ph3611 Privacy Policy 🔒

This Privacy Policy ("Policy") describes how ph3611 ("we," "us," "our," or "the Company") collects, uses, stores, shares, and protects the personal information of individuals ("you," "Player," or "User") who access or use the ph3611 online gaming platform at ph3611.co ("the Platform"), including all associated mobile-optimized interfaces and communication channels.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission of the Philippines ("NPC"). This Policy supplements and should be read together with the ph3611 Terms and Conditions.

1 Who We Are

ph3611 is an online gaming and sports betting platform operated in the Philippines in accordance with the regulatory framework administered by the Philippine Amusement and Gaming Corporation ("PAGCOR"). For the purposes of this Policy, ph3611 is the Data Controller — meaning we are the entity that determines the purposes and means by which your personal data is processed.

ph3611 has designated a Data Protection Officer ("DPO") responsible for overseeing data privacy compliance and handling player data rights requests. The DPO can be reached at [email protected] with the subject line "DPO / Data Privacy."

The ph3611 Platform is intended exclusively for adults aged 21 years and above, consistent with PAGCOR's minimum age requirements. We do not knowingly collect or process the personal data of individuals under 21 years of age. See Section 10 for our Children's Privacy policy.

2 Personal Data We Collect

ph3611 collects personal data that is necessary, adequate, and not excessive relative to the purposes for which it is collected. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on a government-issued Philippine ID
• Date of birth (for age verification — must be 21 years or older)
• Valid Philippine mobile number and email address
• Chosen username and encrypted account password
• Nationality and residential address

2.2 Identity Verification (KYC) Data

• Copies or photographs of government-issued Philippine IDs (UMID, Driver's License, Passport, SSS card, PhilSys National ID, etc.)
• Selfie or facial image for liveness verification where required
• Source of funds documentation where required by PAGCOR or AMLC regulations

2.3 Financial & Transaction Data

• GCash account number or registered mobile number associated with GCash or Maya
• Bank account details (BPI, BDO, Metrobank, etc.) used for deposits or withdrawals
• Transaction history: deposits, withdrawals, amounts, dates, and payment method identifiers
• Wallet balance and bonus balance records

2.4 Gaming Activity Data

• Games played, bet amounts, win/loss records, and session timestamps
• Sports betting selections, stake amounts, and settlement records
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

2.5 Technical & Device Data

• IP address at time of login and during session activity
• Device type, operating system version, and browser type
• Mobile network operator (Globe, Smart, DITO, etc.) where identifiable
• Cookies, session tokens, and similar technical identifiers (see Section 7)

2.6 Communications Data

• Records of live chat, email, and Messenger/Viber communications with ph3611 support
• Survey responses, feedback submissions, and complaint records
• Records of promotional opt-in and opt-out preferences

3 How We Collect Your Data

ph3611 collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, respond to a survey, or participate in a promotion.
• Automatically through the Platform: Through cookies, session tracking technology, server logs, and analytics tools that record your technical interaction with ph3611 as described in Section 7.
• From payment service providers: When you initiate a transaction via GCash, Maya, BPI, BDO, Metrobank, or other accepted payment methods, we receive confirmation data necessary to process and record the transaction.
• From identity verification partners: Where ph3611 uses a third-party KYC verification service provider, we may receive the results of document and liveness checks conducted by that provider.
• From regulatory authorities: Where required by PAGCOR, AMLC, or any other Philippine government authority, we may receive information about a Player relevant to regulatory compliance obligations.

4 Why We Use Your Personal Data

ph3611 processes your personal data for the following specific purposes:

"Contract" means processing necessary to perform our agreement with you. "Legal obligation" means processing required by Philippine law or PAGCOR regulation. "Legitimate interest" means processing that serves a genuine business need not overridden by your privacy rights. "Consent" means you have actively opted in.

5 Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, ph3611 processes your personal data on the following legal bases:

• Consent (Section 12(a), DPA): Where you have given specific, informed, and freely given consent for a particular processing activity, such as receiving personalized promotional communications. You may withdraw consent at any time without affecting prior lawful processing.
• Contractual Necessity (Section 12(b), DPA): Processing necessary for the performance of our agreement with you — including account maintenance, payment processing, and access to games and services.
• Legal Obligation (Section 12(c), DPA): Processing required for ph3611 to comply with applicable Philippine law, including PAGCOR licensing conditions, RA 9160 (Anti-Money Laundering Act), RA 10927 (casino reporting obligations), and NPC data governance requirements.
• Legitimate Interest (Section 12(f), DPA): Processing that serves a genuine, proportionate interest of ph3611 — such as fraud prevention, network security, and Platform improvement — where such interests are not outweighed by your fundamental rights and freedoms.

6 Sharing Your Data with Third Parties

ph3611 does not sell your personal data. We share personal data only with the categories of third parties described below, and only to the extent necessary for the stated purpose:

• Payment Service Providers: GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, Metrobank, and other Philippine financial institutions receive transaction data necessary to process deposits and withdrawals. These providers are independently regulated by the Bangko Sentral ng Pilipinas (BSP).
• KYC / Identity Verification Partners: Where ph3611 uses a third-party identity verification service, your ID documents and verification results are shared with that provider under a strict data processing agreement that limits use to KYC purposes only.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other Philippine government authority with lawful authority to receive the data. Disclosure is made only to the extent required by applicable law or valid legal process.
• Game Software Providers: Where game providers operate live dealer tables or RNG game engines on our Platform, they may receive anonymized session and bet data necessary to operate the game. No personally identifiable information is shared beyond what is necessary for game delivery.
• IT Infrastructure and Security Vendors: Cloud hosting providers and cybersecurity partners process technical data under strict contractual data processing agreements with security standards equivalent to or exceeding those applied by ph3611 directly.
• Professional Advisors: Legal counsel, auditors, and compliance consultants may access limited personal data where necessary to provide professional services to ph3611, subject to applicable professional confidentiality obligations.

7 Cookies & Tracking Technologies

ph3611 uses cookies and similar tracking technologies to maintain session integrity, improve Platform performance, and — where you have consented — to deliver relevant promotional content. The following types of cookies are used:

You can manage your cookie preferences at any time through your browser settings. Disabling essential cookies will prevent you from logging into your ph3611 account or using the Platform's core features. ph3611 does not use third-party advertising cookies or behavioral profiling cookies for cross-site tracking.

8 Data Retention

ph3611 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to overriding legal retention requirements. The following retention periods apply:

• Account data (active accounts): Retained for the lifetime of the active account plus five (5) years following account closure, consistent with PAGCOR record-keeping requirements and applicable Philippine anti-money laundering laws.
• KYC / identity verification documents: Retained for a minimum of five (5) years from the date of last transaction, as required by RA 9160 and RA 10927.
• Financial transaction records: Retained for ten (10) years from the date of the transaction, consistent with AMLC regulations.
• Customer support communications: Retained for three (3) years from the date of the communication to support dispute resolution and quality assurance.
• Technical logs and security data: Retained for up to twelve (12) months for routine logs; longer retention may apply where logs are relevant to an active investigation or legal proceeding.
• Marketing preferences and consent records: Retained until consent is withdrawn, plus three (3) years to maintain evidence of prior consent in the event of a complaint.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized (rendered incapable of identifying a specific individual) using industry-standard data destruction procedures.

9 Data Security

ph3611 implements technical and organizational security measures appropriate to the risk posed by the processing of your personal data. These measures include:

• Encryption: All data transmitted between your device and ph3611 servers is protected by TLS 1.3 / 256-bit SSL encryption. Sensitive data stored at rest (including KYC documents and financial records) is encrypted using AES-256.
• Access Controls: Access to personal data within ph3611 systems is restricted on a strict need-to-know basis. All internal access is logged and subject to regular audit.
• Two-Factor Authentication: All ph3611 internal staff systems that access personal data require multi-factor authentication. Players are strongly encouraged to enable 2FA on their accounts.
• Penetration Testing: ph3611's systems undergo regular third-party penetration testing and security audits to identify and address vulnerabilities proactively.
• Data Breach Response: ph3611 maintains a documented Data Breach Response Plan. In the event of a personal data breach that poses a risk to your rights, ph3611 will notify the NPC within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay as required by the DPA.

10 Children's Privacy (Under 21)

The ph3611 Platform is intended solely for adults aged 21 years and above. ph3611 does not knowingly collect, process, or store the personal data of any individual who is under 21 years of age. Persons under 21 are expressly prohibited from registering an account or using any ph3611 service.

ph3611 employs age verification procedures at registration and during the KYC process to prevent access by minors. If ph3611 discovers or is notified that an account has been registered by a person under 21 years of age, all personal data associated with that account will be deleted as promptly as practicable, subject to any overriding legal retention obligations, and the account will be permanently closed.

Parents and guardians who believe a minor may have accessed ph3611 should contact our support team immediately at [email protected]. We take all reports seriously and respond within 48 hours.

11 Your Data Privacy Rights

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights in respect of your personal data held by ph3611:

• Right to be Informed: You have the right to be informed that your personal data is being collected and processed, and to receive clear information about the purposes, scope, and methods of processing — which this Policy provides.
• Right of Access: You may request a copy of the personal data ph3611 holds about you. We will respond within 15 business days of receiving a verified request.
• Right to Rectification: If your personal data is inaccurate, incomplete, or outdated, you have the right to request correction. You can update most account information directly through your ph3611 account settings; for KYC corrections, contact our DPO.
• Right to Erasure / Blocking: You may request deletion or blocking of your personal data where: (a) it is no longer necessary for the purpose it was collected; (b) consent was the sole legal basis and you withdraw consent; or (c) processing is unlawful. Note that legal retention obligations may prevent immediate full deletion.
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes. Opt-out from marketing communications is available in your account settings at any time.
• Right to Data Portability: You may request that ph3611 provide your personal data in a commonly used, machine-readable format for transfer to another service, where technically feasible.
• Right to File a Complaint: If you believe ph3611 has processed your personal data in violation of the DPA, you may file a complaint with the National Privacy Commission of the Philippines. ph3611 requests that you first raise concerns with our DPO to allow for prompt internal resolution.

To exercise any of these rights, submit a written request to [email protected] with the subject "Data Privacy Request," your registered account username, and a description of the specific right you wish to exercise. We may require identity verification before processing any rights request.

12 Cross-Border Data Transfers

Where ph3611 uses cloud infrastructure, software services, or partner providers located outside the Philippines, personal data may be transferred to and processed in other countries. ph3611 ensures that any cross-border data transfer is conducted in compliance with Section 21 of the Data Privacy Act of 2012 and the NPC's cross-border data transfer regulations, specifically by:

• Entering into data processing agreements with all international service providers that impose security and data handling obligations at least equivalent to those required under Philippine law.
• Limiting cross-border data transfers to countries, organizations, or providers that offer an adequate level of data protection as assessed by the NPC or recognized under applicable Philippine law.
• Ensuring that all international transfers are limited to the minimum data necessary for the specific processing purpose and are not further processed for unrelated purposes.

Players may request information about the specific countries to which their personal data may be transferred by contacting the ph3611 DPO.

13 Amendments to This Policy

ph3611 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. Material changes — those that meaningfully affect your rights or ph3611's obligations — will be communicated to Players via email to the registered account address and via a prominent notice on the Platform at least 14 days before the amended Policy takes effect.

Non-material changes (such as clarifications of existing provisions, corrections of typographical errors, or updates to reflect new contact details) may take effect immediately upon publication without prior individual notice.

Your continued use of the ph3611 Platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically. The version number and "Last updated" date at the top of this Policy indicate when it was last revised.

14 Contact Us & the DPO

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph3611, please contact our Data Protection Officer using the details below. Our DPO and support team are available in both English and Tagalog.

• DPO Contact Email: [email protected] — Subject: "DPO / Data Privacy"
• Live Chat: Available directly on the ph3611 Platform, 24 hours a day, 7 days a week. Average response: 3–5 minutes.
• Response Commitment: ph3611 acknowledges all data privacy requests within 48 hours and provides a substantive response within 15 business days.
• Regulatory Authority: If you remain unsatisfied after contacting ph3611, you may escalate your concern to the National Privacy Commission of the Philippines.