ph364 Privacy Policy

1 About This Privacy Policy

This Policy explains in plain terms what personal data ph364 collects from you, why we collect it, how we store and protect it, who we share it with, and how long we keep it. It also sets out the rights you hold as a data subject under the Data Privacy Act of 2012 and how you can exercise those rights with ph364.

By creating a ph364 account, visiting the ph364 website, or using any ph364 service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you should not use the ph364 platform or provide any personal information to us.

2 Who We Are (Data Controller)

ph364 is the data controller responsible for the personal data processed in connection with the ph364 platform. As data controller, ph364 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out in accordance with the Data Privacy Act of 2012 and all other applicable Philippine data protection regulations.

ph364 operates the online gaming platform accessible at ph364.one and is subject to oversight by the Philippine Amusement and Gaming Corporation (PAGCOR). ph364's designated Data Protection Officer (DPO) can be contacted using the details provided in Section 17 of this Policy.

3 Personal Data We Collect

ph364 collects personal data from you in connection with your registration, ongoing use of the platform, financial transactions, and communications with us. The categories of personal data we collect include:

3.1 Identity and Registration Data

Full legal name, date of birth, nationality, government-issued identification number (e.g. PhilSys ID, passport, UMID, driver's licence number), username, and account password (stored in hashed form).

3.2 Contact Data

Philippine mobile number, email address (where applicable), and residential address as provided during KYC verification or account updates.

3.3 Financial and Transaction Data

GCash mobile number, Maya account details, bank account details (BPI, BDO, UnionBank, Metrobank), deposit and withdrawal history, transaction amounts in Philippine Peso (₱), payment method identifiers, and records of all wagers placed on the ph364 platform.

3.4 KYC Verification Documents

Copies or images of government-issued identity documents submitted for identity verification, including selfies or liveness-check images where required by PAGCOR's KYC compliance framework.

3.5 Technical and Usage Data

IP address, device identifiers (device model, operating system, browser type and version), session duration and timestamps, pages visited within the ph364 platform, game titles accessed, betting and wagering patterns, and login location data.

3.6 Communications Data

Records of your communications with ph364's customer support team (live chat transcripts, support ticket content), and records of any promotional communications you receive from ph364 and your responses to them.

3.7 Responsible Gaming Data

Records of any voluntary deposit limits, session time limits, cooling-off periods, or self-exclusion requests you submit through your ph364 account settings, and any information provided in connection with a responsible gaming support request.

4 How We Collect Your Data

ph364 collects personal data through the following means:

• Account Registration: Information you provide when creating your ph364 account, including during the KYC verification process.
• Platform Use: Data generated automatically as you use the ph364 platform — browsing behaviour, game activity, session logs, and device information collected via cookies and server logs.
• Financial Transactions: Data shared with ph364 by GCash, Maya, and Philippine banks when you make deposits or request withdrawals.
• Customer Support: Information you provide when you contact ph364 support, including chat messages, submitted documents, and follow-up correspondence.
• KYC and AML Verification: Data collected as part of ph364's mandatory identity verification and anti-money laundering compliance procedures as required by PAGCOR.
• Cookies and Tracking Technologies: Information collected via cookies, web beacons, and similar tracking technologies as described in Section 8.
• Third-Party Verification Services: Information received from third-party identity verification or fraud prevention services engaged by ph364 to meet its PAGCOR compliance obligations.

5 How ph364 Uses Your Personal Data

ph364 uses the personal data it collects for the following purposes:

6 Legal Bases for Processing

ph364 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to provide you with the ph364 services you have signed up for, including account management and payment processing.
• Legal Obligation: Processing required to comply with ph364's obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws.
• Legitimate Interests: Processing necessary for ph364's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided that such interests are not overridden by your fundamental rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — most commonly for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

7 Sharing Your Personal Data

ph364 does not sell your personal data. ph364 shares personal data only in the following circumstances and with the following categories of recipients:

• PAGCOR and Philippine Regulatory Authorities: ph364 is required by law to share player data with PAGCOR as part of its regulatory reporting obligations. ph364 will also disclose data to law enforcement or other public authorities where legally compelled to do so.
• Game Providers: Licensed third-party game developers (e.g. Pragmatic Play, JILI, PG Soft, Evolution) may receive gameplay transaction data necessary to operate their games and verify payouts. These providers operate under their own data protection regimes and are internationally certified.
• Payment Service Providers: GCash, Maya, BPI, BDO, UnionBank, and other payment processors receive only the data required to complete your deposit or withdrawal transaction.
• Identity Verification Services: Third-party KYC and AML verification providers engaged by ph364 for PAGCOR compliance purposes may process identity documents and biometric data as data processors acting under ph364's instructions.
• IT and Hosting Providers: Cloud infrastructure and hosting partners who store ph364 platform data are engaged as data processors and are contractually bound to process data only as instructed by ph364 and in compliance with the Data Privacy Act.
• Fraud Prevention Services: Specialist fraud detection providers may receive technical data to identify and prevent fraudulent activity on the ph364 platform.

All third parties who process personal data on ph364's behalf are subject to data processing agreements that impose data protection obligations consistent with the Data Privacy Act of 2012 and ph364's own standards.

8 Cookies & Tracking Technologies

ph364 uses cookies and similar tracking technologies to operate the platform, improve user experience, and analyse platform performance. Cookies are small text files stored on your device by your browser.

Types of Cookies Used

• Strictly Necessary Cookies: Required for the ph364 platform to function — including session management, login authentication, and security. These cannot be disabled without affecting platform functionality.
• Performance and Analytics Cookies: Used to understand how players interact with the ph364 platform, identify popular games, and measure platform performance. Data collected is aggregated and anonymised where possible.
• Functionality Cookies: Remember your preferences within the ph364 platform, such as language settings and responsible gaming configuration.
• Security Cookies: Used to detect and prevent fraudulent activity and protect account security.

You can manage cookie preferences through your browser settings. Disabling certain cookies may limit the functionality of the ph364 platform. ph364 does not use third-party advertising cookies or tracking pixels for the purpose of serving targeted advertising on external platforms.

9 Data Security

ph364 implements technical and organisational security measures appropriate to the risk associated with the personal data it processes. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph364's servers;
• Encryption of sensitive personal data fields at rest in ph364's databases;
• Password hashing using industry-standard cryptographic algorithms — ph364 does not store plaintext passwords;
• Access controls and role-based permissions restricting internal access to personal data on a need-to-know basis;
• Regular security assessments and vulnerability testing;
• Two-factor authentication (2FA) available for all player accounts and mandatory for administrative access;
• Automated anomaly detection and real-time monitoring of access to sensitive data.

While ph364 takes its data security obligations seriously, no system can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, ph364 will notify the National Privacy Commission within the timeframe required under the Data Privacy Act and will inform affected data subjects without undue delay.

10 Data Retention

ph364 retains personal data for the period necessary to fulfil the purposes for which it was collected, subject to any longer retention period required by law. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active ph364 account and for a period of five (5) years following permanent account closure, in accordance with PAGCOR's recordkeeping requirements and AMLA obligations.
• Financial and Transaction Records: Retained for a minimum of five (5) years from the date of the transaction in accordance with Philippine financial record-keeping laws and PAGCOR regulations.
• KYC Verification Documents: Retained for five (5) years from the date of account closure or the date of the last transaction, whichever is later.
• Customer Support Records: Retained for two (2) years from the date of the last communication, unless related to an ongoing dispute or regulatory matter.
• Technical and Usage Logs: Retained for twelve (12) months from the date of collection unless required for longer by a specific security investigation.
• Marketing Consent Records: Retained for the period of your consent plus three (3) years to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, ph364 will securely delete or anonymise your personal data in accordance with its data deletion protocols.

11 Cross-Border Data Transfers

Where ph364 engages game providers, payment processors, or technology service providers whose servers are located outside the Philippines, personal data may be transferred to and processed in countries other than the Philippines. In all such cases, ph364 ensures that appropriate safeguards are in place to protect the personal data in transit and at rest in the receiving jurisdiction.

These safeguards may include data processing agreements incorporating the NPC's standard contractual clauses, transfers to recipients in jurisdictions recognised by the NPC as providing an adequate level of data protection, or transfers authorised by the NPC on a case-by-case basis. ph364 does not transfer personal data internationally unless a valid legal basis and appropriate safeguard is in place.

12 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights as a data subject. To exercise any of these rights, please contact ph364's Data Protection Officer as described in Section 17.

13 Children's Privacy

The ph364 platform is strictly intended for adults aged 18 years and above. ph364 does not knowingly collect personal data from individuals under 18. If ph364 becomes aware that personal data has been collected from a person under 18 — whether through a false age declaration or any other means — ph364 will immediately delete that data and close the associated account in accordance with PAGCOR's underage access policies.

If you are a parent or guardian and believe that a minor has created a ph364 account or submitted personal data to ph364, please contact ph364 support immediately. ph364 will investigate and take prompt action.

14 Marketing Communications

ph364 may send you promotional communications about bonuses, new game launches, platform updates, and special offers — but only where you have provided your consent during registration or subsequently opted in via your account settings.

You may opt out of marketing communications at any time by: (a) updating your communication preferences in your ph364 account settings; or (b) contacting ph364 support with an opt-out request. Opting out of marketing does not affect service communications essential to your account (e.g. security alerts, transaction confirmations, or responsible gaming notifications).

ph364 does not share your contact details with third-party marketers. Any co-branded promotions involving ph364's game provider partners are communicated through ph364's own channels and do not involve sharing your contact data with the partner.

15 Third-Party Platforms

The ph364 platform may contain references to or integration points with third-party services (e.g. payment gateways, game providers). ph364 is not responsible for the privacy practices of those third-party platforms. Once you leave the ph364 platform — for example, by accessing GCash or your bank's app to complete a deposit — you are subject to that platform's own privacy policy and data processing practices. ph364 recommends that you review the privacy policies of any third-party service you interact with.

16 Updates to This Privacy Policy

ph364 may update this Privacy Policy from time to time to reflect changes in its data processing practices, applicable law (including NPC issuances), or PAGCOR requirements. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

For changes that materially affect your rights or ph364's use of your personal data, ph364 will provide reasonable advance notice via the contact details registered on your account or via a prominent in-platform notification. Your continued use of ph364 following notification of changes constitutes your acknowledgment of the updated Policy.

17 Contact Information & Data Protection Officer

For all data privacy matters — including data subject rights requests, data breach reports, consent withdrawals, or general privacy queries — please contact ph364's designated Data Protection Officer:

If your concern is not resolved to your satisfaction by ph364's DPO, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). For responsible gaming concerns including self-exclusion requests, please visit our Responsible Gaming page.