Privacy Policy — ph3611 Data Protection

ph3611 ("we", "us", "our", or the "Platform") operates the online gaming platform available at ph3611.net. We understand that your personal information is important to you, and we take our responsibility as a data controller seriously.

This Privacy Policy describes how ph3611 collects, uses, stores, shares, and protects the personal data of users ("you", "your", or "Player") who register for or use the ph3611 Platform. It applies to all personal data collected through the ph3611 website, mobile application, and any related services.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. By registering on or using the ph3611 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, ph3611 is the Personal Information Controller in respect of the personal data collected through the Platform. ph3611 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

ph3611 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection legislation. Contact details for the DPO are provided in Section 14 of this Policy.

ph3611 collects the following categories of personal data from players, depending on the nature of your interaction with the Platform:

3.1 Identity & Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth (for age verification — players must be 21 or older)
• Nationality and country of residence
• Valid email address
• Philippine mobile number
• Residential address (including barangay, city, province, and ZIP code)

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, PhilHealth ID, UMID, driver's license, or Voter's ID)
• Proof of address documents (e.g., utility bill, bank statement, or barangay certificate)
• Selfie or liveness check images submitted during identity verification

3.3 Financial & Payment Data

• GCash or PayMaya mobile wallet number (last four digits stored; full number processed by the payment provider)
• Bank account details for BPI, BDO, or Metrobank transfers (account name and last four digits)
• Transaction history, including deposit amounts, withdrawal amounts, dates, and reference numbers

3.4 Gaming Activity Data

• Game session logs, including games played, bet amounts, win/loss outcomes, and session duration
• Bonus and promotion usage history
• Responsible gaming settings and self-exclusion records

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type and version
• Unique device identifiers
• Login timestamps and session activity logs

3.6 Communications Data

• Records of your communications with ph3611 customer support, including chat transcripts and email correspondence
• Survey responses and feedback submitted voluntarily

ph3611 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated collection: Technical and device data collected automatically when you access the Platform, through server logs, cookies, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data confirmed through our KYC service providers; payment transaction data confirmed through GCash, PayMaya, BPI, BDO, and Metrobank; fraud prevention data from anti-fraud service providers.

ph3611 does not collect personal data from social media platforms or purchase personal data from data brokers.

ph3611 uses the personal data it collects for the following purposes:

ph3611 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing another lawful basis for processing.

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

• Contractual necessity: Processing required to perform the contract between you and ph3611 — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, tax reporting obligations, and gaming regulatory requirements.
• Legitimate interests: Processing necessary for ph3611's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Where ph3611 relies on your consent as the legal basis for processing — such as for optional marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ph3611 does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Service Providers

ph3611 engages trusted third-party service providers to assist in operating the Platform, including KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), cloud hosting and infrastructure providers, fraud detection and cybersecurity providers, and customer support platform providers. All service providers are contractually bound to process personal data only on ph3611's instructions and to maintain appropriate security standards.

7.2 Game Content Providers

Certain games on the ph3611 Platform are provided by licensed third-party game studios. These providers may receive limited technical data (such as session tokens and bet amounts) necessary to deliver the game experience. They do not receive your full identity or payment data.

7.3 Regulatory & Law Enforcement Authorities

ph3611 may disclose personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law, court order, or regulatory directive — including disclosures required under the Anti-Money Laundering Act (AMLA) and its amendments.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of ph3611's assets, your personal data may be transferred to the acquiring entity. ph3611 will notify affected players of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

ph3611 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, maintain your session, and understand how you use the Platform.

8.1 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming limits you have set.
• Analytics cookies: Help ph3611 understand how players navigate the Platform so we can improve the user experience. Data collected is aggregated and anonymized where possible.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts.

8.2 Managing Cookies

You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph3611 Platform. Strictly necessary and security cookies cannot be disabled as they are essential to the secure operation of the Platform.

ph3611 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Financial transaction records: Retained for a minimum of five (5) years in accordance with AMLA requirements.
• Gaming activity logs: Retained for three (3) years from the date of the activity, or longer if required for dispute resolution or regulatory purposes.
• Customer support communications: Retained for two (2) years from the date of the last communication.
• Technical and device logs: Retained for twelve (12) months from the date of collection.

Upon expiry of the applicable retention period, ph3611 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by ph3611:

• Right to be informed: The right to be notified of how your personal data is being collected and processed — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data ph3611 holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data ph3611 holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ph3611's legal retention obligations.
• Right to object: The right to object to the processing of your personal data where ph3611 relies on legitimate interests as the legal basis, or where your data is being processed for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe ph3611 has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact the ph3611 Data Protection Officer using the contact details in Section 14. ph3611 will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

ph3611 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS 1.3): All data in transit between your device and ph3611 servers is encrypted using industry-standard TLS 1.3 protocols.
• Data encryption at rest: Sensitive personal data stored on ph3611 servers is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized ph3611 personnel on a strict need-to-know basis. All access is logged and regularly audited.
• Multi-factor authentication: Administrative access to systems containing personal data requires multi-factor authentication.
• Regular security audits: ph3611 conducts regular internal and third-party security assessments, penetration testing, and vulnerability scans.
• Incident response plan: ph3611 maintains a documented data breach response plan and will notify affected players and the NPC in accordance with the Data Privacy Act in the event of a qualifying breach.

While ph3611 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your account credentials and for notifying ph3611 immediately if you suspect unauthorized access to your account.

The ph3611 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. ph3611 does not knowingly collect personal data from persons under the age of 21.

If ph3611 becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all personal data associated with that account will be deleted, and any funds in the account will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that your child has registered on the ph3611 Platform, please contact our support team immediately using the contact details in Section 14 so that we can take prompt action.

ph3611 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. When material changes are made, ph3611 will notify registered players by email or through an in-platform notification at least seven (7) days before the changes take effect, where reasonably practicable.

The most current version of this Privacy Policy will always be available at ph3611.net/privacy-policy. The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the ph3611 Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

If you do not agree to the amended Privacy Policy, you must cease using the Platform and may request account closure and deletion of your personal data, subject to ph3611's legal retention obligations.

If you have 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 (DPO) or our general support team. We aim to respond to all privacy-related inquiries within fifteen (15) business days.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012 in the Philippines.

When contacting ph3611 regarding a data privacy matter, please include your registered account username, a clear description of your request or concern, and any relevant reference numbers to help us handle your inquiry promptly and accurately.