platform improvement: Analyzing aggregated and anonymized usage data to improve the performance, security, and user experience of the ph361 platform for all Filipino players.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates via email or SMS, strictly where you have consented to receive such communications. You may withdraw this consent at any time through your account settings.

04 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, ph361 is required to have a lawful basis for each processing activity involving your personal data. The following legal bases apply to ph361's processing activities:

• Contractual necessity: Processing required to perform our contractual obligations to you under the ph361 Terms and Conditions — including operating your account, processing payments, and delivering gaming services.
• Legal obligation: Processing required to comply with legal obligations imposed on ph361 by Philippine law, including PAGCOR regulatory requirements, AML/CTF obligations under the Anti-Money Laundering Act, and reporting obligations to the National Privacy Commission.
• Legitimate interests: Processing necessary for ph361's legitimate business interests, including fraud detection, platform security, and improving our services, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your explicit, freely given, specific, and informed consent — primarily for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Vital interests: In limited circumstances, processing may be necessary to protect your vital interests, such as where ph361 has reasonable concern for your safety in the context of problem gambling identification.

05 Data Sharing and Third-Party Disclosures

ph361 does not sell your personal data. We share your personal data only in the limited circumstances described below, and only to the extent necessary for the specific purpose of the disclosure:

• Payment processors: GCash (Globe Fintech Innovations), PayMaya (Voyager Innovations), and Philippine banks (BPI, BDO, Metrobank, UnionBank) receive necessary financial data to process your deposits and withdrawals. These entities operate under their own privacy policies and are subject to Philippine financial regulations.
• Game providers: Licensed game software providers (such as Pragmatic Play, PG Soft, and others) may receive limited technical data (such as session tokens) necessary to deliver their games on the ph361 platform. Game providers are contractually prohibited from using this data for any purpose beyond delivering the game.
• Identity verification services: Third-party KYC and identity verification providers may process copies of your identification documents to verify your identity. These providers are bound by data processing agreements that restrict use of your data solely to identity verification purposes.
• Regulatory authorities: ph361 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government authorities where required by law, a court order, or a valid regulatory request.
• Fraud prevention networks: ph361 may share data with fraud prevention databases and industry-wide self-exclusion registers (such as gambling exclusion schemes) where required for player protection and AML compliance.
• Professional advisors: Lawyers, accountants, auditors, and insurers who provide professional services to ph361 on a confidential basis may have access to limited personal data where necessary for the provision of their professional services.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all of ph361's assets, personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

06 Cookies and Tracking Technologies

ph361 uses cookies and similar tracking technologies on the Platform to deliver essential functionality, improve performance, and — where you have provided consent — to serve relevant content. A cookie is a small text file placed on your device by a web server when you access the ph361 Platform.

• Essential cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in, security cookies that prevent cross-site request forgery, and load-balancing cookies. Essential cookies cannot be disabled without impairing core Platform functionality.
• Functional cookies: Allow the Platform to remember your preferences, such as language settings, preferred game categories, and display settings. These cookies improve your ph361 experience but are not strictly required for basic functionality.
• Analytics cookies: Used to collect aggregated, anonymized data about how Filipino players use the Platform — such as which pages are visited most frequently and how long sessions last. This data helps ph361 improve the Platform experience. Analytics cookies require your consent.
• Security and fraud detection: Technical identifiers used by our security systems to detect suspicious login patterns, unauthorized access attempts, and fraudulent activity. These operate in the background and are essential to Platform security.

You can manage cookie preferences through your browser settings. Most modern browsers (Chrome, Firefox, Safari, Samsung Internet) allow you to view, control, and delete cookies. Note that disabling essential cookies will affect your ability to use the ph361 Platform normally. ph361 does not use third-party advertising cookies or behavioral tracking cookies for the purpose of targeting you with advertising on other websites.

07 Data Retention

ph361 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account data and KYC documents: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR regulations and the Philippine Anti-Money Laundering Act. Where a regulatory investigation, dispute, or legal proceeding is ongoing, data will be retained for the duration of that matter plus an additional period as legally required.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLC record-keeping requirements applicable to online gambling operators.
• Communications and support records: Live chat transcripts and support emails are retained for two (2) years from the date of the communication, or longer if related to an unresolved dispute or complaint.
• Marketing consent records: Records of consent for marketing communications are retained for the duration of the consent plus three (3) years to demonstrate compliance.
• Technical logs: Server logs, security logs, and access logs are retained for twelve (12) months for security monitoring purposes, after which they are deleted or anonymized.

When personal data is no longer required for its stated purpose and has passed the applicable retention period, ph361 will securely delete or irreversibly anonymize it. Anonymized data may be retained indefinitely for statistical and analytical purposes as it no longer constitutes personal data.

08 Data Security Measures

ph361 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, alteration, or disclosure. Our security framework includes the following measures:

• Encryption in transit: All data transmitted between your device and the ph361 Platform is encrypted using TLS/SSL 256-bit encryption. The padlock icon in your browser address bar confirms this protection is active during your session.
• Encryption at rest: Sensitive data stored in ph361's databases — including KYC documents, financial identifiers, and authentication credentials — is encrypted using AES-256 encryption at rest.
• Access controls: Access to personal data within ph361's systems is restricted on a strict need-to-know basis. Staff access is controlled through role-based access permissions, multi-factor authentication, and comprehensive access logging.
• Regular security audits: ph361 conducts periodic security assessments, including vulnerability scanning and penetration testing, to identify and remediate potential security weaknesses before they can be exploited.
• Incident response: ph361 maintains a documented data breach response procedure. In the event of a confirmed breach affecting personal data, ph361 will notify affected players and the National Privacy Commission within the timeframes required by the Data Privacy Act.
• Staff training: All ph361 staff who handle personal data receive mandatory data protection training covering the requirements of the Philippine Data Privacy Act and ph361's internal data handling procedures.

09 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph361. These rights are real and ph361 provides a clear process for exercising each of them:

To exercise any of the rights described above, please contact ph361's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." ph361 will respond to all valid requests within thirty (30) days. ph361 will not charge a fee for handling data subject rights requests unless the requests are manifestly unfounded or excessive.

10 Children's Privacy and Underage Access

The ph361 Platform is strictly intended for persons aged 21 years and above. ph361 does not knowingly collect personal data from individuals under the age of 21. The age restriction is enforced through mandatory age declaration during registration and through KYC identity verification procedures that confirm date of birth via government-issued identification.

If ph361 discovers or has reasonable grounds to believe that personal data has been collected from a person under 21 years of age, ph361 will immediately suspend the associated account, cease processing the data, and take steps to delete the data from our systems as quickly as practicable, subject to any legal obligations that may require temporary retention for investigation or reporting purposes.

If you believe that a minor may have registered on ph361 using false age information, please contact our support team immediately so we can investigate and take appropriate action.

11 International Data Transfers

ph361's primary operations are centered on the Philippine market and the Platform is operated with Philippine players in mind. However, some of ph361's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a service provider in another country, ph361 takes steps to ensure that appropriate safeguards are in place to protect the data in transit and at the recipient's facilities.

Such safeguards may include data processing agreements that incorporate the standard contractual clauses recognized by the National Privacy Commission, adequacy assessments of the recipient country's data protection framework, or binding corporate rules where applicable. ph361 does not transfer personal data to countries or jurisdictions that do not provide an adequate level of data protection without ensuring that contractual safeguards are in place.

12 Updates to This Privacy Policy

ph361 may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable Philippine law, or improvements to our platform. When material changes are made to this Policy, ph361 will notify registered players by email and/or by placing a prominent notice on the Platform.

The updated Policy will specify the effective date of the changes. Your continued use of the ph361 Platform after the effective date of any update to this Policy constitutes your acknowledgment of the revised Policy. If you do not agree to the updated Policy, you should cease using the Platform and close your account before the effective date of the changes.

We encourage Filipino players to review this Privacy Policy periodically to stay informed about how ph361 protects your personal data. The "Last Updated" date at the top of this Policy indicates when the most recent revision was made.

13 Contact Our Data Protection Officer

ph361 has designated 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 relating to this Privacy Policy or ph361's data processing practices, you may contact the DPO through the following channels:

This Privacy Policy was last updated on January 1, 2026 and is effective from that date. By continuing to use ph361 after this date, you confirm that you have read and understood this Privacy Policy.