ph636 Privacy Policy

1 Who We Are

ph636 ("ph636," "we," "our," or "us") operates the online gaming and casino platform accessible at ph636.org. ph636 is committed to protecting the personal information of all users who access or register on the platform, particularly Filipino players for whom the platform is primarily designed.

For the purposes of the Republic Act 10173 (Data Privacy Act of 2012), ph636 acts as the Personal Information Controller (PIC) with respect to the personal data of registered players and visitors to ph636.org. ph636 has designated a Data Protection Officer (DPO) who is responsible for ensuring compliance with the DPA and overseeing data privacy practices across the platform.

2 Scope of This Policy

This Privacy Policy applies to:

• All registered players who hold an active or previously active account on ph636.org;
• Visitors to ph636.org who have not registered an account, to the extent that ph636 collects browsing data through cookies and similar technologies;
• Individuals who contact ph636 customer support, whether or not they hold a registered account;
• Persons who subscribe to ph636 promotional communications.

This Policy does not apply to third-party websites, platforms, or services that may be linked from ph636.org. ph636 has no control over and is not responsible for the privacy practices of third parties.

3 Personal Data We Collect

ph636 collects different categories of personal data depending on your relationship with the platform. The following table summarizes the principal data categories and what they include:

4 How We Collect Your Data

ph636 collects personal data through the following channels and means:

• Direct Provision: Information you voluntarily provide when registering an account, completing KYC verification, updating your profile, or contacting customer support.
• Automated Technical Collection: Data collected automatically when you access ph636.org, including IP address, device identifiers, session data, and browsing behavior within the platform, through cookies and server logs.
• Payment Providers: Confirmation and reference data from payment processing partners (such as GCash and Maya) relating to deposits and withdrawal transactions. ph636 does not receive or store full payment credentials such as PINs or passwords for third-party payment accounts.
• Game Providers: Session and outcome data from integrated third-party game providers as required for transaction records, dispute resolution, and responsible gaming monitoring.
• Identity Verification Services: Where applicable, ph636 may use third-party identity verification services to assist with KYC compliance. These services process submitted documents on behalf of ph636 under data processing agreements.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, ph636 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between ph636 and the player — including account creation, game access, payment processing, and withdrawal disbursement.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including PAGCOR regulatory requirements, Anti-Money Laundering Act (AMLA) obligations, and tax reporting requirements.
• Legitimate Interest: Processing necessary for ph636's legitimate business interests, such as fraud prevention, platform security monitoring, and responsible gaming oversight, where these interests are not overridden by player data rights.
• Consent: Processing based on freely given, specific, and informed consent — primarily for marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

6 How We Use Your Data

ph636 uses personal data collected from players for the following purposes:

• Creating and managing your ph636 player account and authenticating your identity on login;
• Completing KYC verification as required by applicable Philippine gaming regulations and AML obligations;
• Processing deposits and disbursing withdrawals through your nominated payment method (GCash, Maya, bank transfer, etc.);
• Providing customer support, investigating complaints, and resolving disputes relating to your account or game results;
• Detecting, preventing, and investigating fraud, money laundering, and other prohibited activities on the platform;
• Monitoring platform usage for responsible gaming purposes — including identifying patterns that may indicate problem gambling behavior;
• Sending transactional communications (account confirmations, deposit receipts, withdrawal notifications, security alerts);
• Sending promotional offers, bonuses, and marketing communications, where you have opted in to receive such communications;
• Complying with legal obligations, including record-keeping requirements under Philippine AML regulations, tax laws, and PAGCOR reporting obligations;
• Improving platform performance, game selection, and user experience through aggregated and anonymized analytics.

7 Data Sharing & Disclosure

ph636 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual safeguards:

• Payment Processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other payment partners, for the purpose of processing deposits and withdrawals.
• Game Content Providers: Third-party game studios and platform providers (such as Pragmatic Play, PG Soft, NetEnt) whose games are integrated into ph636. Data shared is limited to session and transaction identifiers necessary for game functionality and dispute resolution.
• Identity Verification Services: Third-party KYC and document verification providers, for the purpose of fulfilling identity verification obligations.
• Regulatory Authorities: PAGCOR and other competent Philippine government authorities, where disclosure is required by law, court order, or regulatory direction.
• Law Enforcement: Philippine law enforcement and anti-money laundering authorities (AMLC), where disclosure is legally required in connection with AML investigations or other criminal proceedings.
• Technology Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers operating under data processing agreements that obligate them to handle ph636 player data only as instructed and with equivalent security standards.

8 Cookies & Tracking Technologies

ph636.org uses cookies and similar technologies to operate the platform, maintain session state, and analyze usage patterns. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the ph636 platform — including session authentication tokens, security cookies, and load balancing. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Store your preferences such as language settings, remembered device status, and game lobby layout preferences to improve your experience on return visits.
• Analytics Cookies: Collect anonymized or pseudonymized data about how players navigate and use ph636.org, used to improve platform performance and identify technical issues. ph636 uses only privacy-respecting analytics services for this purpose.

You may control cookie preferences through your browser settings. Note that disabling certain cookies may affect platform functionality. ph636 does not use third-party advertising or tracking cookies for behavioral advertising purposes.

9 Data Storage & Security

ph636 implements the following technical and organizational security measures to protect your personal data:

• All data transmitted between your device and ph636.org is encrypted using TLS (Transport Layer Security) encryption, indicated by the HTTPS protocol and padlock icon in your browser.
• Personal and financial data stored on ph636 servers is encrypted at rest using industry-standard encryption algorithms.
• Access to player personal data is restricted to authorized ph636 personnel and authorized third-party processors through role-based access controls.
• ph636 systems are monitored continuously for unauthorized access attempts, anomalous activity, and security incidents.
• In the event of a personal data breach that is likely to result in a risk to player rights and freedoms, ph636 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by the DPA.

10 Data Retention Periods

ph636 retains personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required by law. The following general retention guidelines apply:

• Active Accounts: Personal data associated with active ph636 accounts is retained for the duration of the account relationship and for a period of five (5) years following account closure.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of five (5) years from the date of transaction in accordance with AMLA obligations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the last transaction date, whichever is later, as required by applicable AML regulations.
• Customer Support Records: Communication records with ph636 support are retained for three (3) years from the date of the last interaction.
• Technical & Log Data: Server logs and technical data are typically retained for 90 days unless retained longer for security investigation purposes.
• Marketing Preferences: Consent records and marketing preference data are retained for the duration of the account relationship and for one (1) year following account closure.

Upon expiry of the applicable retention period, ph636 will securely delete or anonymize personal data in accordance with its data disposal procedures.

11 Your Rights Under the Data Privacy Act

As a data subject under Republic Act 10173 (Data Privacy Act of 2012), ph636 players have the following rights with respect to their personal data:

• Right to Be Informed: The right to know whether ph636 holds personal data about you and how it is being processed — fulfilled by this Privacy Policy.
• Right of Access: The right to obtain a copy of the personal data ph636 holds about you, along with information about how it is used.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. For most basic account information, you may update this directly in your ph636 Account Settings.
• Right to Erasure ("Right to be Forgotten"): The right to request deletion of your personal data. Note that this right may be limited where ph636 is required by law to retain certain data — for example, AML transaction records.
• Right to Object: The right to object to certain types of processing, including direct marketing communications and processing based on legitimate interests.
• Right to Data Portability: The right to receive a copy of certain personal data in a structured, commonly used format, enabling you to transfer it to another service provider.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated. The NPC may be contacted through official Philippine government channels.

To exercise any of these rights, please submit a written request to the ph636 Data Protection Officer at [email protected] with the subject line "Data Rights Request." ph636 will acknowledge your request within five (5) business days and provide a substantive response within fifteen (15) business days. In complex cases, this period may be extended by a further 15 business days with notification.

12 Children & Minors

ph636 is strictly restricted to persons aged 21 years and above in the Philippines. ph636 does not knowingly collect personal data from persons under the age of 21. The platform's KYC verification process is designed to prevent registration and participation by underage individuals.

If ph636 becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, the data will be deleted to the extent permitted by applicable law, and the matter will be escalated in accordance with ph636's compliance procedures.

If you believe that a minor has registered on ph636 or has accessed the platform, please notify us immediately at [email protected].

13 Third-Party Links & Integrations

ph636.org may contain references to, or integrations with, third-party services — including payment providers such as GCash and Maya, and game content from third-party studios. When you interact with these third-party services, you are subject to their own privacy policies and terms.

ph636 is not responsible for the privacy practices or data handling of third-party services. ph636 recommends that players review the privacy policies of any third-party service they interact with in connection with their ph636 account, including payment providers and banking applications used for deposits or withdrawals.

14 Changes to This Privacy Policy

ph636 reserves the right to update this Privacy Policy at any time to reflect changes in data practices, applicable law, or platform services. The following procedure applies:

• Material changes that may affect player rights will be communicated by email to registered account holders at least 14 days before the updated Policy takes effect.
• Non-material changes such as clarifications or typographical corrections may be made at any time without advance notice.
• The effective date at the top of this Policy will always reflect the most recent version. Players are encouraged to review this page periodically.
• Continued use of the ph636 platform following the effective date of a revised Privacy Policy constitutes acceptance of the updated terms. If you disagree with a material change, you have the right to close your account before the change takes effect.

15 Contact & Data Protection Officer

For privacy-related inquiries, data rights requests, or concerns about ph636's data practices, please contact the ph636 Data Protection Officer through the following channel:

• Email: [email protected] — please include "Privacy / DPO" in your subject line
• Response Time: Acknowledgment within 5 business days; full response within 15 business days
• Language: English and Filipino
• Platform: ph636.org

If you believe that ph636 has not resolved your privacy concern to your satisfaction, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines through official NPC channels.