ph636 Privacy Policy

ph636 takes the privacy of its members seriously. This Privacy Policy ("Policy") describes how ph636 ("ph636", "we", "us", "our") processes personal data collected from users ("Member", "Player", "You") who access, register on, or use the ph636 online casino platform at ph636.club ("Platform"). Please read this Policy carefully. By using the Platform, you acknowledge that you have read, understood, and agree to the data processing practices described herein.

1. Who We Are (Data Controller)

ph636 is the data controller responsible for the personal data collected through the Platform. As data controller, ph636 determines the purposes and means of processing your personal data and is accountable under the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

For all privacy-related inquiries, you may contact our Data Protection Officer (DPO) at the contact details provided in Section 15 of this Policy.

2. Personal Data We Collect

ph636 collects the following categories of personal data from members and prospective members:

2.1 Identity Data

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth
• Gender (where provided)
• Government-issued identification number (e.g., PhilSys ID, UMID, driver's license, passport number)
• Copies of identification documents submitted for KYC verification
• Selfie or biometric photographs (where required for enhanced verification)

2.2 Contact Data

• Philippine mobile number (primary account identifier)
• Email address (where provided)
• Residential address (for KYC purposes)

2.3 Financial Data

• GCash or Maya / PayMaya account number or registered mobile number
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where used for transactions
• Deposit and withdrawal transaction records denominated in Philippine Peso (PHP)

2.4 Gaming & Behavioral Data

• Bet history, game session data, win/loss records
• Game preferences, favorite titles, and session duration
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion requests)

2.5 Technical Data

• IP address and geolocation data
• Device type, operating system, browser type and version
• Login timestamps, session duration, and access logs
• Cookies and similar tracking technologies (see Section 10)

2.6 Communications Data

• Records of your communications with ph636 customer support (live chat transcripts, email correspondence)
• Feedback, survey responses, and complaints

3. How We Collect Your Personal Data

ph636 collects personal data through the following means:

• Direct submission — when you register an account, complete KYC verification, make deposits or withdrawals, contact customer support, or participate in promotions.
• Automated technical collection — through cookies, server logs, and similar technologies when you browse or use the Platform.
• Third-party sources — from payment processors (GCash, Maya), identity verification service providers, fraud prevention databases, and PAGCOR's regulatory registers, where applicable.

4. How We Use Your Personal Data

ph636 processes your personal data for the following purposes:

• Account creation and management — to register, authenticate, and administer your ph636 account.
• Identity verification (KYC/AML) — to verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine anti-money laundering laws (RA 9160, as amended).
• Transaction processing — to facilitate GCash and Maya deposits, withdrawals, and internal wallet transfers.
• Gameplay and service delivery — to provide access to casino games, live dealer tables, sports betting, and promotional offers.
• Responsible gaming compliance — to monitor gaming behavior, enforce deposit limits and self-exclusion requests, and detect signs of problem gambling.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, unauthorized access, and money laundering.
• Customer support — to respond to your inquiries, complaints, and support requests.
• Legal compliance — to meet obligations under PAGCOR regulations, RA 10173, RA 9160, and other applicable Philippine laws.
• Marketing communications — to send promotional offers and casino updates, subject to your communication preferences. You may opt out at any time.
• Platform improvement — to analyze usage patterns and improve the ph636 user experience.

5. Legal Basis for Processing

ph636 processes your personal data on the following legal bases as recognized under RA 10173:

• Contractual necessity — processing is necessary to perform the Terms & Conditions agreement between you and ph636, including account management and payment processing.
• Legal obligation — processing is required to comply with PAGCOR regulations, Philippine AML laws, and NPC requirements.
• Legitimate interests — processing for fraud prevention, security monitoring, and platform improvement, where such interests do not override your privacy rights.
• Consent — for marketing communications and non-essential cookies, where ph636 relies on your explicit consent, which you may withdraw at any time.

6. Data Sharing & Disclosure

ph636 does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors — GCash (GXI / G-Xchange Inc.), Maya (Paymaya Philippines Inc.), and other payment providers to facilitate transactions.
• Identity verification providers — third-party KYC and AML screening service providers operating under data processing agreements with ph636.
• Game content providers — JILI Games, PG Soft, Evolution Gaming, Asia Gaming, and other game studios to enable gameplay. These providers process only the technical data required to deliver game outcomes.
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine competent authorities, as required by law.
• IT and infrastructure providers — cloud hosting, cybersecurity, and analytics service providers engaged by ph636 under binding data processing agreements.
• Legal advisors and auditors — where disclosure is necessary for legal proceedings, regulatory audits, or tax compliance.

All third parties with whom ph636 shares personal data are required to implement appropriate security measures and to process such data solely for the purposes specified by ph636.

7. International Data Transfers

Some of ph636's service providers and game content partners are located outside the Philippines. Where personal data is transferred to countries that may not provide an equivalent level of data protection as Philippine law, ph636 implements appropriate safeguards, including contractual clauses approved by the NPC or equivalent, to ensure that your personal data is adequately protected. ph636 will not transfer your personal data internationally without a lawful basis under RA 10173.

8. Data Retention

ph636 retains your personal data for as long as your account is active and for such period thereafter as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• KYC/identity documents — retained for a minimum of five (5) years following account closure, as required by PAGCOR and Philippine AML regulations.
• Transaction records — retained for a minimum of five (5) years following the date of the transaction.
• Gaming session logs — retained for a minimum of three (3) years.
• Customer support communications — retained for a minimum of two (2) years.

Upon expiry of the applicable retention period, ph636 will securely delete or anonymize your personal data.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by ph636:

• Right to be Informed — to know whether ph636 processes your personal data and the details of such processing.
• Right of Access — to obtain a copy of your personal data held by ph636.
• Right to Rectification — to request correction of inaccurate or incomplete personal data.
• Right to Erasure / Blocking — to request deletion or blocking of your personal data where processing is no longer necessary or lawful, subject to ph636's legal retention obligations.
• Right to Object — to object to the processing of your personal data for direct marketing purposes.
• Right to Data Portability — to receive a structured, machine-readable copy of the personal data you have provided to ph636.
• Right to Lodge a Complaint — to file a complaint with the National Privacy Commission (NPC) if you believe ph636 has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at the details in Section 15. ph636 will respond to verified requests within thirty (30) days of receipt.

10. Cookies & Similar Technologies

ph636 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyze usage patterns. The categories of cookies used include:

• Strictly necessary cookies — required for the Platform to function (e.g., session management, login authentication). These cannot be disabled.
• Functional cookies — remember your preferences such as language settings and game display options.
• Analytics cookies — collect anonymized data about how members use the Platform to help us improve its performance and usability.

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality. ph636 does not use cookies to serve advertising on behalf of third parties.

11. Children's Privacy

ph636 strictly prohibits access to or use of the Platform by any person under the age of 21, as mandated by PAGCOR for all licensed online gambling in the Philippines. ph636 does not knowingly collect personal data from individuals under 21 years of age. If ph636 becomes aware that personal data of an under-age individual has been collected, such data will be deleted immediately and the account will be permanently closed. Age verification is conducted as part of the mandatory KYC process for all ph636 accounts.

12. Data Security

ph636 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• TLS/SSL encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including payment credentials and identification documents.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of Platform infrastructure.
• Two-factor authentication (2FA) available to members for account login.

In the event of a personal data breach that is likely to pose a risk to your rights and freedoms, ph636 will notify the National Privacy Commission and affected members in accordance with the timelines prescribed by RA 10173 and the NPC's Breach Notification Guidelines.

13. Third-Party Links

The ph636 platform does not contain links to external third-party websites. If ph636 ever incorporates such links in the future, please be aware that ph636 has no control over the privacy practices of third-party websites and this Privacy Policy does not apply to those sites. You should review the privacy policy of any third-party site you visit independently.

14. Changes to This Privacy Policy

ph636 reserves the right to update this Privacy Policy at any time to reflect changes in legal requirements, regulatory guidance, or our data processing practices. Material changes will be communicated to registered members via email or in-platform notification at least seven (7) days before the revised Policy takes effect. The "Last updated" date at the top of this Policy will be revised accordingly. Continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Policy.

15. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph636, please contact our Data Protection Officer:

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 inside your ph636 member dashboard after login.

ph636 aims to respond to all data privacy requests within thirty (30) calendar days of receipt. If you are not satisfied with ph636's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).