Privacy Policy — ph356

1. Data Controller

ph356 ("ph356," "we," "us," or "our") is the data controller responsible for the personal information collected through the ph356 Platform at ph356.org. As data controller, ph356 determines the purposes and means by which your personal data is processed, and is accountable for ensuring that such processing complies with applicable data protection laws, including the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), and its implementing rules and regulations.

If you have any questions or concerns about how ph356 handles your personal data, please refer to Section 13 of this Policy for contact details.

2. Data We Collect

ph356 collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Identity & Contact Data

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Nationality and country of residence
• Email address
• Mobile phone number
• Residential address

2.2 Identity Verification Documents

• Government-issued photo identification (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys national ID)
• Proof of address documents (e.g., utility bill, bank statement)
• Selfie or liveness check images where required for KYC

2.3 Financial Data

• GCash account details (mobile number linked to GCash)
• PayMaya / Maya account details
• Bank account details (bank name, account number, account name) for BPI, BDO, Metrobank, UnionBank, Landbank, PNB, or Security Bank transfers
• Debit card details (card number, expiry — stored in tokenized form only)
• Transaction history, deposit and withdrawal records

2.4 Gaming & Behavioral Data

• Game session history, bet amounts, win/loss records
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)
• Customer support interaction records

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookie identifiers and similar tracking data (see Section 8)

3. How We Collect Data

ph356 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions;
• Automatically — through cookies, web beacons, and similar technologies when you browse or use the ph356 Platform (see Section 8);
• From third parties — including identity verification service providers, payment processors (GCash, Maya, banks), fraud prevention services, and regulatory authorities where required by law.

4. Purpose & Legal Basis for Processing

ph356 processes your personal data only where we have a lawful basis to do so. The table below summarizes our primary processing activities:

Where ph356 relies on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

ph356 does not sell your personal data to third parties. 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 processors — GCash, PayMaya/Maya, and partner banks, for the purpose of processing deposits and withdrawals;
• Identity verification providers — third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements;
• Fraud prevention services — providers that help ph356 detect and prevent fraudulent activity, money laundering, and other prohibited conduct;
• Regulatory and law enforcement authorities — including PAGCOR and other competent Philippine government agencies, where disclosure is required by law, court order, or regulatory directive;
• IT and platform service providers — hosting, cloud infrastructure, and software vendors who process data on our behalf under strict data processing agreements;
• Professional advisers — lawyers, auditors, and accountants where necessary for the conduct of our business, subject to professional confidentiality obligations.

All third parties with whom ph356 shares personal data are required to handle that data in accordance with applicable data protection laws and ph356's data protection standards. ph356 does not permit third-party service providers to use your personal data for their own purposes.

6. Data Retention

ph356 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account and KYC data — retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML regulations;
• Transaction and financial records — retained for a minimum of five (5) years from the date of the transaction;
• Gaming session data — retained for a minimum of three (3) years;
• Customer support records — retained for three (3) years from the date of the last interaction;
• Marketing consent records — retained until consent is withdrawn, plus one (1) year thereafter as evidence of consent.

Where retention beyond these periods is required by law or for the establishment, exercise, or defence of legal claims, ph356 will retain the relevant data for the additional period required. Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized.

7. Data Security

ph356 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph356 Platform;
• Encryption of sensitive data at rest, including financial and identity information;
• Tokenization of payment card details — ph356 never stores raw card numbers;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication requirements for account access and administrative systems;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

8. Cookies & Tracking Technologies

ph356 uses cookies and similar tracking technologies to operate and improve the Platform, personalize your experience, and analyze usage patterns. The types of cookies we use include:

8.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They include session cookies that keep you logged in during your visit and security cookies that help protect against fraud.

8.2 Functional Cookies

These cookies remember your preferences — such as your preferred language, game settings, and responsible gaming tool configurations — so you do not have to re-enter them each time you visit.

8.3 Analytics Cookies

ph356 uses analytics tools to understand how players interact with the Platform, which pages are most visited, and where technical issues occur. This data is aggregated and used solely to improve the ph356 experience. Analytics cookies do not identify you personally.

8.4 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling strictly necessary cookies may affect the functionality of the ph356 Platform. Detailed cookie preferences can be managed via the cookie consent banner displayed on your first visit to ph356.org.

9. Your Data Rights

Under the Philippine Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by ph356:

• Right to be Informed — You have the right to know what personal data ph356 collects about you and how it is used, as set out in this Privacy Policy;
• Right of Access — You may request a copy of the personal data ph356 holds about you;
• Right to Rectification — You may request correction of any inaccurate or incomplete personal data;
• Right to Erasure — You may request 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;
• Right to Object — You may object to the processing of your personal data where ph356 relies on legitimate interest as the legal basis, or where data is used for direct marketing;
• Right to Data Portability — You may request that ph356 provide your personal data in a structured, commonly used, machine-readable format;
• 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 ph356 has not handled your personal data in accordance with the DPA.

To exercise any of the above rights, please contact ph356 using the details in Section 13. ph356 will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

10. Minors & Age Restriction

ph356 employs age verification procedures during registration to prevent underage access. If ph356 discovers that personal data has been collected from a person under 21 years of age, that account will be immediately closed, all associated data will be deleted, and any funds in the account will be handled in accordance with applicable regulations.

If you are a parent or guardian and believe that your child has registered on the ph356 Platform, please contact us immediately using the details in Section 13 so we can take prompt action.

11. International Data Transfers

ph356 primarily processes and stores personal data within the Philippines. In some cases, personal data may be transferred to and processed in countries outside the Philippines — for example, where ph356 uses cloud infrastructure or third-party service providers with operations in other jurisdictions.

Where such transfers occur, ph356 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law. ph356 will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without implementing appropriate safeguards.

12. Changes to This Privacy Policy

ph356 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or the services we offer. When we make material changes, we will notify registered players by email or by posting a prominent notice on the ph356 Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how ph356 protects your personal data. Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Policy.

13. Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or ph356's handling of your personal data, please contact our Data Protection Officer:

If you are not satisfied with ph356's response to your complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.