Privacy Policy – 368phwin

368phwin is an online gaming and entertainment platform operating in the Philippines under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). The 368phwin platform offers online casino games, sports betting, live dealer games, bingo, slots, and related gaming entertainment services to eligible Filipino players aged 21 and above.

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), 368phwin acts as the Personal Information Controller (PIC) with respect to the personal data of its registered users and platform visitors. We determine the purposes and means of processing your personal data and are responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

Our designated Data Protection Officer (DPO) can be contacted at the details provided in Section 14 of this Policy.

368phwin collects the following categories of personal data from users of the platform:

368phwin does not collect sensitive personal information (as defined under RA 10173) unless strictly required for regulatory compliance, such as government-issued ID numbers for KYC purposes. We do not collect biometric data, health information, or political affiliations.

368phwin 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 promotions;
• Automated Collection: Technical data collected automatically when you access the 368phwin platform, including through cookies, web beacons, log files, and similar tracking technologies (see Section 7);
• Third-Party Sources: Identity and fraud-check data from KYC verification service providers; payment data from e-wallet and banking partners (GCash, Maya, BPI, BDO, UnionBank, and others); analytics data from platform analytics providers;
• Publicly Available Sources: In limited circumstances, publicly available information may be used to verify identity or investigate fraud, in accordance with applicable law.

368phwin processes your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 368phwin player account, including authentication and access control;
• KYC & Age Verification: To verify your identity and confirm that you meet the 21+ age requirement mandated by PAGCOR regulations;
• Payment Processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card, and to maintain accurate financial records;
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and other applicable Philippine laws and regulations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, collusion, and other prohibited conduct on the platform;
• Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Platform Improvement: To analyse usage patterns, improve platform performance, and develop new features and services;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided your consent to receive such communications. You may withdraw consent at any time.

368phwin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

Under the Philippine Data Privacy Act of 2012, 368phwin processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and 368phwin (i.e., the Terms & Conditions), including account management, payment processing, and game operation;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AML obligations, and tax reporting;
• Legitimate Interests: Processing is necessary for the legitimate interests of 368phwin, including fraud prevention, platform security, and responsible gaming monitoring, provided that such interests are not overridden by your rights and freedoms;
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

368phwin does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: GCash, PayMaya (Maya), BPI, BDO, UnionBank, Metrobank, Landbank, PNB, Security Bank, and other payment processors, for the purpose of processing deposits and withdrawals;
• KYC & Identity Verification Providers: Third-party identity verification services used to conduct KYC checks and age verification in compliance with PAGCOR requirements;
• Game Content Providers: Licensed game software providers whose games are hosted on the 368phwin platform, to the extent necessary for game operation and dispute resolution;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation;
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process;
• IT & Platform Service Providers: Cloud hosting, cybersecurity, analytics, and customer support technology providers who process data on our behalf under strict data processing agreements.

368phwin uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and analyse platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the platform, including session management, authentication, and security. These cookies cannot be disabled without affecting platform functionality;
• Functional Cookies: Used to remember your preferences, such as language settings and game preferences, to provide a more personalised experience;
• Analytics Cookies: Used to collect anonymised information about how visitors use the 368phwin platform, including pages visited, time spent, and navigation paths. This data helps us improve platform performance and user experience;
• Marketing Cookies: Used to deliver relevant promotional content and track the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 368phwin platform. For strictly necessary cookies, no consent is required as they are essential to platform operation.

368phwin retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following retention periods apply:

• Account & Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AML obligations;
• Financial & Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act;
• Gaming & Wagering Records: Retained for a minimum of three (3) years from the date of the gaming session;
• Customer Support Communications: Retained for two (2) years from the date of the last interaction;
• Marketing Preferences: Retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations;
• Technical & Log Data: Retained for up to twelve (12) months from the date of collection.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures. Where data is anonymised, it may be retained indefinitely for statistical and analytical purposes.

368phwin implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the 368phwin platform is encrypted using industry-standard 256-bit SSL/TLS encryption;
• Access Controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis, with role-based access controls and multi-factor authentication for administrative systems;
• Secure Infrastructure: The 368phwin platform is hosted on secure, PAGCOR-compliant infrastructure with regular security audits, penetration testing, and vulnerability assessments;
• Data Minimisation: We collect only the personal data that is strictly necessary for the specified purposes and do not retain data beyond the applicable retention periods;
• Incident Response: We maintain a data breach response plan and will notify the National Privacy Commission (NPC) and affected individuals of any personal data breach within 72 hours of discovery, as required by RA 10173.

While 368phwin takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your 368phwin login credentials and for ensuring the security of the device you use to access the platform.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 368phwin:

To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 14. We will respond to all verified requests within fifteen (15) business days. We may request proof of identity before processing your request to protect against unauthorised access.

If you believe that 368phwin has not handled your personal data in accordance with RA 10173, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The 368phwin platform is strictly intended for persons aged 21 years and above, in compliance with PAGCOR regulations governing online gaming in the Philippines. 368phwin does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete all personal data collected from that individual, and, where applicable, report the matter to the relevant authorities.

If you are a parent or guardian and believe that your child under 21 has registered on the 368phwin platform, please contact us immediately at the details in Section 14 so that we can take appropriate action.

In the course of operating the 368phwin platform, your personal data may be transferred to and processed in countries outside the Philippines, for example where our technology service providers or game content partners are located in other jurisdictions.

Where such cross-border transfers occur, 368phwin ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries that have been assessed as providing an adequate level of data protection;
• Implementing contractual clauses with overseas recipients that require them to protect your personal data to a standard equivalent to that required under RA 10173;
• Obtaining your consent to the transfer where required by applicable law.

By using the 368phwin platform, you acknowledge and consent to the transfer of your personal data to overseas recipients as described in this section, subject to the safeguards outlined above.

368phwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, we will notify registered users via email or a prominent notice on the platform at least seven (7) days before the changes take effect.

The effective date of the most recent version of this Policy is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how 368phwin protects your personal data. Your continued use of the platform following the publication of an updated Policy constitutes your acceptance of the revised terms.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 368phwin, please contact our Data Protection Officer (DPO):

For complaints regarding our data processing practices that have not been resolved to your satisfaction, you may also contact the National Privacy Commission (NPC) of the Philippines through its official channels.