phl365 Privacy Policy

1. Introduction

1.1   phl365 ("the Company," "we," "us," "our") is committed to protecting the privacy and personal data of all individuals who interact with the phl365 Platform. This Privacy Policy ("Policy") describes our practices concerning the collection, use, storage, sharing, and protection of personal data in connection with phl365.vip and all associated services.

1.2   This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

1.3   By registering for a phl365 account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must refrain from using the phl365 Platform.

2. Data Controller

2.1   phl365 acts as the personal information controller in respect of the personal data of all registered players and website visitors. As data controller, phl365 determines the purposes and means of processing your personal data.

2.2   phl365 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and with applicable data protection legislation. Contact details for the DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

3.1   phl365 collects the following categories of personal data:

3.1.1 Identity Data

• Full legal name;
• Date of birth;
• Government-issued identification document number and type (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys national ID, voter's ID);
• Photograph or scan of identification document (for KYC verification purposes).

3.1.2 Contact Data

• Philippine mobile number;
• Email address;
• Residential address (for identity verification and AML compliance purposes).

3.1.3 Financial Data

• Deposit and withdrawal transaction history;
• Payment method identifiers (e.g., GCash mobile number, bank account name — we do not store full bank account numbers or card numbers);
• Account wallet balance history.

3.1.4 Gameplay Data

• Game history, bet records, session logs, and wagering activity;
• Bonus and promotion redemption history;
• Responsible gaming tool usage (e.g., deposit limit settings, self-exclusion requests).

3.1.5 Technical Data

• IP address;
• Device type, operating system, and browser information;
• Session timestamps and duration;
• Cookie and tracking technology data (see Section 11).

3.1.6 Communications Data

• Records of customer support interactions, including live chat transcripts and email correspondence;
• Marketing preference records.

4. How We Collect Personal Data

4.1   phl365 collects personal data through the following means:

• Directly from you — when you register a phl365 account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey or promotion;
• Automatically — through cookies, server logs, and tracking technologies as you navigate and use the phl365 Platform;
• From third parties — from identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), and fraud prevention services engaged by phl365 for compliance and security purposes.

5. Legal Basis for Processing

5.1   phl365 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity — processing required to fulfill our obligations under the phl365 Terms & Conditions, including account management, gameplay, and payment processing;
• Legal obligation — processing required for compliance with PAGCOR regulations, AML obligations under Republic Act No. 9160 (as amended), and the Data Privacy Act;
• Legitimate interests — processing for fraud prevention, security monitoring, platform analytics, and improvement of the phl365 service, where such interests are not overridden by your rights;
• Consent — processing for direct marketing communications, where you have provided freely given, specific, informed, and unambiguous consent, which you may withdraw at any time.

6. How We Use Your Personal Data

6.1   phl365 uses your personal data for the following purposes:

• To create, verify, and manage your phl365 player account;
• To process deposits, withdrawals, and in-platform transactions;
• To conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by PAGCOR and Philippine law;
• To provide customer support and resolve disputes;
• To enforce the phl365 Terms & Conditions and detect prohibited conduct, fraud, or collusion;
• To deliver responsible gaming tools and comply with responsible gaming obligations, including age verification;
• To send account-related communications (transaction confirmations, security alerts, policy updates);
• To send promotional and marketing communications where you have provided consent;
• To analyze platform usage, improve game offerings, and optimize user experience;
• To comply with applicable laws, regulations, and lawful orders from regulatory authorities.

7. Data Sharing & Disclosure

7.1   phl365 does not sell your personal data. We may share personal data with third parties only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment service providers (GCash, PayMaya, BPI, BDO, Metrobank) — to process deposits and withdrawals;
• Identity verification and KYC service providers — to authenticate identity documents and conduct AML screening;
• Game content providers — game providers whose titles are offered on the phl365 Platform may receive gameplay data necessary for game operation and certification audits;
• Regulatory and law enforcement authorities — including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies, where disclosure is required by applicable law or a lawful order;
• Professional advisers — lawyers, auditors, and compliance consultants engaged by phl365 under contractual confidentiality obligations;
• Business successors — in the event of a merger, acquisition, or sale of phl365 assets, personal data may be transferred subject to equivalent privacy protections.

7.2   All third parties with whom phl365 shares personal data are required to handle such data in accordance with applicable privacy laws and are subject to appropriate data processing agreements.

8. International Data Transfers

8.1   Some of phl365's service providers may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection, phl365 will implement appropriate safeguards, such as standard contractual clauses approved by the National Privacy Commission, to ensure that your data remains protected to the standard required by the Data Privacy Act of 2012.

8.2   By using the phl365 Platform, you acknowledge and consent to such international transfers where necessary for service delivery, subject to the safeguards described in this Section.

9. Data Retention

9.1   phl365 retains personal data for as long as necessary to fulfill the purposes set out in this Policy, unless a longer retention period is required or permitted by applicable law. The following general retention periods apply:

• Account and identity data — retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by AML regulations;
• Transaction and financial data — retained for a minimum of five (5) years from the date of transaction, in compliance with AMLC record-keeping requirements;
• Customer support records — retained for three (3) years from the date of the interaction;
• Marketing preference records — retained until consent is withdrawn or the account is closed, whichever occurs first.

9.2   When personal data is no longer required for the purposes for which it was collected and no legal obligation requires further retention, phl365 will securely delete or anonymize such data.

10. Security Measures

10.1   phl365 implements technical and organizational security measures designed to protect personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and phl365 servers;
• AES-256 encryption for personal and financial data stored at rest;
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Two-factor authentication for administrative system access;
• Incident response procedures aligned with NPC breach notification requirements.

10.2   In the event of a personal data breach that poses a risk to your rights and freedoms, phl365 will notify the National Privacy Commission and affected data subjects in accordance with the timelines prescribed under the Data Privacy Act and NPC Circular 16-03.

11. Cookies & Tracking Technologies

11.1   phl365 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit phl365.vip. We use the following categories of cookies:

• Strictly necessary cookies — essential for the Platform to function, including session management and login authentication. These cannot be disabled;
• Functional cookies — store your preferences (e.g., language, display settings) to improve your experience;
• Analytics cookies — collect aggregated, anonymized data on how players navigate the Platform, used to improve content and performance;
• Security cookies — detect fraud, unauthorized account access, and platform abuse.

11.2   You may manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the phl365 Platform.

12. Your Rights as a Data Subject

12.1   Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phl365:

12.2   To exercise any of the above rights, please submit a written request to the phl365 Data Protection Officer using the contact details provided in Section 15. phl365 will respond to all verified data subject requests within fifteen (15) working days of receipt, or within the timeframe prescribed by the NPC where applicable.

12.3   Where phl365 is unable to fulfill a data subject request — for example, where retention is required by law — we will explain the basis for refusal in writing.

12.4   If you believe phl365 has not adequately addressed your privacy concerns, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

13. Children's Privacy

13.1   The phl365 Platform is strictly intended for individuals aged 21 years and above. phl365 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an underage individual, we will immediately suspend the relevant account, delete the associated data, and, where required, report the matter to the appropriate authority.

13.2   If you have reason to believe that a minor has registered an account or provided personal data to phl365, please contact our Data Protection Officer immediately.

14. Changes to This Privacy Policy

14.1   phl365 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on phl365.vip at least seven (7) days before the changes take effect.

14.2   The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Continued use of the phl365 Platform following the effective date of any update constitutes acceptance of the revised Policy.

15. Contact & Data Protection Officer

15.1   For questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by phl365, please contact our Data Protection Officer:

15.2   Please include "Privacy Request" in your subject line and provide sufficient information to identify your phl365 account so we can process your request efficiently.