36ji Casino – Privacy Policy

1 Introduction

36ji Casino Philippines is committed to protecting the privacy and personal data of every player. We take data protection seriously — not merely as a legal obligation, but as a core part of our promise to Filipino players that 36ji is a trustworthy platform where your information is handled with the same care as your money.

This Policy describes the types of personal information we collect from you, the purposes for which we process that information, the circumstances under which it may be shared with third parties, how long we retain it, and the rights available to you under applicable Philippine law. 36ji processes all personal data in compliance with the Data Privacy Act of 2012 (Republic Act 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

2 Data We Collect

36ji collects the following categories of personal information from players and platform users:

a) Registration Data:

• Full legal name as it appears on government-issued identification
• Date of birth (used for age verification — players must be 21 or older)
• Philippine residential address
• Mobile number (Philippine format: +63 9XX)
• Email address
• Username and hashed password (passwords are never stored in plain text)

b) KYC / Identity Verification Data:

• Scanned or photographed copies of valid Philippine government-issued identification
• Selfie or live photo for liveness verification where required
• Proof of Philippine residential address (utility bill, bank statement, or barangay certificate)
• Taxpayer Identification Number (TIN) where required by PAGCOR or AMLC guidelines

c) Financial & Transaction Data:

• GCash or Maya account number / registered mobile number
• Bank account details (BPI, BDO, Metrobank, or other PH banks) where applicable
• Deposit and withdrawal transaction history in PHP
• Bonus and promotional credits history

d) Gaming & Behavioral Data:

• Game session logs, bet history, game outcomes, and RTP data
• Platform usage patterns, feature interactions, and session duration
• Responsible gaming settings (deposit limits, session timers, self-exclusion status)

e) Technical Data:

• IP address and approximate geographic location (region/city level)
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookie identifiers and analytics data (see Section 6)

3 How We Use Your Data

36ji uses your personal information for the following purposes:

• Account creation and management — to register, verify, and maintain your 36ji player account
• Age and identity verification — to confirm that all players are 21 years or older and are who they claim to be, as required by PAGCOR
• Payment processing — to facilitate PHP deposits via GCash, Maya, and bank transfers, and to process withdrawal requests
• Regulatory compliance — to fulfill obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160 as amended), and AMLC directives, including Suspicious Transaction Reporting (STR) and Cash Transaction Reporting (CTR)
• Game service delivery — to provide access to slots, live dealer games, sports betting, bingo, and specialty games
• Customer support — to respond to queries, investigate complaints, and resolve disputes raised through 36ji's support channels
• Security and fraud prevention — to detect, investigate, and prevent unauthorized account access, bonus abuse, money laundering, and other prohibited activities
• Responsible gaming — to apply deposit limits, session controls, and self-exclusion settings you configure, and to identify patterns that may indicate problem gambling
• Marketing communications — to send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications
• Platform improvement — to analyze aggregated, anonymized usage data to improve 36ji's platform performance, game selection, and user experience

36ji will not use your personal data for any purpose incompatible with those listed above without first obtaining your separate consent or as required by law.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012, 36ji processes your personal information on the following legal bases:

• Contractual necessity: Processing required to perform the gaming services agreement you entered into when creating your 36ji account, including payment processing and account management.
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulatory requirements, AML/CTF obligations under RA 9160, data breach notification requirements, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics — where such interests are not overridden by your fundamental privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given clear, freely provided, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 KYC & Identity Verification

In compliance with PAGCOR's Know Your Customer (KYC) framework and the Philippines' Anti-Money Laundering Act, 36ji is legally required to verify the identity of all players before enabling full deposit and withdrawal access. KYC is not optional — it is a regulatory requirement for all licensed Philippine online gaming operators.

KYC documents submitted to 36ji are processed by trained compliance staff and/or accredited third-party identity verification service providers operating under data processing agreements with 36ji. All KYC data is transmitted and stored using 256-bit AES encryption. Documents are used exclusively for the purposes of identity verification and regulatory compliance — they are never sold or used for commercial profiling.

Players who are unable or unwilling to complete KYC will have their accounts restricted to demo mode only — no real-money deposits, withdrawals, or bonus claims until verification is completed. This is a PAGCOR compliance requirement that 36ji cannot waive under any circumstances.

6 Cookies & Tracking Technologies

36ji uses the following categories of cookies and similar tracking technologies on the platform:

• Strictly necessary cookies: Required for platform operation — session authentication, security tokens, and login state management. These cannot be disabled without breaking platform functionality.
• Performance cookies: Collect anonymized data about page load times, game performance, and error rates to help 36ji maintain platform reliability. No personally identifiable information is included in performance cookie data.
• Functional cookies: Remember your language preferences, display settings, and game lobby filter configurations between sessions.
• Analytics cookies: Used to understand aggregated user behavior on the platform — which games are most popular, which features are most used, and where players encounter friction. Analytics data is anonymized before analysis.

You may manage non-essential cookie preferences through your browser settings. Disabling functional or analytics cookies will not affect your ability to play games at 36ji. Instructions for managing cookies are available in your browser's help documentation.

7 Data Sharing & Disclosure

36ji does not sell, rent, or trade your personal information to third parties for commercial purposes. Your data may be shared with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment processors: GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other Philippine payment service providers necessary to process your deposits and withdrawals.
• KYC and compliance providers: Third-party identity verification service providers engaged to process KYC documents under data processing agreements with 36ji, subject to equivalent data protection standards.
• Game providers and studios: Software providers who supply games to the 36ji platform may receive session and game play data necessary to deliver their game services. Game providers do not receive your financial or identity documentation.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government bodies as required by law or in response to a lawful order.
• Law enforcement: Philippine law enforcement agencies (PNP, NBI) in response to a lawful subpoena, court order, or investigation related to fraud, money laundering, or other criminal activity involving the 36ji platform.
• Corporate transactions: In the event of a merger, acquisition, or sale of 36ji's business assets, player data may be transferred to the acquiring entity, subject to equivalent privacy protections and prior notification to affected players.

8 Data Retention

36ji retains personal data for the periods required by applicable Philippine law and regulatory guidance:

• Active account data: Retained for the duration of your 36ji account plus five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the date of the last transaction, in accordance with RA 9160 (AMLA) requirements.
• Transaction and gaming records: Retained for five (5) years following the date of the transaction, per AMLC and PAGCOR record-keeping rules.
• Support and complaint records: Retained for three (3) years following resolution of the matter.
• Marketing consent records: Retained for as long as your consent remains active plus one (1) year following withdrawal of consent.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with NPC guidelines. Anonymized, aggregated data may be retained indefinitely for statistical and platform improvement purposes.

9 Data Security

36ji implements the following technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 36ji platform
• AES-256 encryption for all sensitive data at rest, including KYC documents and financial records
• Hashed and salted password storage — plaintext passwords are never stored or accessible to 36ji staff
• Multi-factor authentication (MFA) available for all player accounts and mandatory for 36ji administrative access
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• Regular penetration testing and vulnerability assessments of the 36ji platform and infrastructure
• Incident response procedures aligned with NPC data breach notification requirements

In the event of a personal data breach that poses a risk to your rights and freedoms, 36ji will notify the National Privacy Commission within 72 hours of becoming aware of the breach and will notify affected players without undue delay, in accordance with NPC Circular 16-03.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 36ji:

To exercise any of these rights, contact 36ji's Data Protection Officer using the details in Section 13. 36ji will respond to all verified data subject requests within thirty (30) calendar days.

11 Children & Minors

The 36ji platform is strictly restricted to individuals who are 21 years of age or older, in compliance with PAGCOR's regulations for Philippine online gaming. 36ji does not knowingly collect personal information from individuals under 21 years of age.

If 36ji discovers or is notified that personal data has been collected from an individual below the minimum age requirement, that account will be immediately suspended, all personal data associated with the account will be securely deleted as soon as legally permissible, and any deposits will be returned in accordance with PAGCOR's guidelines. Parents or guardians who believe a minor has registered with 36ji should contact support immediately.

12 Changes to This Privacy Policy

36ji may update this Privacy Policy periodically to reflect changes in applicable law, regulatory guidance, our data processing practices, or platform features. Material changes to this Policy will be notified to registered players via platform notification and/or email to the registered address on file at least fourteen (14) days before the changes take effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the 36ji platform following the effective date of an updated Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must discontinue use of the platform and may request account closure.

13 Contact & Data Protection Officer

For questions, requests, or complaints regarding this Privacy Policy or the handling of your personal data by 36ji Casino Philippines, please contact:

• Data Protection Officer (DPO), 36ji Casino Philippines
• Email: [email protected]
• Support: 24/7 Live Chat via your 36ji account dashboard
• Response time: All data privacy requests will be acknowledged within 3 business days and resolved within 30 calendar days

If you are not satisfied with 36ji's response to your privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines in accordance with the Data Privacy Act of 2012.