35ph Privacy Policy

1 Data Controller

The data controller responsible for your personal data is the operator of https://35ph.one ("35ph," "we," "us," "our"), a PAGCOR-licensed online gaming platform operating in the Republic of the Philippines. References to the "Platform" in this Privacy Policy mean the 35ph website and all services accessible through it.

For all data privacy matters, including the exercise of your rights under the Philippine Data Privacy Act of 2012 (RA 10173), please contact our Data Protection Officer at [email protected]. We respond to all privacy-related queries within ten (10) business days.

2 Data We Collect

35ph collects personal data that is necessary for the operation of a regulated online gaming platform. The categories of data we collect include:

Identity & Registration Data

• Full legal name, date of birth, and nationality;
• Email address and Philippine mobile number;
• Username and encrypted password;
• Government-issued identification documents submitted during KYC verification (e.g., Philippine Passport, Driver's Licence, SSS ID, UMID);
• Selfie or photograph submitted for identity verification purposes.

Financial Data

• GCash account details, PayMaya account details, or bank account information provided for deposit and withdrawal processing;
• Transaction history, including deposit amounts, withdrawal requests, and processing dates;
• Details of any chargebacks, disputes, or fraud investigations involving your Account.

Gaming & Usage Data

• Game play history, bet amounts, game outcomes, and session durations;
• Bonus and promotional activity, including wagering progress;
• Responsible gaming tool settings, including deposit limits, self-exclusion status, and session reminders.

Technical & Device Data

• IP address and approximate geolocation;
• Browser type, device type, operating system, and screen resolution;
• Session timestamps and Platform navigation patterns;
• Cookie identifiers and similar tracking technology data.

Communications Data

• Records of your communications with 35ph customer support, including live chat transcripts and email correspondence;
• Survey responses, feedback submissions, and promotional opt-in preferences.

3 How We Collect Your Data

35ph collects personal data through the following means:

• Directly from you — when you register an Account, complete KYC verification, make deposits or withdrawals, contact support, or respond to promotions;
• Automatically — through cookies, web beacons, and server logs as you use the 35ph Platform;
• From third parties — including KYC verification service providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), fraud prevention services, and PAGCOR where required for regulatory compliance;
• From publicly available sources — where necessary for AML compliance checks or fraud investigation purposes.

4 How We Use Your Data

35ph uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your 35ph Account, including authentication and session management;
• Payment processing: Processing deposits and withdrawal requests through your chosen Philippine payment method;
• Regulatory compliance: Fulfilling our obligations under PAGCOR licensing conditions, the Philippine Anti-Money Laundering Act (RA 9160 as amended), and related regulations, including filing Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) where legally required;
• Identity verification: Conducting KYC checks to verify your identity and age (21+) prior to withdrawal processing and as required by PAGCOR;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, cheating, collusion, and unauthorised Account access;
• Responsible gaming: Administering self-exclusion programmes, deposit limits, and other responsible gaming tools; identifying players who may be at risk;
• Customer support: Responding to your queries, complaints, and dispute submissions;
• Platform improvement: Analysing usage patterns to improve the 35ph Platform, fix technical issues, and develop new features;
• Marketing communications: Sending promotional offers, bonuses, and relevant updates — where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 35ph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil your Account registration, game play, and payment transactions;
• Legal obligation: Processing required to comply with PAGCOR licensing, AML legislation, tax reporting, and other Philippine regulatory requirements;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights;
• Consent: Processing for optional marketing communications and certain cookie categories — you may withdraw consent at any time without affecting prior processing.

6 Data Sharing & Disclosure

35ph does not sell your personal data to third parties. We may share your data only in the following circumstances:

• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where legally required or upon receipt of a lawful request;
• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely for the purpose of processing your transactions;
• KYC and fraud prevention vendors: Third-party identity verification and fraud screening services engaged by 35ph to fulfil regulatory obligations;
• Technology providers: Platform hosting, customer support tools, and analytics vendors operating under contractual data processing agreements consistent with this Policy;
• Game content providers: Where necessary for the technical operation of specific games on the 35ph Platform, limited to session and technical data only;
• Law enforcement and legal proceedings: Where required by applicable Philippine law, court order, or with your explicit consent.

7 Data Retention

35ph retains your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law, whichever is longer. Specific retention periods include:

• Account data and KYC records: Retained for a minimum of five (5) years following Account closure, as required by Philippine AML regulations;
• Transaction and financial records: Retained for a minimum of five (5) years, in compliance with PAGCOR reporting requirements and Philippine tax regulations;
• Game play history: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes;
• Customer support communications: Retained for three (3) years following resolution of the relevant query or dispute;
• Marketing consent records: Retained until consent is withdrawn, plus a reasonable period thereafter for compliance documentation;
• Technical logs: Retained for up to twelve (12) months for security monitoring and fraud investigation purposes.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with 35ph's data destruction procedures.

8 Cookies & Tracking Technologies

35ph uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used include:

• Strictly necessary cookies: Required for Platform functionality, including session authentication and security. These cookies cannot be disabled without affecting Platform operation;
• Functional cookies: Store your preferences, such as language settings and responsible gaming tool configurations;
• Analytics cookies: Collect aggregated data on how players use the 35ph Platform, used to improve performance and user experience. These do not identify you personally;
• Marketing cookies: Used to display relevant promotions within the 35ph Platform. These require your consent and may be disabled at any time through your browser settings or our cookie management tool.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect Platform functionality, including your ability to log in to your 35ph Account.

9 Data Security

35ph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 35ph Platform;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Role-based access controls limiting internal access to personal data to authorised personnel only;
• Two-factor authentication available for all 35ph player accounts;
• Regular security audits and penetration testing of Platform infrastructure;
• Incident response procedures compliant with the National Privacy Commission's personal data breach notification requirements.

In the event of a personal data breach affecting your data, 35ph will notify you and the National Privacy Commission in accordance with RA 10173 and applicable NPC guidelines within the legally required timeframe.

10 Your Rights Under the DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 35ph:

• Right to be Informed: The right to be notified of how your personal data is collected and processed, as set out in this Privacy Policy;
• Right of Access: The right to request a copy of the personal data 35ph holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data, subject to applicable legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your specific situation;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

11 Children's Privacy

The 35ph Platform is strictly intended for adults aged 21 years and above, as required under PAGCOR regulations for casino-style online gaming in the Philippines. 35ph does not knowingly collect or process personal data of individuals under 21 years of age.

If 35ph becomes aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated Account. If you believe that a minor has accessed or registered on the 35ph Platform, please contact us immediately at [email protected].

12 Cross-Border Data Transfers

35ph's primary operations and data storage are based in the Philippines. In certain circumstances, your personal data may be processed by third-party vendors located outside the Philippines — for example, game content providers or international fraud screening services.

Where personal data is transferred outside the Philippines, 35ph ensures that appropriate safeguards are in place, including contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under RA 10173. Such transfers are conducted in accordance with NPC guidelines on cross-border data flow.

13 Changes to This Policy

35ph reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered players via email to the registered account address and/or by prominent notice on the 35ph Platform no less than seven (7) days prior to the effective date of the change.

Your continued use of the 35ph Platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. We encourage you to review this page periodically. The "Last updated" date at the top of this page reflects the most recent revision.

14 Contact & Data Protection Officer

For all privacy-related queries, data subject rights requests, or complaints, please contact the 35ph Data Protection Officer:

If you are not satisfied with 35ph's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint with the NPC is available on the NPC's official website.