Who We Are
36phppg is an online casino and sports betting platform operating at https://36phppg.net, licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR). For the purposes of this Privacy Policy, 36phppg acts as the Personal Information Controller as defined under Republic Act No. 10173 (the Data Privacy Act of 2012) and its Implementing Rules and Regulations.
As a regulated gaming operator, 36phppg is subject to oversight by PAGCOR and the Anti-Money Laundering Council (AMLC), and is required by law to collect and retain certain categories of player data as a condition of our operating license. This Privacy Policy explains how we fulfil those obligations while respecting your rights as a data subject.
If you have any questions about how 36phppg handles your personal data, our Data Protection Officer (DPO) can be reached at [email protected].
Data We Collect
36phppg collects the following categories of personal data from registered players and platform visitors:
| Category | Examples | Required? |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, government-issued ID number (PhilSys, passport, UMID, driver's licence) | Mandatory (KYC) |
| Contact Data | Email address, Philippine mobile number, residential address (barangay, city/municipality, province) | Mandatory |
| Account Data | Username, hashed password, account preferences, communication opt-ins, responsible gaming settings | Mandatory |
| Financial Data | GCash number, PayMaya account reference, BDO/BPI/Metrobank account name and last 4 digits, transaction history, deposit and withdrawal records | Mandatory |
| Gaming Data | Game activity logs, bet history, win/loss records, session duration, responsible gaming tool usage | Automatic |
| Technical Data | IP address, device type, operating system, browser type, geolocation (city/region level), login timestamps | Automatic |
| Verification Documents | Scanned or photographed copies of government-issued Philippine IDs, selfie with ID (liveness check), proof of address documents | Mandatory (KYC) |
| Communications Data | Records of support chat conversations, email correspondence, complaint history, feedback submissions | As applicable |
We do not collect sensitive personal information — such as religious beliefs, political affiliations, or biometric data beyond what is required for identity verification — unless explicitly required by law or with your specific consent.
How We Collect Your Data
3.1 Direct Collection
Most of your personal data is collected directly from you when you: register an account on 36phppg; complete the KYC identity verification process; make a deposit or withdrawal; contact our customer support team; respond to a promotional survey or feedback request; or update your account profile.
3.2 Automated Collection
When you access and use the 36phppg platform, certain technical and gaming data is collected automatically through our systems. This includes your IP address, device identifiers, browser details, session logs, gameplay records, and platform interaction data. This automated collection is necessary for platform security, fraud detection, and regulatory compliance.
3.3 Third-Party Sources
In limited circumstances, 36phppg may receive data about you from authorised third-party sources, including: payment processors who confirm transaction details; identity verification service providers who assist with KYC checks; and PAGCOR or law enforcement authorities in connection with regulatory enquiries. Any such data received is handled in accordance with this Privacy Policy.
Why We Process Your Data
36phppg processes your personal data for the following purposes:
- Account Registration and Management: To create, maintain, and administer your 36phppg player account, including processing deposits, withdrawals, and gaming activity.
- Identity Verification (KYC): To comply with PAGCOR licensing requirements and the Philippine Anti-Money Laundering Act (RA 9160, as amended) by verifying the identity of all registered players.
- Fraud Prevention and Platform Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, collusion, and other prohibited conduct on the platform.
- Regulatory Compliance: To fulfil our obligations to PAGCOR, the AMLC, the Bureau of Internal Revenue (BIR), the National Privacy Commission (NPC), and other applicable Philippine regulatory authorities.
- Responsible Gaming: To monitor gaming behaviour, flag potential problem gambling patterns, enforce self-exclusion and cooling-off period requests, and ensure the 21+ age requirement is maintained across all accounts.
- Customer Support: To respond to your enquiries, resolve disputes, process complaints, and provide 24/7 Filipino-language support services.
- Platform Improvement: To analyse aggregated, anonymised usage data in order to improve game performance, user experience, and platform stability.
- Marketing and Promotions: To send you relevant promotional offers, bonus notifications, and platform updates — only where you have provided consent or where we have a legitimate interest, and always with an easy opt-out mechanism.
Legal Bases for Processing
Under the Data Privacy Act of 2012, 36phppg processes your personal data on the following legal grounds:
- Contractual Necessity: Processing required to fulfil our obligations under the Terms and Conditions you accepted upon registration — including account management, deposits, withdrawals, and gaming services.
- Legal Obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws.
- Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where these interests are not overridden by your rights as a data subject.
- Consent: Processing for direct marketing communications, optional personalisation features, and any other purpose for which we specifically seek your opt-in. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Cookies & Tracking Technologies
36phppg uses cookies and similar tracking technologies on its platform. Cookies are small text files placed on your device that help us deliver a functional, secure, and personalised gaming experience.
6.1 Types of Cookies We Use
- Strictly Necessary Cookies: Essential for platform operation — including authentication, session management, and security. These cannot be disabled.
- Performance Cookies: Collect anonymised information about how players use the platform (e.g., pages visited, game load times) to help us improve performance.
- Functionality Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations.
- Analytics Cookies: Help us understand aggregate usage patterns. Data collected is anonymised and not associated with individual player profiles for marketing purposes.
36phppg does not use third-party advertising or retargeting cookies. You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect platform functionality.
Sharing Your Personal Data
36phppg does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances:
- Regulated Payment Processors: GCash, PayMaya, BDO, BPI, Metrobank, and InstaPay receive the minimum data necessary to process your deposits and withdrawals securely.
- KYC and Identity Verification Providers: Authorised third-party providers who assist in verifying your identity documents in compliance with PAGCOR and AMLC requirements.
- Technology and Hosting Partners: Secure cloud hosting and infrastructure providers who process data on 36phppg's behalf under strict data processing agreements and confidentiality obligations.
- Game Content Providers: Licensed game studios whose products are hosted on the 36phppg platform may receive aggregated, anonymised gameplay data for audit and certification purposes.
- Regulatory Authorities: PAGCOR, the AMLC, the NPC, the BIR, and Philippine law enforcement agencies where disclosure is required or permitted by law — including in connection with anti-money laundering investigations or court orders.
- Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by 36phppg, who are bound by professional confidentiality obligations.
International Data Transfers
36phppg's primary operations and data storage are based in the Philippines. Where it is necessary to transfer personal data outside the Philippines — for example, to cloud infrastructure providers or game platform partners whose servers are located in other jurisdictions — 36phppg ensures that such transfers comply with the requirements of the Data Privacy Act of 2012 and the implementing rules of the National Privacy Commission.
Specifically, cross-border data transfers are permitted only where: the receiving jurisdiction provides an adequate level of data protection comparable to Philippine standards; or appropriate contractual safeguards (such as Standard Contractual Clauses) are in place between 36phppg and the receiving entity; or the transfer is required by law or is necessary for the performance of a contract with you.
You may request details of any international transfers of your personal data, including the countries involved and the safeguards in place, by contacting [email protected].
Data Retention
36phppg retains your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, subject to the following regulatory minimums that we are legally required to observe:
| Data Category | Retention Period | Regulatory Basis |
|---|---|---|
| KYC / Identity Documents | 5 years after account closure | PAGCOR regulations; RA 9160 (AMLA) |
| Financial Transaction Records | 5 years from transaction date | RA 9160 (AMLA); BIR requirements |
| Gaming Activity Logs | 3 years from account closure | PAGCOR audit requirements |
| Customer Support Records | 3 years from last interaction | Dispute resolution; PAGCOR compliance |
| Marketing Consent Records | Duration of consent + 1 year | NPC regulations; accountability requirement |
| Technical / Server Logs | 12 months on a rolling basis | Security and fraud investigation purposes |
Once the applicable retention period has expired and no overriding legal obligation exists, personal data is securely and permanently deleted or anonymised in a manner that prevents re-identification.
Security Measures
36phppg implements a comprehensive set of technical, organisational, and physical security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:
- 256-bit TLS/SSL Encryption on all data transmission between your browser or app and our servers
- AES-256 Encryption at Rest for all stored personal data, financial records, and identity documents
- Multi-Factor Authentication (MFA) available for player accounts and mandatory for all internal administrative access
- Role-Based Access Controls ensuring that only authorised 36phppg personnel with a legitimate need can access player personal data
- Regular Penetration Testing and Security Audits conducted by independent third-party security firms
- DDoS Protection and Web Application Firewall (WAF) to protect platform availability and integrity
- Incident Response Plan to ensure rapid detection, containment, and notification in the event of a security breach
- Staff Privacy and Security Training for all 36phppg employees who handle personal data
While 36phppg takes all reasonable steps to secure your data, no online system is completely immune to security risks. You also play an important role in keeping your account safe — please use a strong, unique password and never share your login credentials with anyone.
Children's Privacy and the 21+ Requirement
The 36phppg platform is strictly for individuals who are 21 years of age or older, in accordance with Philippine law and PAGCOR regulations governing online gambling. 36phppg does not knowingly collect, process, or store personal data from individuals under the age of 21.
During the registration process, all applicants are required to declare their date of birth and submit government-issued ID for KYC verification. Any account found to have been registered by a person under 21 years of age will be immediately suspended, and all personal data associated with that account will be securely deleted in accordance with applicable law, except where retention is required for regulatory audit purposes.
If you believe that a minor has registered an account on 36phppg, please notify us immediately at [email protected]. We take the protection of minors extremely seriously and will investigate all such reports without delay.
Marketing Communications
36phppg may send you promotional emails, SMS notifications, and in-platform messages about bonuses, new games, seasonal promotions, and platform updates. We will only send you direct marketing communications where:
- You have provided explicit consent during registration or in your account settings, or
- You are an existing registered player and the communication relates to products and services similar to those you have already used (soft opt-in), subject to your right to object at any time.
Every marketing communication from 36phppg includes a clear and easy unsubscribe mechanism. You may opt out of all marketing communications at any time by:
- Clicking the "Unsubscribe" link in any marketing email;
- Replying STOP to any SMS promotional message;
- Updating your communication preferences in your 36phppg account settings; or
- Sending a written opt-out request to [email protected].
Opting out of marketing communications does not affect your ability to use the 36phppg platform, and you will continue to receive transactional messages related to your account (e.g., deposit confirmations, withdrawal notifications, security alerts) regardless of your marketing preferences.
Exercising Your Rights
To exercise any of your rights under the Philippine Data Privacy Act of 2012 — including the rights to access, correct, erase, restrict, object to, or port your personal data — please submit a written request to our Data Protection Officer at [email protected].
Your request should include your full name, registered email address, and a clear description of the right you wish to exercise and the data concerned. We may need to verify your identity before processing your request to protect against unauthorised access to your personal data.
We will acknowledge your request within 5 business days and aim to resolve it within 30 calendar days. In complex cases, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.
If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act.
Changes to This Privacy Policy
36phppg reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When we make material changes, we will:
- Post the updated Privacy Policy on this page with a revised effective date;
- Display a prominent notice on the 36phppg platform informing players of the update; and
- Where the changes are significant, send a direct notification to your registered email address at least 14 days before the changes take effect.
Your continued use of the 36phppg platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you should stop using the platform and may request account closure by contacting our support team.
We encourage you to review this Privacy Policy periodically to stay informed about how 36phppg protects your personal data. The date at the top of this page always reflects when the policy was last reviewed and updated.
Contact & Complaints
If you have any questions, concerns, or complaints about this Privacy Policy or about how 36phppg handles your personal data, please contact our Data Protection Officer:
Data Protection Officer — 36phppg
Email: [email protected]
Response time: Within 5 business days
Platform: https://36phppg.net
If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC is the government authority responsible for administering and enforcing the Data Privacy Act of 2012.