365ph Privacy Policy

This Privacy Policy ("Policy") is issued by 365ph ("the Company," "we," "us," or "our"), the operator of the online gaming platform accessible at 365ph.one ("the Platform"). This Policy describes how 365ph collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," or "User") who access or use the Platform, including registered players, visitors, and any other persons whose personal data we process in connection with our services.

This Policy applies to all personal data processed by 365ph in connection with the Platform, regardless of the device or method used to access it — whether via desktop browser, mobile browser, or any other means. It covers data collected directly from you, data collected automatically through your use of the Platform, and data received from third parties in connection with your account.

365ph is committed to protecting the privacy and personal data of all Filipino players in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. Where applicable, we also observe internationally recognized data protection principles.

By registering for an account on 365ph or by continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein.

365ph collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect are described below:

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where such information is incidentally disclosed during the responsible gaming self-assessment process (e.g., problem gambling disclosures), in which case it is treated with the highest level of confidentiality.

365ph uses the personal data we collect for the following purposes:

1. Account Management: To create, maintain, and manage your 365ph player account, including processing your registration, verifying your identity, and enabling you to access all Platform features.
2. Service Delivery: To provide you with the gaming services available on the 365ph Platform, including casino games, sports betting, bingo, and slot games, and to process your bets, deposits, and withdrawals.
3. KYC & AML Compliance: To verify your identity and age (21+), conduct anti-money laundering checks, and comply with our obligations under Philippine law, including the Anti-Money Laundering Act (AMLA) and PAGCOR regulatory requirements.
4. Payment Processing: To process deposits and withdrawals via your chosen payment method (GCash, PayMaya, BPI, BDO, Metrobank, etc.) and to maintain accurate financial records.
5. Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
6. Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other prohibited conduct on the Platform.
7. Responsible Gaming: To monitor gaming patterns that may indicate problem gambling behavior and to administer self-exclusion, deposit limit, and other responsible gaming tools you have requested.
8. Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 365ph Platform.
9. Marketing Communications: To send you promotional offers, bonus notifications, and news about 365ph — but only where you have provided your consent or where we have a legitimate interest in doing so, and always subject to your right to opt out.
10. Legal Compliance: To comply with applicable Philippine laws, court orders, regulatory directives from PAGCOR or the NPC, and other legal obligations.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, 365ph processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 365ph — specifically, to operate your player account, process transactions, and deliver the gaming services you have requested.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing is necessary for the legitimate interests of 365ph, including fraud prevention, platform security, responsible gaming monitoring, and business analytics — provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: For certain processing activities — particularly marketing communications and non-essential cookies — we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

365ph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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:

• Payment Service Providers: GCash, PayMaya, and Philippine banking partners (BPI, BDO, Metrobank) receive the financial data necessary to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Services: Third-party KYC and AML screening providers who assist us in verifying your identity and complying with our regulatory obligations. These providers process your data only on our instructions and under strict confidentiality agreements.
• Game Software Providers: Licensed game developers and providers whose games are available on the 365ph Platform may receive anonymized or pseudonymized usage data for game performance and fairness auditing purposes.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required in connection with the investigation or prosecution of criminal activity, including fraud and money laundering.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by 365ph, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 365ph's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

365ph uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. The following types of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled without significantly impairing your ability to use the Platform.
• Performance & Analytics Cookies: These cookies collect anonymized information about how visitors use the Platform — such as which pages are visited most frequently and how users navigate between sections. This data helps us improve the Platform's performance and user experience.
• Functional Cookies: These cookies remember your preferences and settings (such as language preference and display options) to provide a more personalized experience on the 365ph Platform.
• Marketing Cookies: With your consent, these cookies track your activity on the Platform to enable us to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. You may opt out of marketing cookies at any time.

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 365ph Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

365ph retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with 365ph, plus a minimum of five (5) years following account closure, in accordance 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 each transaction, as required by Philippine financial regulations and AMLC reporting obligations.
• KYC & Identity Verification Documents: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later.
• Customer Support Communications: Retained for three (3) years from the date of the last communication, to enable us to resolve any subsequent disputes or complaints.
• Technical & Usage Data: Retained for up to twenty-four (24) months from collection, after which it is anonymized or deleted.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years thereafter, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 365ph's data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it is isolated from active processing until deletion is possible.

365ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and the 365ph Platform is encrypted using 256-bit SSL/TLS encryption, ensuring that your personal and financial data cannot be intercepted during transmission.
• Encryption at Rest: Sensitive personal data stored in our systems — including financial data and identity documents — is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within 365ph is restricted on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and receive regular data protection training.
• Multi-Factor Authentication: Administrative access to systems containing personal data requires multi-factor authentication to prevent unauthorized access.
• Regular Security Audits: 365ph conducts regular security assessments, penetration testing, and vulnerability scans to identify and remediate potential security weaknesses.
• Incident Response: 365ph maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we 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.

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by 365ph:

1. Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
2. Right of Access: You have the right to request a copy of the personal data that 365ph holds about you, along with information about how it is being processed.
3. Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data we hold about you. You may update certain account details directly through your 365ph account settings.
4. Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under Philippine law.
5. Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our ability to demonstrate compelling legitimate grounds.
6. Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
7. Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
8. Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 365ph has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days of receipt, in accordance with the Data Privacy Act and its Implementing Rules.

The 365ph Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. 365ph does not knowingly collect personal data from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under the age of 21, we will take immediate steps to delete that data from our systems and close the associated account. Any funds deposited by an underage user will be returned to the originating payment method after verification, less any applicable processing fees.

If you are a parent or guardian and believe that your child under the age of 21 has registered on the 365ph Platform or provided us with personal data, please contact our Data Protection Officer immediately using the contact details in Section 13. We will investigate and take appropriate action promptly.

In the course of operating the 365ph Platform, your personal data may be transferred to, stored in, or processed in countries other than the Philippines — for example, where our technology infrastructure providers or game software partners are located. Such transfers may occur to countries that have different data protection laws from those applicable in the Philippines.

Where personal data is transferred outside the Philippines, 365ph ensures that appropriate safeguards are in place to protect your data, including:

• Transferring data only to countries that the National Privacy Commission has recognized as providing an adequate level of data protection.
• Implementing standard contractual clauses or data processing agreements that impose data protection obligations on the recipient equivalent to those required under the Data Privacy Act of 2012.
• Ensuring that all international data processors are bound by confidentiality obligations and are required to implement appropriate technical and organizational security measures.

By using the 365ph Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

365ph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, regulatory requirements, or Platform features. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this Policy.
• Post a prominent notice on the 365ph Platform informing registered players of the changes.
• Where required by law or where changes are significant, send a direct notification to your registered email address.

Your continued use of the 365ph Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the changes, you should discontinue use of the Platform and may request account closure by contacting our support team.

We encourage you to review this Privacy Policy periodically to stay informed about how 365ph is protecting your personal data. Previous versions of this Policy are available on request from our Data Protection Officer.

365ph has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012 and the regulations of the National Privacy Commission. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 365ph, please contact our DPO through the following channels:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 directly on the 365ph Platform — the fastest channel for urgent privacy concerns.

When submitting a privacy request, please include your full name, registered email address, and a clear description of your request or concern. We will acknowledge receipt of your request within 48 hours and provide a substantive response within thirty (30) days, in accordance with the Data Privacy Act of 2012.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through its official channels. 365ph will cooperate fully with any NPC investigation or inquiry.