Privacy Policy

1. Introduction

366ph is committed to protecting the privacy and security of your personal information. This Privacy Policy governs all aspects of data collection, processing, storage, and disclosure related to your use of the 366ph gaming platform, including our website, mobile applications, and all associated services (collectively, the "Platform").

This policy applies to all users and visitors of the Platform, regardless of whether you have registered an account. We are transparent about what data we collect, why we collect it, how we use it, and with whom we share it. We adhere to the principles of lawfulness, fairness, and transparency in all data processing activities.

This Privacy Policy should be read in conjunction with our Terms and Conditions, which govern your use of the Platform. Together, these documents form the complete agreement regarding your relationship with 366ph and your use of our services.

2. Data Controller

For the purposes of applicable data protection laws, including the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and the General Data Protection Regulation (GDPR) where applicable, 366ph acts as the data controller for personal information collected through the Platform.

As the data controller, 366ph determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws and regulations.

You can contact our Data Protection Officer regarding any questions, concerns, or requests related to your personal data by emailing [email protected] with "Data Protection" in the subject line.

3. Information We Collect

3.1 Information You Provide Directly

When you register for an account on 366ph, we collect the following personal information:

• Identity Information: Full legal name, date of birth, gender, nationality
• Contact Information: Email address, phone number, residential address
• Account Credentials: Username, password (stored in encrypted form)
• Financial Information: Payment method details (e.g., GCash account, bank account information, credit/debit card numbers), transaction history
• Verification Documents: Government-issued identification (passport, driver's license, national ID), proof of address, proof of payment method ownership
• Communication Data: Customer support correspondence, live chat messages, feedback submissions

3.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain technical and usage information:

• Device Information: IP address, device type, operating system, browser type and version, device identifiers
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, clickstream data, referring URLs
• Location Data: Approximate geographic location derived from IP address
• Cookies and Similar Technologies: Data collected through cookies, web beacons, and similar tracking technologies (see Section 8)

3.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction verification data from GCash, PayMaya, banks, and card networks
• Identity Verification Services: Age verification, identity authentication, and fraud prevention data from third-party verification providers
• Regulatory Authorities: Information required for compliance with anti-money laundering (AML) and know-your-customer (KYC) regulations
• Affiliate Partners: Referral source data if you accessed 366ph through a partner or affiliate link

4. How We Use Your Data

366ph processes your personal information for the following purposes:

4.1 Account Management and Service Provision

• Create and maintain your 366ph account
• Authenticate your identity and verify your age (21+ requirement)
• Process your deposits and withdrawal requests
• Enable you to participate in gaming activities and place wagers
• Track your gaming activity, balance, and transaction history
• Provide customer support and respond to your inquiries

4.2 Legal and Regulatory Compliance

• Comply with Philippine gaming regulations and licensing requirements
• Fulfill KYC (Know Your Customer) and AML (Anti-Money Laundering) obligations
• Detect and prevent fraud, money laundering, and other illegal activities
• Maintain records required by law for audit and regulatory purposes
• Respond to legal requests and enforce our Terms and Conditions

4.3 Platform Improvement and Personalization

• Analyze usage patterns to improve Platform functionality and user experience
• Develop new features, games, and services
• Personalize content and game recommendations based on your preferences
• Conduct internal research, analytics, and statistical analysis
• Monitor and maintain Platform security and performance

4.4 Marketing and Communications

• Send promotional offers, bonuses, and newsletters (with your consent)
• Notify you of new games, features, and updates
• Provide important account notifications and service announcements
• Conduct surveys and request feedback to improve our services

4.5 Responsible Gaming

• Monitor gaming behavior to identify potential problem gambling indicators
• Implement deposit limits, loss limits, and self-exclusion mechanisms
• Provide resources and support for responsible gaming practices

5. Legal Basis for Processing

Under applicable data protection laws, we process your personal data on the following legal bases:

5.1 Contractual Necessity

Processing is necessary to perform our contract with you (the Terms and Conditions) and to provide the gaming services you have requested. This includes account creation, payment processing, and service delivery.

5.2 Legal Obligation

Processing is required to comply with legal and regulatory obligations, including age verification, AML/KYC procedures, tax reporting, and record-keeping requirements imposed by Philippine law and gaming regulations.

5.3 Legitimate Interests

Processing is necessary for our legitimate business interests, including fraud prevention, security monitoring, Platform improvement, and direct marketing, provided such interests are not overridden by your fundamental rights and freedoms.

5.4 Consent

For certain processing activities, such as marketing communications and non-essential cookies, we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

6. Data Sharing & Disclosure

366ph does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of recipients for the purposes described:

6.1 Service Providers

We engage trusted third-party service providers to support our business operations, including:

• Payment Processors: GCash, PayMaya, banks, and payment gateways to process deposits and withdrawals
• Identity Verification Services: Third-party providers that verify age, identity, and address information
• Hosting and Cloud Services: Data storage and server infrastructure providers
• Customer Support Tools: Live chat, email, and ticketing system providers
• Analytics and Marketing Platforms: Tools to analyze Platform usage and deliver targeted communications

All service providers are contractually bound to protect your data and use it only for the specified purposes.

6.2 Regulatory Authorities and Law Enforcement

We may disclose your personal information to regulatory bodies, government agencies, and law enforcement when required by law, legal process, or to comply with gaming licensing requirements, tax obligations, and anti-money laundering regulations.

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

6.4 Fraud Prevention and Security

We may share information with fraud prevention agencies, credit reference agencies, and security service providers to detect and prevent fraudulent activity, money laundering, and other illegal conduct.

7. Data Security Measures

366ph employs industry-standard security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

7.1 Encryption

All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption. Sensitive information stored in our databases, including passwords and financial data, is encrypted at rest using advanced encryption algorithms.

7.2 Access Controls

Access to personal data is restricted to authorized personnel on a need-to-know basis. Employees and service providers with access to personal data are bound by confidentiality obligations and receive regular data protection training.

7.3 Security Monitoring

We implement continuous monitoring systems to detect and respond to security incidents, suspicious activity, and unauthorized access attempts. Regular security audits and penetration testing are conducted to identify and address vulnerabilities.

7.4 Secure Infrastructure

Our servers and data centers employ physical security measures, including restricted access, surveillance systems, and environmental controls. We use reputable hosting providers with ISO 27001 certification and other recognized security standards.

7.5 Incident Response

In the event of a data breach affecting your personal information, we will notify you and relevant regulatory authorities in accordance with applicable data protection laws and take immediate steps to mitigate harm and prevent future incidents.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They enable the website to recognize your device and remember information about your visit, such as preferences and login status.

8.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function properly, including session management, authentication, and security features. These cannot be disabled.
• Performance Cookies: Collect information about how you use the Platform, such as pages visited and errors encountered, to help us improve functionality.
• Functional Cookies: Remember your preferences (e.g., language, currency) and provide enhanced features.
• Marketing Cookies: Track your browsing activity to deliver targeted advertising and measure campaign effectiveness. These require your consent.

8.3 Managing Cookies

You can control and delete cookies through your browser settings. However, disabling certain cookies may affect Platform functionality and your user experience. Most browsers allow you to:

• View and delete cookies stored on your device
• Block all cookies or only third-party cookies
• Receive notifications when cookies are set
• Delete cookies when you close your browser

8.4 Other Tracking Technologies

In addition to cookies, we may use web beacons, pixel tags, and similar technologies to track user behavior, measure advertising effectiveness, and gather usage statistics. These technologies work in conjunction with cookies to provide insights into Platform performance and user engagement.

9. Data Retention

366ph retains your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with legal and regulatory obligations.

9.1 Active Accounts

While your account remains active, we retain all account information, transaction history, and gaming records to provide ongoing services and support.

9.2 Closed Accounts

After you close your account, we retain certain information for the following periods:

• Transaction Records: Retained for seven (7) years from the date of the transaction to comply with Philippine tax and financial regulations
• Identity Verification Documents: Retained for five (5) years from account closure for AML/KYC compliance
• Gaming Activity Logs: Retained for five (5) years to comply with gaming licensing requirements
• Communication Records: Retained for three (3) years to resolve potential disputes

9.3 Deletion

Once retention periods expire and no legal obligation requires further storage, your personal data is securely deleted from our systems and backup archives. Anonymized or aggregated data that cannot identify you may be retained indefinitely for statistical and analytical purposes.

10. Your Privacy Rights

Under the Philippines Data Privacy Act and, where applicable, the GDPR, you have the following rights regarding your personal data:

10.1 Right of Access

You have the right to request a copy of all personal information we hold about you. We will provide this information in a structured, commonly used, and machine-readable format.

10.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You can update most information directly through your account settings or by contacting customer support.

10.3 Right to Erasure (Right to Be Forgotten)

You may request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or when you withdraw consent. This right is subject to legal and regulatory retention requirements.

10.4 Right to Restrict Processing

You may request that we limit the processing of your personal data in certain situations, such as when you contest the accuracy of the data or object to processing based on legitimate interests.

10.5 Right to Data Portability

You have the right to receive your personal data in a portable format and to transmit it to another service provider, where technically feasible.

10.6 Right to Object

You may object to processing of your personal data for direct marketing purposes at any time. You can unsubscribe from marketing communications by clicking the unsubscribe link in emails or contacting customer support.

10.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.

10.8 Right to Lodge a Complaint

If you believe we have violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines or your local data protection authority.

10.9 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. We will respond to your request within thirty (30) days and may request additional information to verify your identity before processing the request.

11. International Data Transfers

366ph primarily operates within the Philippines, and your personal data is stored on servers located in the Philippines or within the Asia-Pacific region. However, certain service providers and business partners may be located outside the Philippines, which may involve transferring your data to jurisdictions with different data protection standards.

When we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by relevant data protection authorities
• Data Processing Agreements with third-party service providers
• Ensuring recipients are located in jurisdictions recognized as providing adequate data protection
• Implementing additional security measures for cross-border data transfers

By using the 366ph Platform, you consent to the transfer of your personal data to countries outside the Philippines under the safeguards described above.

12. Children's Privacy

366ph services are intended exclusively for individuals aged 21 years and older. We do not knowingly collect, use, or maintain personal information from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will take immediate steps to delete such information from our systems and close any associated account.

If you believe we have collected information from a minor, please contact us immediately at [email protected] so we can take appropriate action.

Parents and guardians are encouraged to monitor their children's online activities and use parental control tools to prevent minors from accessing age-restricted content and gaming platforms.

13. Changes to This Privacy Policy

366ph reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations.

Material changes to this policy will be communicated through one or more of the following methods:

• Email notification to your registered email address
• Prominent notice displayed on the Platform homepage
• In-app notification when you log in to your account

The effective date at the top of this policy indicates when the most recent changes were made. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

Your continued use of the Platform following notification of changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should discontinue use of the Platform and may request closure of your account.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

366ph Data Protection Office
Email: [email protected]
Subject Line: "Privacy Policy Inquiry" or "Data Protection Request"

For specific privacy rights requests (access, rectification, erasure, etc.), please use the subject line "Privacy Rights Request" and provide sufficient details to help us process your request efficiently.

We aim to respond to all privacy-related inquiries within thirty (30) days. Complex requests may require additional time, in which case we will notify you of the extended timeframe.

National Privacy Commission (Philippines)
If you wish to lodge a complaint regarding our data practices, you may contact the National Privacy Commission at:
Website: www.privacy.gov.ph
Email: [email protected]